Humansa | Privacy Policy

This Personal Information Collection Statement (this “Statement”) is made by Humansa Health (HK) Limited (“Humansa”, “we”, “us”, or “our”), and applies between us and you (“you”, or “your”). This Statement governs the collection, use and transfer of your personal data by Humansa and Humansa Health Service Providers (defined below). This Statement should be read together with the Terms and Conditions (if any) of the Humansa Application and/or other device(s) or application(s) (“Application”) and our website at www.humansa.com.hk (“Website”) (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data, this Statement shall prevail.

Humansa is part of the New World group of companies which includes Twilight Wood Limited and their respective subsidiaries in or outside Hong Kong from time to time as listed here (together, the “Humansa Health Service Providers”) whose activities include health care and senior care, sports and recreational facilities, food and beverages, and the provision of other health and wellness products and services (the “Goods and Services”).

In order to enable us and Humansa Health Service Providers to perform the Purposes (including the Purposes For Collecting Medical Information) (see below) (as the case may be), you are required to provide all the requested/mandatory personal data requested in the patient registration form. If you do not provide the required personal data, then we may not be able to perform the Purposes (including the Purposes For Collecting Medical Information) and/or provide certain goods or services to you (as the case may be).

The kinds of personal data we may collect from you include your name, gender, age (or age range), month and date of birth, identity card number (or passport number, where applicable), contact details, e-mail address, mailing/ residential/correspondence address, contact number, patient number, occupation, username and password, Log Files (see below), tracking information about your use of the Application/Website and transaction information (including your characteristics and transaction behavior) (“Tracking Data”), social media account information etc.

Please note that your identity card number (or passport number, where applicable) will only be used for verifying your identity when providing you with service(s) requested from any of the Humansa Health Service Providers, dealing with your enquiry and registration of the relevant services.

We may also collect from you and/ or third parties authorized by you, your medical information, history, condition, drug history and/ or other relevant information relating to your health (“Medical Information”) and retain the same for performing the Purposes For Collecting Medical Information).

The personal data to be collected from you (except for Medical Information) will be used and retained by us for the following purposes (as may be applicable from time to time) (together, the “Purposes”):

• Processing your enquiry about the services and/or related facilities, as the case maybe, provided by any of the Humansa Health Service Providers;
• Providing you with the relevant services requested from any of the Humansa Health Service Providers;
• Contacting you in connection with your enquiry and/or registration of the relevant services from any of the Humansa Health Service Providers, as the case may be;
• To process bookings made by you and send you event or booking reminders;
• Identifying and verifying your identity and/or as a member;
• Registering you as a user of the Application/Website;
• To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Application/Website;
• Following registration as a user, accessing your account information and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/unsubscribing from direct marketing, etc.);
• Research, development, and analysis in relation to your/customer behavior including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour to provide other services better tailored to your needs, and to assist us in selecting Marketing Subjects (see below) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining;
• For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website of, or by text message, email and/or mail, and/or other media whether now known or available in the future);
• Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website of, or by text message, email and/or mail, and/or other media whether now known or available in the future);
• Improving the Application/Website, Purposes, and the Goods and Services of Humansa andHumansa Health Service Providers;
• Direct marketing and cross-marketing for the Marketing Subjects, subject to your consent (see below section entitled “Direct marketing”);
• Data analytics, profiling, information management and database administration;
• Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal;
• Collection or recovery of any debt owed by you to us or any of the Humansa Health Service Providers;
• The normal management, operation, and maintenance of the Application/Website and the provision of the Goods and Services to you;
• Storing your personal data (whether by a single or multiple Humansa Health Service Providers (including us)) for the purpose of sharing such personal data with Humansa Health Service Providers for any and all of the other Purposes listed above; and/or
• Other purposes ancillary or related to the above.

For the avoidance of doubt, Purposes shall also include Purposes For Collecting Medical Information (see below).

The personal data to be collected from you (except for Medical Information) may also be provided to Humansa Health Service Providers for performing the Purposes, and subject to your consent, for performing direct marketing and/ or cross marketing for the Marketing Subjects (see below section entitled “Direct marketing”).

The Medical Information to be collected from you will be used and retained by us only for the following purposes (as may be applicable from time to time) (together, the “Purposes For Collecting Medical Information”):

• Providing you with the relevant services requested from any of the Humansa Health Service Providers;
• Direct marketing and cross-marketing for the Marketing Subjects, subject to your consent (see below section entitled “Direct marketing”);
• Data analytics and statistics
• Other purposes ancillary or related to the above.

Subject to your consent, some or all of your Medical Information may also be provided to Humansa Health Service Providers for performing the Purposes For Collecting Medical Information, direct marketing and/ or cross-marketing for the Marketing Subjects.

We may engage agents, contractors, suppliers and service providers in connection with the Purposes and/or the provision of the Goods and Services, e.g. IT providers, marketing agents, social media, research companies, and service providers of development and maintenance, administrative, data processing, digital storage, or other similar services (together, “Third Party Service Providers”), and may transfer to or share your personal data (except for Medical Information) with them for the Purposes . We may also share your personal data (except for Medical Information) with Humansa Health Service Providers and the social media platforms that we and/or Humansa Health Service Providers use for such Purposes. We would only share your Medical Information with Humansa Health Service Providers for Purposes For Collecting Medical Information with your consent . We may also share your Medical Information with Third Party Service Providers for data analytics, maintenance, administrative, data processing, data storage or other support services necessary to enable us and/ or Humansa Health Service Providers to carry out the Purposes For Collecting Medical Information with your consent. Where we are required by the law of any country or territory or requested by any court, regulatory body or governmental body of any country or territory, we may also disclose your personal data as required. In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business, your personal data may be transferred to the new entity as part of the transaction, provided that the new entity abides by this Statement and continues to exercise the same level of care, in respect of your personal data, as we would. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.

Your personal data may be shared with our New World group of companies which includes New World Development Company Limited, New World Property Management Company Limited, NWS Holdings Limited, New World China Land Limited, New World Department Store China Limited, K11 Concepts Limited, New World Loyalty Programme Limited, New World Group Charity Foundation Limited, K11 Art Foundation Limited, Humansa Limited and other affiliated or related companies from time to time as listed here for the purpose of research, development, and analysis in relation to your/customer behavior including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour to provide services better tailored to your needs, and to assist us in selecting Marketing Subjects (including Medical Marketing Subjects) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining.

Your personal data may be stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with Humansa Health Service Providers located within or outside Hong Kong. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the country or territory in which it is stored, and we procure by contract or use our reasonable endeavours to ensure that, Humansa Health Service Providers do the same.

Subject to your consent, we may use your personal data (including Medical Information) to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, Humansa Health Service Providers and/or our Marketing Partners in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, or other media whether now known or available in the future (together, “Communication Channels”).

Subject to your consent, we may also use your personal data (including Medical Information) for, or provide your personal data to Humansa Health Service Providers so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, Humansa Health Service Providers and/or our Marketing Partners in relation to the Marketing Subjects (see below) whether by any of the Communication Channels. Our “Marketing Partners” include health care and senior care, sports and recreational facilities, food and beverages, and other providers of health and wellness products and services in or outside Hong Kong.

We may, subject to your consent, share your personal data (including Medical Information) with Humansa Health Service Providers. We may also receive your personal data (including for Medical Information) from Humansa Health Service Providers, our Marketing Partners and/or other third parties. Subject to your consent given to Humansa Health Service Providers, our Marketing Partners and/or such third parties, we may also use such personal data to send you direct marketing about us, Humansa Health Service Providers and/or our Marketing Partners in relation to the Marketing Subjects.

The types of products, services, events and charitable initiatives that we and Humansa Health Service Providers may market to you include the following (together, the “Marketing Subjects”):

• goods and services offered by us in relation to the Goods and Services;
• pharmaceutical products, medical and pharmaceutical services, therapists;
• consumer products and services by retail outlets and/or online businesses, including health and personal cares, food and beverages, baby products, sports and leisure equipment, ;
• gym and fitness services;
• reward, loyalty, privileges programmes and promotions;
• restaurants, catering services on food, wine and beverage;
• medical services;
• professional advice and/or consultation on personal enhancement;
• charitable initiatives which support areas including sports, recreation, art and cultural programmes relief of poverty, advancement of education, advancement of religion and other purposes that are beneficial to the community

We cannot use or provide your personal data (including Medical Information) for direct marketing purposes unless you consent. Even if you give your consent, you can opt out of direct marketing at any time (or you may request that we cease to provide your personal data to third parties, at which point we will cease to do so), free of charge, by writing to our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or privacy@humansa.com.hk or privacy@nwd.com.hk (marked Confidential).

You have the right to:

• check whether we hold any of your personal data;
• access your personal data held by us;
• require us to correct any personal data which is inaccurate;
• ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.

If you would like to make a request in relation to the above (or make any general enquiries), please contact our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or privacy@humansa.com.hk or privacy@nwd.com.hk (marked Confidential). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.

[Humansa Health (HK) Limited] is part of the New World Group and we adopt the New World Group Privacy Policy Statement. You can find out more about our policy on personal data protection by accessing the New World Group Privacy Policy Statement available at http://www.nwd.com.hk/privacy-policy. If there is any inconsistency or conflict between the New World Group Privacy Policy Statement and this Statement, this Statement shall prevail.

Please also see the New World Group Privacy Policy Statement for our policies and information about;

• Our collection and/or use of log files (data relating to your use of/visits to this website, including but not limited to your IP address, domain name, browser type and access time);
• The use of cookies and other tracking mechanisms;
• Retention of your personal data;
• Third party merchants and/or websites that may be contained in this website;
• How we keep your personal data secure;
• Use of your personal data in legal proceedings.

If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by us, please contact our Personal Data Privacy Officer at:

• Humansa Health (HK) Limited
• 30/F New World Tower, 16-18 Queen’s Road, Central, HK
• Attention: Personal Data Privacy Officer (Legal Department)
• (Marked Confidential)

If you would like to make a request in relation to the above (or make any general enquiries), please contact our Personal Data Privacy Officer at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or privacy@humansa.com.hk or privacy@nwd.com.hk (marked Confidential). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.

If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.

This Statement may be updated from time to time to reflect changes to our policy with respect to personal data protection and/or changes to personal data/data privacy laws and regulations. Where there are significant changes, we will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Application/Website for updates to this Statement on a regular basis.

Nothing in this Statement shall limit your rights under the Personal Data (Privacy) Ordinance of the laws of Hong Kong.

This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.

Updated: [2022-09-06]