Updated: April 2018
Your privacy is important
- What personal data we collect;
- How we collect your personal data;
- How we use your personal data.
SPMC may from time to time provide you with additional information which is specific to certain products or services in addition to this Policy. SPMC may also give you additional notices while using our products or services. If there is a difference between such notices and this Policy, the notices prevail.
SPMC products or services may contain links to other companies’ websites and services that have their own privacy policies. SPMC is not responsible for the privacy practices of others. SPMC encourages you to read their privacy notices in order to protect your personal data.
Please do not use our products and services or provide SPMC with your personal data if you do not agree with this Policy.
Personal Data We Collect
You may provide SPMC your data directly, e.g. when you make a transaction with SPMC, use or register into SPMC products and services, take part in campaigns or research or otherwise interact with SPMC.
Depending on the products and services you use, the data we collect can include
- Contact details such as your name (including first, middle and last name), your email address, your phone number, postal address and any other contact details
- Demographic information such as gender, age, country, language
- Transaction information (if applicable) such as user names, password, feedback, payment data (e.g. bank account information, credit card details and any other financial information), delivery information. SPMC also may also maintain a record of your agreement, consent, preference, settings relating to, for example, location data, marketing and sharing of personal data. SPMC may, subject to applicable law, record your communication with SPMC or with other such contact points
- Medical or health sensitive information in relation to your physical or mental health information, such as description of symptoms, medical reports, diagnoses or other such information. If you are submitting these information for and on behalf of your family member, friend or any other third party (“Third Party”), please make sure that you have already obtained the relevant consent from the Third Party before submitting any such information to SPMC. The submission of any such Third-Party information to SPMC by you shall be deemed as a valid consent which you have already obtained from the Third Party. If not, please do not submit any Third-Party information to SPMC.
How We Process Personal Data
SPMC processes your personal data for the following purposes: (1) providing products and services we offer; (2) managing accounts / files which help maintain your content, preference, settings; (3) developing and managing products and services (such as sales, marketing, customer care and support); (4) communicating with you regarding updated notices relating to our products and / or services; (5) marketing and advertising when we have your consent or otherwise it is allowed.
- Providing the products and services – We may use your personal data to provide you with our products and services, to process your requests or as otherwise may be necessary to perform the contract between you and SPMC.
- Account / Files Management – We may use your personal data to manage accounts and files in relation to the products and services which we provide.
- Developing and managing products and services – We may use your personal data to develop and manage our products, services, customer care, sales and marketing. We may combine personal data collected in connection with your use of a particular SPMC product and/or service with other personal data we may have about you, unless such personal data was collected for a different purpose.
- Communications – We may use your personal data to communicate with you personally, for example to inform you about our service change, to send you critical alerts and other such notices relating to our products and/or services and to contact you for customer care related purposes.
- Marketing, advertising and making recommendations – We may contact you to inform you of new products, services or promotions we may offer and to conduct market research when we have your consent or it is otherwise allowed.
Third Party Elements
Our domains may include third party elements that set cookies on behalf of a third party, for example relating to third party social network.
Why We Share Personal Data
We do not sell, lease, rent or otherwise disclose your personal data to third parties unless otherwise stated below.
- Your consent – We only share your personal data if we have your specific consent or as necessary to provide you with the service as requested and authorized by you.
- SPMC companies and affiliates – We may share your personal data among other SPMC companies and affiliates. SPMC companies and affiliates include Ingenova Health Group Limited or any other companies which are within the same group of SPMC.
- Authorized third parties – We may share your personal data (excluding all medical and health information) with agents and vendors who process personal data for SPMC for the purposes described in this policy. For example, we may hire vendors and agents to provide services such as data management, customer care and support, managing marketing and promotion of our products and services. These companies need to comply with our privacy and security requirements and are now allowed to disclose the personal data received from us for other purposes.
- International transfers of personal data – SPMC may use resources and servers located in different countries around the world, hence your personal data may be transferred across international borders outside the country where you use our services. SPMC ensures that such a transfer is in compliance with the applicable laws and provide adequate protection for your personal data as required by applicable law.
- To comply with applicable law and valid legal process – SPMC may be required to disclose your personal data to certain authorities, law enforcement agencies or other third parties in the countries where we or third parties acting on our behalf operate in order to comply with applicable law.
- Mergers and Acquisitions – If we decide to sell, buy, merge or otherwise reorganize our businesses in certain countries, this may involve us disclosing personal data to prospective or actual purchasers and their advisers, or receiving personal data from sellers and their advisers.
Steps Taken To Safeguard Personal Data
SPMC cares about your privacy and is committed to protect your personal data. We take appropriate steps to address online security, physical security, risk of data loss and other such risks taking into consideration the risk represented by the processing and the nature of the data being protected. We use different technologies and have a variety procedures to protect your personal data from unauthorized access, use and disclosure.
Retention of Personal Data
SPMC retains your personal data as long as it is necessary to provide you with the relevant products and services, to comply with the applicable legal obligations, to resolve disputes and to enforce our contractual obligations.
You have a right to know what personal data we hold about you. You have a right to have incomplete, incorrect, unnecessary or outdated personal data deleted or updated. You have a right to unsubscribe from direct marketing messages and to request that we stop processing your personal data for direct marketing purposes or on other compelling legal grounds. However, if you opt-out from marketing and other communications from SPMC, critical alerts may still be sent to you.
You may exercise your rights by contacting us via email at firstname.lastname@example.org or send us a written notice to the following address:
Room 401, 4/F, Yue Hwa International Building, No. 1 Kowloon Park Drive, TST, Kowloon, Hong Kong.
SPMC may from time to time update this Policy or change, modify or withdraw access to this site at any time with or without notice. We will revise the “Updated” date accordingly. If this Policy is changed in a material, adverse way, SPMC will post a notice advising of such change at the beginning of this Policy. We recommend that you re-visit this Policy from time to time to learn of any such update or changes to this Policy.