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Private Policy

The Privacy Policy was updated on 1st Oct 2022. Please review to note the changes.

We, Dr520. Ltd., its subsidiaries, branches, controlled entities and affiliates (“Dr520”, “DrJ”, “we”,  “ours”,  “us”), welcome persons who access and/or register on our website and subscribe (“you”,  “your”) to our service (including all forms of access – website, apps, third-party apps powered by the Dr520 app, etc.) (the “Platform”). We ask that you review this privacy policy, which is intended to constitute a binding agreement that governs how we use your Personal Data (“Privacy Policy”). Your use of the Website in any form whatsoever will constitute agreement to this Privacy Policy.”

Purpose

As part of our commitment to act with integrity and respect individual privacy, we protect the personal data of our stakeholders, including employees, customers, shareholders, partners, suppliers and other individuals who trust us with information. “Personal Data” includes any information, which identifies or locates an individual, or is capable of doing so. To be a trusted business partner, Dr520 continually strives to protect Personal Data in accordance with applicable laws and regulations and industry standards. To that end, this policy guides how Dr520 collects, uses, stores, transfers and secures Personal Data.

Dr520 addresses the complexities and critical needs of today’s healthcare environment by providing a health data management tool (“HDM”) to service providers and a personal health record (“PHR”) to patients. Dr520 is dedicated to protecting the privacy of the users of any of our products or services and obtains Personal Data for business-related purposes, which may include, but are not limited to, designing, developing, selling and deploying a HDM, PHR and other health and wellness products and service, providing related support, opening your account, communicating with you, implementing your requests, hosting our website, running our mobile and web applications, authenticating your visits, providing personalized content, tracking your usage of our products and services, conducting analytics to promote or improve and enhance our services, conducting surveys or polls, obtaining testimonials, processing and delivering your test results, performing research and development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities. Such business-related services, such as surveys and polls, may not be applicable if accessing the Website via a third-party application.

Dr520’s HDM and PHR are developed for the highest levels of performance. We utilize world-class data centers equipped with modern technology to securely house sensitive data. Dr520 has numerous security measures in place to help protect against the loss, misuse, or alteration of information within the system. These measures include encryption of communications using the Secure Socket Layer (SSL) system and using a secure messaging system when you transmit personal information or requests to your medical providers or patients through our website. If you are a user of our website, in addition to this Privacy Policy, we may also require you to sign a user agreement or otherwise provide us with consent to utilize our services that explains how we use and disclose health information, and we may have additional privacy policies for users of these services. If such user agreements and/or additional privacy policies are consented to, they take precedence over this policy. You can find the user agreement for our physician portal and for our patient portal here. Please read these carefully before you use these services.

Revisions Changes and Updates

Dr520 may revise and update the Privacy Policy at any time, without notice to you. We encourage you to periodically reread this Privacy Policy, to see if there have been any changes to our policies that may affect you.

User Forum

We may offer forums for the exchange of information among our users. You agree to assume all responsibility for your use of such forums. In particular, you understand that we do not assure the accuracy, reliability, confidentiality or security of information made available through the use of our forums. You should understand that any information you disclose through our user forums will be accessible to the public. You agree that any information you place in user forums will become the exclusive property of Dr520.

Visitor Data

Information from computer/mobile device.

Any information about the computer system or other technological device that you use to access our Websites (www.drj.com.hk) or apps, such as the Internet protocol (IP) address used to connect your computer or device to the Internet, operating system type, and web browser type and version. If you access a DR520 website (www.drj.com.hk) or app via a mobile device such as a smartphone, the collected information will also include, where permitted, your phone’s unique device ID, advertising ID, geo-location, and other similar mobile device data.

Websites/communication usage information.

As you navigate through and interact with our Websites or newsletters, We use automatic data collection technologies to collect certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages. This information is captured using automated technologies such as cookies and web beacons, and is also collected through the use of third party tracking for analytics and advertising purposes. Further use of this site (by clicking, navigating or scrolling) and apps will be considered consent. 

Dr520 maintains permission to gather information on usage, such as numbers of visits, visitor source and visitor activity. This data is collected for the purposes of improving the overall user experience, which includes assisting in creating additional products and services that might be attractive to our users and our partners.

Third Party Services

We will share data with third parties for analytics purposes, in particular to improve service quality, features and standards. We use third-party data analytics platforms to improve the Dr520 service in a variety of ways. One such example: Mixpanel: We use Mixpanel as our primary analytics tool to understand how our customers use the Dr520 service and Mixpanel People to contact you about the use of our product. You can read the MixPanel Privacy Policy and opt-out. We also share information with third party services. To continue to improve our products and services, we or our contracted third-party partners may contact you to obtain feedback on our current offerings as well as to solicit feedback on how we may improve them.

Password Protection

Access to our products are password protected. We strongly recommend that you do not divulge your password to anyone and that you update your credentials on a regular basis. Exercise the utmost personal security in how you handle your password. Dr520 will never ask for your password in an unsolicited phone call or unsolicited email.

Emails

Your email address is never used for any purpose other than to communicate with you, either by us or our contracted third-party partners, or on your behalf. Your email may also be used for forgotten password or user account information, and in the future, it may be used as a tool for messaging. Unless you have opted out, we may also use your email address to send you promotional and marketing materials. For the use of Hong Kong and Macau users’ email addresses for sending promotional and marketing materials, please see the section “Use of Personal Data for Direct Marketing Purposes” below. Dr520 never shares your email address with external companies, unless we have explicitly contracted them to deliver services on our behalf. Additionally, users may revoke their email permission at any time to opt out of receiving any future information. Simply contact us at: support@dr520.com.hk .

The use of your email for sending promotional and marketing materials may not be applicable if accessing the Website solely via a third-party application.

Surveys, Questionnaires and Polls

Dr520 may ask you to participate in use surveys, questionnaires, or polls, to facilitate feedback and input from our users. When you respond to surveys, questionnaires or polls related to our site, this information is used for statistical purposes and to improve our products and services.

This section may not be applicable if accessing the Website solely via a third-party application.

Marketing Products and Services

We may place advertisements concerning the products and services of third parties on the interface to our services, so that you see them when you use the services. Unless you have opted out, we may also email marketing materials to you. For the use of Hong Kong and Macau users’ email addresses for sending promotional and marketing materials, please see the section “Use of Personal Data for Direct Marketing Purposes” below. We may receive remuneration from the suppliers of these products and services for placing their advertisements. We may use computerized processes to tailor the advertisements to you or to your use of the system. However, except as described above, we will not disclose, to any third party, any information that identifies you to enable the third party to market products or services to you directly.

The placement of advertisements and use of your email for sending marketing materials may not be applicable if accessing the Website solely via a third-party application.

Internet Cookies

Each time you access our services, Dr520 collects the limited information that your browser or app makes available whenever you visit any website or access a third-party service online. Additionally, Dr520 may place internet “cookies” on the computer hard drives of visitors to this Website. Information we obtain from cookies helps us to tailor our site to be more helpful and efficient for our visitors. The cookie consists of a unique identifier that does not contain information about you or your health history. We use two types of cookies, “session” cookies and “persistent” cookies. A session cookie is temporary and expires after you end a session and close your web browser. We use session cookies to help customize your experience on our site and maintain your signed-on status as you navigate through the features. Persistent cookies remain on your hard drive after you’ve exited from our site, until you erase them or they expire. Persistent cookies will not contain any personal information about you.

This section is not applicable if accessing the Website solely via a third-party application.

Links to other materials

This site provides links to sites operated by third parties. Dr520 has no control over the content of such linked sites, and is not responsible for it, or for the effect of your accessing a site through a link on our site. You should assume that any information that does not bear the Dr520/DrJ logo is operated by a third party, and you should read the site’s privacy notice before using it.

This section is not applicable if accessing the Website solely via a third-party application.

Age Limitation

We have no intention of accepting any information from individuals under the age of 18. If you are not yet 18 years of age, please leave this site immediately. Parents are urged to monitor and supervise their children’s online activity.

Use of your Information

We collect health information about you and store it in a personal health record. The health record created is the property of Dr520, though the health information it contains is your property. We use the information that we collect from you to provide our services to you. For this, we disclose health information to our employees and others involved in providing the care that you need. In addition to this we may use your Personal Data for one or more of the following purposes:

  • To provide information to you that you request from us relating to our services. We may share your health information with doctors or healthcare providers who will provide services to you through us.
  • As required for the operation of Dr520. We may use and disclose health information about you to review and improve the quality of services we provide, or to improve the competence and qualifications of our professional staff.
  • To provide information to you relating to other healthcare related products and services that may be of interest to you. Such additional information will no longer be provided if you have opted out from receiving such information. For our policy on using your Personal Data for promotional or marketing purposes, please see the section “Use of Personal Data for Direct Marketing Purposes” below.
  • To inform you of any changes to our website, services or goods and products.
  • To contact and remind you about products and services that you have selected either from us or our partners.
  • As necessary for medical reviews, legal services and audits, including fraud and abuse detection and compliance programs and business planning and management.
  • As part of a research study or data mining exercise with the purpose of deriving metrics or insights or other findings which may be used for promotional purposes or published in some other way. All data used for promotional purposes or published in any way will be aggregated and anonymized.
  • Dr520, like many businesses, sometimes hires other companies to perform certain business-related functions, such as processing payments. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function.

In order to provide our services to you we may provide your Personal Data to third parties, which may include, but are not limited to, the following:

  • Doctors or healthcare providers who will provide services to you through our website.
  • Your insurer(s) who referred you to use our service and may require proof of services rendered and/or a medical report before payment is made to Dr520; or if they are required to authorize services or referrals.
  • Third party service providers who have provided services to you or your physician (e.g. x-ray services or lab testing services) in order to obtain test results or for the purposes of issuing invoices.
  • Our business associates, such as our associates providing billing services, or performing administrative services for us. Dr520 enters agreements with each of these business associates that require these service providers to protect confidentiality and security of all information extended to them.
  • Other companies who help gather your information or communicate with you, such as research companies and ratings agencies, for the purposes of data mining and deriving other insights and in order to enhance the services provided under Dr520.
  • Government or regulatory bodies to whom Dr520 is required to make disclosure to under a legal and / or regulatory obligation in that jurisdiction applicable to Dr520.
  • Providers generating clinical notes (if applicable). We will not use or disclose your clinical notes without your prior written authorization except for the following: Use by the originator of the notes for your treatment, for training our staff, students and other trainees, to defend ourselves if you sue us or bring some other legal proceeding, if the law requires us to disclose the information to you or to another body or for some other reason, in response to health oversight activities concerning your physician, to avert a serious and imminent threat to health or safety, or to the coroner or medical examiner after death. To the extent you revoke an authorization to use or disclose your clinical notes, we will stop using or disclosing these notes, unless one the above items are applicable.

Use of your Personal Data for direct contact regarding any of the above notifications may not be applicable if accessing the Website solely via a third-party application.

Storing Your Personal Data

In operating our website, it may become necessary to transfer data that we collect from you to locations outside of Singapore, Hong Kong and Macau for processing and storing. By providing your Personal Data to us, you agree to this transfer, storing or processing. We do our utmost to ensure that all reasonable steps are taken to make sure that your data is treated stored securely. Dr520 protects Personal Data from loss, misuse, or unauthorized access, disclosure, alteration or destruction. We store Personal Data, regardless of its form, with security procedures appropriate to the sensitivity of the data. Unfortunately, the sending of information via the internet is not totally secure and on occasion such information can be intercepted. We cannot guarantee the security of data that you choose to send us electronically. Sending such information is entirely at your own risk.

We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain financial information such as credit card numbers. Rather, all such information is provided directly to our third-party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed at https://stripe.com/us/privacy.

Disclosing your Information

We will not disclose your personal information to any other party other than in accordance with this Privacy Policy and in the circumstances detailed below: In the event that we sell any or all of our business to a buyer. Where we are legally required by law to disclose your personal information. To further fraud protection and reduce the risk of fraud. The other circumstances discussed in this policy.

Use Of Personal Data for Direct Marketing Purposes​

For users outside of Hong Kong and Macau, “Personal Details” shall mean your Personal Data.

For Hong Kong and Macau users, “Personal Details” shall mean your name and contact information.

As well as for the purposes set out above, Dr520 intends to use your Personal Details for promotional or marketing purposes including sending you promotional materials and conducting direct marketing in relation to the following products, services, advice and subjects: medical/health treatment; medicine; educational; training; reward/loyalty/privilege programs; gymnasium and fitness; sporting and special events; sports and fitness equipment; food and beverage; health supplement; spa and similar relaxation activities and other leisure services; telecommunication and mobile services; internet; other retail/consumer products and services; wellness and charitable/non-profitable causes; hospitality services; insurance; (“Marketing Categories”).

For the purposes of direct marketing, we may provide your Personal Details to providers (and their agents) (whether within or outside of Dr520) of any of the Marketing Categories described above so that they can contact you and/or send you promotional materials and conduct direct marketing in relation to the products and services that they offer (these materials may be sent to you by postal mail, email or other means). We may provide your Personal Details to providers (whether within or outside of Dr520) of any of the Marketing Categories for gain.

For users outside of Hong Kong and Macau, unless you opt-out, you hereby consent to us using your Personal Details for the purposes set out above and/or providing your Personal Details to the transferees set out above and that we may use and/or provide your Personal Details for any promotional or marketing purpose.

For Hong Kong and Macau users only, before using your Personal Details for the purposes set out above and/or providing your Personal Details to the transferees set out above, we will obtain your auditable consent, and only after having obtained such auditable consent will we use and/or provide your Personal Details for any promotional or marketing purpose.

You may in the future withdraw your consent to the use and provision to a third party by Dr520 of your Personal Details for direct marketing purposes and thereafter Dr520 shall cease to use such data for direct marketing purposes.

If you wish to withdraw your consent, please inform us by writing to the address in the section on “Questions, Complaints and Contacts” or sending us an email. Any such request should clearly state details of the Personal Details in respect of which the request is being made.

This section may not be applicable if accessing the Website via a third-party application.

Third Party Links

On occasion, we include links to third parties on this Website. When we provide a link, it does not mean that we endorse or approve that site’s policy towards visitor privacy. You should review their privacy policy before sending them any Personal Data.

This section is not applicable if accessing the Website solely via a third-party application.

Personal Data Protection

Except as described in this Privacy Policy, Dr520 will not use personal and/or health information which identifies you without your written authorization. We work to ensure that Personal Data is accurate, complete and reliable for its intended use. If you do authorize Dr520 to use or disclose your personal and/or health information for another purpose, you may revoke your authorization in writing at any time. You are entitled to access your Personal Data at any time by requesting for the same in writing. As costs are incurred by Dr520 in recovering the Personal Data, Dr520 reserves the right to charge a nominal fee for the recovery of Personal Data requested. You have the right to request that Dr520 amends your personal and/or health information that you believe is incomplete or incorrect. You must make a request to amend in writing. We may deny the request if we do not have the information or did not create the information.

Questions, Complaints and Contacts​

Personal Data, send an email to support@dr520.com.hk or by mail to the address below:

Data Protection Officer
Dr520 Limited
Unit F, 23/F, Plaza 88,
88 Yeung Uk Road, Tseun Wan, Kln
Hong Kong SAR
China