1. Introduction​

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​1.1 When you use Cognitact Limited’s (“Cognitact”, “Company”, “we” or “us”) services (“Services”) and our website [*](“Website”), you entrust us with personal information (“Personal Data”). We are committed to protecting the privacy and security of your personal information. This Privacy Policy is provided to you in connection with your dealings and provision of data or information to Cognitact. We treat your personal data in accordance to the Personal Data (Privacy) Ordinance (Cap.486) ("PDPO") which regulates the storage, process, access and transfer of personal data in Hong Kong. The use of our Services are subject to our Terms of Use of Website and Services (“Terms and Conditions’) and shall be incorporated in this Privacy Policy. 

1.2 If you have any queries regarding our Privacy Policy, please contact our Customer Relationship Executive at (852) 2116 1676 /9805 1678 or enquiry@cognitact.com.

1.3 We and our Website may ask you to provide certain information through online resources and communications, including the Website, e-mails or other online methods (collectively, “Online Sources”) or offline channels. We shall treat the Personal Data that you provide from Online Sources and offline channels according to this Privacy Policy Statement and to applicable laws and regulations.

1.4 You have several choices regarding your visit on our Website. You could decide not to submit any Personal Data at all by not entering it into any forms or data fields on our sites and not using any available personalized services. However, non-provision of personal information requested by the Company may result in the Company being unable to process your application, request for information or services, enquiries and/or provide services or products to you if the processing of such personal information is necessary for such purpose(s).

1.5 Separate privacy notices apply for recruitment or employment purposes. 

1.6 This Privacy Policy is intended to ensure that you can make informed decisions about providing your personal information to Cognitact in accordance with this Privacy Policy.  Please be aware that this Privacy Policy replaces any notice or statement of similar nature that may have been provided to you previously.  When you click on “I Agree” or select any options with similar content, or log in, confirm, agree to, use or accept this Privacy Policy we provide via registration procedure or any other way, you consent to your personal information being collected, stored, used, processed, transferred, disclosed or shared in accordance with this Privacy Policy.

1.7 If you provide us with the personal information about other individuals, you must tell those individuals that you have provided us with their details and let them know where they can find a copy of this Privacy Policy.

 

2. Information Collected

 

2.1 We generally collect the following information or Personal Data:

(I) Information directly provided by you
(a) Registration information 
You can visit certain parts of our Website without providing any Personal Data. In certain circumstances (including but not limited to using our Services, creating or registering your account with our Website or making test appointment), you may need to provide us with your Personal Data, such as your name, address, phone number, e-mail address, or any other identifying information (“Registration Information”), when you registering an account or placing an order for our Services with us.
(b) Payment information
Payment details used to purchase our Services such as credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information. Card details are not stored by us and are managed by our third-party card processing provider. 
(c) Self-Reported Information 
You have the option to self-report and provide us with additional information about yourself through health surveys, forms, or features for the optimal performance of our Services, including but not limited to:
1 information about your personal traits (e.g. age and sex); 
2 ethnicity; 
3 health conditions;
4 other health-related information; and
5 your own medical history and your family history information (e.g. information similar to the foregoing about your family members). Before you disclose information about a family member, you acknowledge that you have obtained the permission from the relevant family member.
(collectively “Self-Reported Information”)

(II) Information relating to our Services
(a) Blood Sample
To use our Services, you shall conduct a blood test. Before conducting your blood test, you are strongly advised to review this Privacy Policy and our policy on the handling of your blood test sample as set out in the Terms and Conditions and this document. You will have to provide the Personal Data generated through the analysis of your blood test for engaging our Services. The blood sample collection will be performed by professional phlebotomists engaged by Cognitact. Upon receiving the blood sample, we will proceed to isolate the blood plasma from the blood sample and to analyze the blood plasma proteomic profile. We will dispose the residue of the blood sample after the blood plasma isolation. 
Unless we receive written objection and a request for immediate disposal of your  blood plasma, the blood plasma shall be disposed within 3 months upon the issuing of the test report for (inter alia) any necessary re-examination. With your explicit prior consent for the use of your blood plasma for research purpose, the blood plasma will be disposed of after 10 years from the issuing of the test report. When your blood plasma will be used for research purposes, it will be de-identified and will not be linked to your Registration Information. Should you wish to update your extract  blood plasma storage preference to dispose a stored sample, you can do so by emailing us (info@cognitact.com). We will only generate information about your blood plasma proteomic profile when analyzing and processing your blood sample and  blood plasma isolation. We will not use this sample to access your genetic information. 

(III) Automatically collected information
(a) Web behaviour information
We may collect information on how you make use of our Website. This information is collected through log files, cookies, and web beacon-, analytical- and advertising technologies][note: please confirm if applicable and whether there are other technologies used in collecting information on the Website. You can find more information in Clause 6.1 regarding our Cookie Policy.

We may receive your Personal Data as provided and supplied by you or referral from healthcare providers and/or medical practitioners for providing all or part of our Services and/or for purposes set out in Paragraph 3 below. For such Personal Data, we shall protect and safeguard them as provided in this Privacy Policy.

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3. Purposes of Collection

 

3.1 Cognitact, including its affiliates, subsidiaries, divisions and groups worldwide and/or the companies we hire to perform services on our behalf will use any Personal Data you choose to give us to provide you our Services and to comply with your requests for our Services. We shall retain control of and responsibility for the use of this information. Some of this data may be stored or processed at computers located in other jurisdictions, whose data protection laws may differ from the Hong Kong. In such cases, we shall take measures that appropriate protections are in place to require the data processor in that country to maintain protections on the data that are equivalent to those that apply in Hong Kong.

3.2 We may use the information and Personal Data you provided for the following purposes:

(i). in connection with operating, providing, analyzing and improving our Services. These activities may include (inter alia) the followings:
(a) creating an account for you subscribing to our Services, communicating with you;
(b) authenticating access to your profile and provide personalized content and information;
(c) delivering to you any test results and/or report or following up on the test results;
(d) sending reminders to you in relation to any follow-up tests;
(e) providing you with newsletter promotional materials or information of our products and services (if applicable);
(f) issuing surveys and/or questionnaires to collect additional Personal Information for provide Services to you;
(g) offering our aftersales services (if applicable);
(h) informing you of our Services charges (if applicable);
(i) detecting and/or protecting against error, fraud, infringement and/or other criminal malicious activity;
(j) handling your enquiries and/or complaints on our products and/or Services;
(k) optimizing your experience with us and improving our Website, products and/or Services; 
(l) any other specific purposes for which your personal data is collected by us (collectively from (a) to (l), the “Purposes”.)

(ii). in connection with processing, analyzing and delivering your blood testing results. In this connection, after we receive your blood test sample from our blood sample collection at our designated collaborating testing centers, we further analyze it to provide you with our test report. We continuously work to improve our Services based on our research and product development, and other technological advancements identified in scientific literature. If we are able to offer additional reports, or otherwise improve reports in the future, you may be notified of these changes.

(iii). in connection with the research and development activities in fields related to biometric information, including but not limited to healthcare services and pharmaceutical product development: 
(a) We may conduct researches sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or pharmaceutical companies.  Our researches may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on proteomic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care. Our research may use information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified  and/or information about a single individual's diseases or other traits/characteristics, but which is not necessarily tied to Personal Data (“Individual Information”), information regarding your blood plasma analysis, generated through processing of your blood sample by us, successors or assignees, or otherwise processed by and/or contributed to us (“Blood Plasma Analysis Information”) and Self-Reported Information.
(b) When your Blood Plasma Analysis Information, Individual Information and/or Self-Reported Information will be used for research purposes, it will be de-identified and will not be linked to your Registration Information;
(c) We may share summary statistics, which do not identify any particular individual or contain Individual Information, with our qualified research collaborators.
(d) There are some risks to sharing your Blood Plasma Analysis Information and/or Self-Report Information to us which includes (inter alia) the followings:
1. Your blood plasma test analysis, survey responses, and/or personally identifying information may be stolen in the event of a security breach. In the event of such a breach, if your data are associated with your identity, they may be made public or released to insurance companies, which could have a negative effect on your ability to, for example, obtain insurance coverage. In addition, if you or a family member has genetic data linked to your name or your family member's name in a public database, someone who has access to your genetic data might be able to link that data to your name or your family member's name through the publicly available genetic data. As you may appreciate, the said risk(s) cannot be completely eliminated in the technologies currently available, we have policies and securities measures (as set out in Paragraph 7) in place to minimize the possibility of such breach.
2. As with any online service, if you disclose your account password to others, they may be able to access your account and your Blood Plasma Analysis Information & Self-Reported Information.
3. There may be additional risks to participation that are currently unforeseeable.
(e) in connection with our marketing and other marketing communication directly with you:
1. By confirming your acceptance, you agree and consent that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You can unsubscribe from receiving these direct marketing and/or marketing communications or opt out from the same by following the procedure as set out in Paragraph 9.2 below.
2. No Third-Party Direct Marketing Use. We shall not sell or otherwise transfer the personally identifiable information that you provide to us at our Websites to any third parties for their own direct marketing use unless we provide clear notice to you and obtain your explicit consent for your data to be shared in this manner.
(f) in connection with processing payments for any Cognitact products and/or services and/or any refund thereof when you make a purchase directly from us online or offline;
(g) in connection with additional user information analysing blood samples or a biopsy; generating a report with or without discussions on the results and delivery of the same to you;
(h) in connection with our business development, such as for marketing and statistical analysis;
(i) to respond to appropriate requests of legitimate government agencies or where required by applicable laws, court orders, or government regulations;
(j) where needed for corporate audits or to investigate or respond to a complaint or security threat;

3.3 if you do not wish to use or provide your Personal Data for use of any purposes as described above, you may your opt-out right by notifying us.

 

4. Links to third parties

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4.1 Our Website contains links to other websites that are operated by third party companies with different privacy practice. The existence of such links on this Website does not constitute our approval, authorization or association with such websites. If you click on these links or use the services of these third parties, you will leave this Website. We recommend that you review the privacy policies of those third-party platforms before sharing your personal data with them.

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4.2 We have no control over the Personal Data that you submit or receive from these third parties and will not be responsible for the use of your Personal Data by these third parties, and we cannot guarantee that they have the same level of personal data protection policies as ours.

 

5. Transfer of Personal Information

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5.1 Personal information collected or held by the Company relating to you will be kept confidential, but the Company may transfer such personal information inside or outside the Hong Kong Special Administrative Region of the People’s Republic of China, for the purposes specified in paragraph 3 above to the following classes of transferees:

(a) healthcare providers and/or medical practitioners, with your explicit prior written consent to do so;

(b) for customer referred by healthcare providers and/or medical practitioners , by accepting our Services and conducting a blood test would constitute a consent from you for us to transfer your personal information collected to those healthcare providers and/or medical practitioners engage by the customers;

(c) any member and/or brand of the Group Companies who provides medical, health, insurance, wellness or other related services or products;

(d) any third parties engaged in connection with a member of the Group Company’s business who provides medical, health, insurance, wellness or other related services or products;

(e) any agent, contractor or other third party service providers who provides administrative, telecommunications, computer, payment, data processing, storage of analytics, printing, research, telemedicine, distribution or other services to the Company in connection with the operation of the business (including, without limitation, insurers, banks, lawyers and accountants);

(f) any member of the Group Companies and our affiliates or third parties involved in the marketing of services, products and other subjects (please see further details in paragraph 5 below);

(g) your employer, if your employer is paying for the services or products we are providing;

(h) third party reward, loyalty, co-branding and privileges programme providers and co-branding partners of a member of the Group Companies;

(i) financial institutions engaged by the Company or you for billing and payment purposes;

(j) any actual or proposed assignee, transferee, participant or sub-participant of all or a substantial part of our rights or business; and

(k) any person to whom the Company is under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice or guidelines binding on us including, without limitation, any applicable regulators, governmental bodies, industry recognised bodies, the Courts, and where otherwise required by law.

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5.2 We will only disclose personal information limited to that which is necessary to the above parties for the relevant purposes, who may process (including, without limitation, by recording, organising, structuring, storing, adapting, altering, retrieving, using, aligning, combining or erasing) your personal information for the relevant purposes set out in paragraph 3 above.

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5.3 In the event that we complete the acquisition of a new healthcare company or brand, we shall communicate with you through the communication channels you provided to us, and any personal information shall be treated in accordance with this Privacy Policy if it is practicable and permissible to do so.

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6. Use of Cookies

 

6.1 When you use our sites, we and third-party companies collect information by using cookies and other technologies such as pixel tags (for simplicity we refer to all such technologies as “cookies”). A cookie is a text file containing small amounts of information which a server may download to your computer, mobile or tablet when you visit a website or use an app. A pixel tag (sometimes called a web beacon) is an invisible image with a line of code which is placed within an email message or on a web page.

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6.2 There are different types of cookies which are used to do different things. These include letting you navigate between different pages on a website efficiently, remembering preferences you have given and helping us to identify ways to improve your overall site experience. Others are used to provide you with advertising, which is more tailored to your interests, or to measure the number of site visits and the most popular pages. To find out more about cookies visit aboutcookies.org or allaboutcookies.org.

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6.3 The information we obtain from our use of cookies will not usually contain your personal information. Although we may obtain information about your computer or accessing devices such as your domain, IP address, your browser type, operating system etc., this will not normally identify you personally. In certain circumstances, we may collect personal information about you - but only where you voluntarily provide it e.g. by completing an online inquiry form or where you purchase services from us.

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6.4 Most web browsers automatically accept cookies, but you may refuse to accept cookies by modifying the browser settings on your computer. If you choose to decline cookies, you may be unable to use certain interactive features of our sites.

 

7. Security and Retention

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7.1 The Company retains your personal information for as long as necessary for the purposes set out in this Privacy Policy, or otherwise agreed between you and us, unless otherwise required or permitted under applicable law.

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7.2 Where the Company no longer requires your personal information for the purposes under this Privacy Policy, or otherwise required under law, we will take appropriate steps to securely delete or destroy your personal information.

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7.3 We will take reasonable steps to securely store your personal information. This includes implementing a range of digital and physical security measures. In addition, we will restrict access to your personal information to those properly authorised to have access.

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7.4 Despite our security measures above, we cannot guarantee there shall be no breach of the security of your Personal Data. While we shall, as far as practicable, take measures to protect the relevant systems, networks, hardware and/or software and prevent any further breaches, we shall not be liable for any loss, damages, expenses or fees incurred as a result of or in connection with such security breach and/or the data loss.​

 

8. Privacy Policy Statement for Children

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Our Website is directed at an adult who is 18 years old or older. We do not intend to collect any Personal Data from anyone we know to be under the age of 18 without the prior consent of his/ her parent(s), guardian, or legal representative who has the right, upon request, to view the information provided by the child and/or to require that it be deleted.

 

9. Data Access and Correction

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9.1 You have the rights to:

(a) check whether the Company holds personal information relating to you and to access such personal information;

(b) request the Company to correct any personal information relating to you which is inaccurate;

(c) ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by the Company;

(d) request the Company to cease using and/or processing your personal information; and

(e) change your preference in respect of our use of your personal information.

 

9.2 You have the right to opt out for particular services or communications provided by us by notifying us in writing or by selecting the options of opting out of a number of sections as provided for in the Website. If you decide to unsubscribe from a service or communication, we will work to remove your information promptly, although we may require additional information before we can process your request.

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9.3 To exercise the above rights, please send your request in writing to:

By post: Customer Relationship Executive

Office 627, 6/F

Building 16W,

Hong Kong Science Park,

Shatin, Hong Kong

Or, by email: enquiry@cognitact.com

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9.4 We are entitled to charge a reasonable fee for processing your personal data access request.

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9.5 Nothing in this document shall limit your rights under PDPO.

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10. Language

 

The original English version of this Privacy Policy Statement has been translated into Chinese. In the event of a dispute about the contents or interpretation of this Privacy Policy Statement or inconsistency or discrepancy between the English version and the Chinese version of this Privacy Policy Statement, the English version shall prevail.

 

11. Amendments

 

This Privacy Policy may be amended from time to time without prior notice and the updated policy will be published on our Website.