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Privacy policy
This privacy policy ("Policy") describes how DEEPHEALTH LIMITED as a whole
("DEEPHEALTH LIMITED ", "DH", ”we", "us" or "our") collects, protects and uses the
personally identifiable information ("Personal Information") you ("User", "you" or "your")
may provide in the HealthCap mobile application and any of its products or services
(collectively, "Mobile Application" or "Services"). It also describes the choices available to
you regarding our use of your Personal Information and how you can access and update
this information. This Policy does not apply to the practices of companies that we do not
own or control, or to individuals that we do not employ or manage.


Collection of personal information
We receive and store any information you knowingly provide to us voluntarily when you
create an account, fill any online forms in the Mobile Application. When required, this
information may include your email address, name, phone number, or other Personal
Information. You can choose not to provide us with certain information, but then you may
not be able to take advantage of some of the Mobile Application's features, such as Health
Reports. Your data may be used in healthcare related research. Users who are uncertain
about what information is mandatory are welcome to contact us.


Collection of non-personal information
When you open the Mobile Application, our servers automatically record information that
your device sends. This data may include information such as your device's IP address
and location, device name and version, operating system type and version, language
preferences, information you search for in our Mobile Application, access times and dates,
and other statistics.


Use and processing of collected information
Any of the information we collect from you may be used to personalize your experience;
improve our Mobile Application; improve customer service and respond to queries and
emails of our customers; send notification emails such as password reminders, updates,
etc; run and operate our Mobile Application and Services. Non-Personal Information
collected is used only to identify potential cases of abuse and establish statistical
information regarding Mobile Application traffic and usage. This statistical information is
not otherwise aggregated in such a way that would identify any particular user of the
system.

We may process Personal Information related to you if one of the following applies: (i) You
have given your consent for one or more specific purposes. Note that under some
legislations we may be allowed to process information until you object to such processing
(by opting out), without having to rely on consent or any other of the following legal bases
below. This, however, does not apply, whenever the processing of Personal Information
is subject to European data protection law; (ii) Provision of information is necessary for
the performance of an agreement with you and/or for any pre-contractual obligations
thereof; (iii) Processing is necessary for compliance with a legal obligation to which you
are subject; (iv) Processing is related to a task that is carried out in the public interest or
in the exercise of official authority vested in us; (v) Processing is necessary for the
purposes of the legitimate interests pursued by us or by a third party. In any case, we will
be happy to clarify the specific legal basis that applies to the processing, and in particular
whether the provision of Personal Data is a statutory or contractual requirement, or a
requirement necessary to enter into a contract.


Information transfer and storage
Depending on your location, data transfers may involve transferring and storing your
information in a country other than your own. You are entitled to learn about the legal
basis of information transfers to a country outside the European Union or to any
international organization governed by public international law or set up by two or more
countries, such as the UN and about the security measures taken by us to safeguard your
information. If any such transfer takes place, you can find out more by checking the
relevant sections of this document or inquire with us using the information provided in the
contact section.


The rights of users
You may exercise certain rights regarding your information processed by us. In particular,
you have the right to do the following: (i) you have the right to withdraw consent where
you have previously given your consent to the processing of your information; (ii) you have
the right to object to the processing of your information if the processing is carried out on
a legal basis other than consent; (iii) you have the right to learn if information is being
processed by us, obtain disclosure regarding certain aspects of the processing and obtain
a copy of the information undergoing processing; (iv) you have the right to verify the
accuracy of your information and ask for it to be updated or corrected; (v) you have the
right, under certain circumstances, to restrict the processing of your information, in which
case, we will not process your information for any purpose other than storing it; (vi) you
have the right, under certain circumstances, to obtain the erasure of your Personal
Information from us; (vii) you have the right to receive your information in a structured,
commonly used and machine readable format and, if technically feasible, to have it
transmitted to another controller without any hindrance. This provision is applicable
provided that your information is processed by automated means and that the processing
is based on your consent, on a contract which you are part of or on pre-contractual
obligations thereof.


The right to object to processing
Where Personal Information is processed for the public interest, in the exercise of an
official authority vested in us or for the purposes of the legitimate interests pursued by us,
you may object to such processing by providing a ground related to your particular
situation to justify the objection. You must know that, however, should your Personal
Information be processed for direct marketing purposes, you can object to that processing
at any time without providing any justification. To learn, whether we are processing
Personal Information for direct marketing purposes, you may refer to the relevant sections
of this document.


How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact
details provided in this document. These requests can be exercised free of charge and
will be addressed by the Owner as early as possible and always within one month.


Newsletters
We offer electronic newsletters to which you may voluntarily subscribe at any time. You
may choose to stop receiving our newsletter or marketing emails by following the
unsubscribe instructions included in these emails or by contacting us. However, you will
continue to receive essential transactional emails.


Remarketing
We also may permit certain third-party companies to help us tailor advertising that we
think may be of interest to users and to collect and use other data about user activities in
the Mobile Application. These companies may deliver ads that might place cookies and
otherwise track user behavior.


Affiliates
We may disclose information about you to our affiliates for the purpose of being able to
offer you related or additional products and services. Any information relating to you that
we provide to our affiliates will be treated by those affiliates in accordance with the terms
of this Privacy Policy.


Links to other mobile applications
Our Mobile Application contains links to other mobile applications that are not owned or
controlled by us. Please be aware that we are not responsible for the privacy practices of
such other mobile applications or third-parties. We encourage you to be aware when you
leave our Mobile Application and to read the privacy statements of each and every mobile
application that may collect Personal Information. For avoidance of doubt, the data will not
be transferred to other parties.


Information security
We secure information you provide on computer servers in a controlled, secure
environment, protected from unauthorized access, use, or disclosure. We maintain
reasonable administrative, technical, and physical safeguards in an effort to protect
against unauthorized access, use, modification, and disclosure of Personal Information in
its control and custody. However, no data transmission over the Internet or wireless
network can be guaranteed. Therefore, while we strive to protect your Personal
Information, you acknowledge that (i) there are security and privacy limitations of the
Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all
information and data exchanged between you and our Mobile Application cannot be
guaranteed; and (iii) any such information and data may be viewed or tampered with in
transit by a third-party, despite best efforts.


Data breach
In the event we become aware that the security of the Mobile Application has been
compromised or users’ Personal Information has been disclosed to unrelated third parties
as a result of external activity, including, but not limited to, security attacks or fraud, we
reserve the right to take reasonably appropriate measures, including, but not limited to,
investigation and reporting, as well as notification to and cooperation with law enforcement
authorities. In the event of a data breach, we will make reasonable efforts to notify affected
individuals if we believe that there is a reasonable risk of harm to the user as a result of
the breach or if notice is otherwise required by law. When we do, we will post a notice in
the Mobile Application.


Legal disclosure
We will disclose any information we collect, use or receive if required or permitted by law,
such as to comply with a subpoena, or similar legal process, and when we believe in good
faith that disclosure is necessary to protect our rights, protect your safety or the safety of
others, investigate fraud, or respond to a government request. In the event we go through
a business transition, such as a merger or acquisition by another company, or sale of all
or a portion of its assets, your user account, and personal data will likely be among the
assets transferred.


Changes and amendments
We reserve the right to modify this Policy relating to the Mobile Application or Services at
any time, effective upon posting of an updated version of this Policy in the Mobile
Application. When we do so, we will revise the updated date at the bottom of this page.
Continued use of the Mobile Application after any such changes shall constitute your
consent to such changes.


Acceptance of this policy
You acknowledge that you have read this Policy and agree to all its terms and conditions.
By using the Mobile Application or its Services, you agree to be bound by this Policy. If
you do not agree to abide by the terms of this Policy, you are not authorized to use or
access the Mobile Application and its Services.


Disclaimer
The privacy policies set forth in this document hereof have been translated into Chinese.
If there is any discrepancy, inconsistency or ambiguity between the English version and
Chinese version of the privacy policies, the English version shall prevail.


Contacting us
If you have any questions about this Policy, please contact us at info@deephealth.com.hk.

This document was last updated on October 24, 2019.

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