Dickson Privacy Policy

About Dickson and this Privacy Policy

We, Dickson (“we”, “us”, “our”, “Company”, “DICKSON”), are committed to protecting your privacy. This Privacy Policy provides information on how we collect and use personal data. Dickson operates websites such as[Insert website] and any mobile apps we may publish (collectively, the "Website").

This Privacy Policy outlines the information we collect, the reasons for its collection, and how we may use and share it. We take our responsibilities under Hong Kong’s Personal Data Protection Ordinance (the “PDPO”) seriously and recognise the importance of the personal data you entrust to us.

The Website is not intended for use by children under the age of 18. We do not knowingly transact through the Website with anyone under 18 years of age. By providing personal data to us, you declare and affirm that you are at least 18 years of age and agree to the terms herein.

This Privacy Policy may be updated periodically; please check back frequently for changes. Any modifications will be posted and viewable on our Website.

If you have any questions about this Privacy Policy, including requests to exercise your legal rights, you can contact us via email at [insert email address].

What Information do we collect, and How?

"Personal data" is defined under the PDPO as information relating to a living individual that can be used to identify that individual, existing in a practicable form for access or processing. We receive or collect information about you when you provide it to us, use our Website, or interact with us.

When you interact with us, whether by using our Website or communicating with us, we may collect the following information about you:

Information you give us: You may provide us with information about yourself if you:
Show interest in our products and/or services.
Request, apply for, purchase, or subscribe to our or a Healthcare Provider’s products and/or services.
Open an account with us.
Communicate with us.
Provide feedback, comments, or reviews.
Depending on what you provide, this information can include your name, identification number, home address, health-related information, contact details (such as mobile number, email address), transactional information, credit card and/or other financial information used for a transaction, and location information of yourself and/or your computer or device.

Information our IT systems collect about you: Each time you visit the Website, certain information is created and automatically recorded by our IT systems. That information includes:

  • Internet protocol (IP) address.
  • Connection information (browser type and version, operating system and platform).
  • Unique reference number linked to data entered on our system.
  • Login details.
  • Full URL clickstream to, through, and from the Website (including date and time).
  • Cookie number.
  • Your activity on our Website, including pages visited and searches made.
  • Location data, if you activate geo-location services on our mobile or web-based applications.

Information we receive from other accounts or sources: We may receive information about you from third parties if you use any websites or social media platforms operated by them (e.g., Facebook, Instagram, Twitter) and have chosen to link your profile on our Website with your profile on those platforms. We may also receive or collect personal data about you from sources other than yourself. We may combine information received from other sources with information you provide to us and/or information we already hold about you, using this combined information for the stated purposes.

What do you use my Information for?

Dickson will/may collect, use, disclose, and/or process your personal data for one or more of the following purposes (the “Purposes”):

  • Processing, facilitating, and/or dealing with your interest in our or a Healthcare Provider’s products and/or services. This includes disclosing your personal data to a Healthcare Provider.
  • Considering, processing, facilitating (including risk or fraud analysis), dealing with, and/or managing your request, application, purchase, intended purchase, or subscription for our or a Healthcare Provider’s products and/or services (the “Transaction”).
  • Dealing with, facilitating, processing, and/or administering any account you open with us.
  • Facilitating, processing, dealing with, administering, and/or managing Transaction(s) or intended Transaction(s).
  • Providing products(s) or services to you.
  • Administering, facilitating, managing, processing, and/or dealing with your relationship with us or a Healthcare Provider.
  • Administering, facilitating, processing, and/or dealing in any matter(s) relating to your use of the Website or a Healthcare Provider's website, including location data collection and processing.
  • Monitoring, processing, and/or tracking your use of the Website to provide a seamless experience, facilitate or administer your use, and/or improve your experience.
  • Administering, facilitating, processing, and/or dealing in any transactions or activities carried out by you on the Website or a Healthcare Provider's website or mobile application.
  • Carrying out and/or facilitating your instructions or responding to any inquiry given by (or purported to be given by) you.
  • Contacting you or communicating with you via phone/voice call, text message, fax message, email, and/or postal mail for one or more of the Purposes. You acknowledge that such communication may involve disclosing certain personal data on correspondence or external mail covers for delivery purposes.
  • Conducting training to develop or improve our products or services and/or our staff’s and agents’ services and/or service quality, which may involve collecting, using, disclosing, or processing your personal data, including feedback or comments.
  • Carrying out due diligence or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations, governmental authority requirements, and/or our risk management procedures.
  • Preventing or investigating any fraud, unlawful activity, omission, or misconduct; dealing with conflict of interests; or dealing with and/or investigating complaints.
  • Carrying out fraud detection and/or credit risk control in relation to your Transactions/online transactions or attempted Transactions/online transactions.
  • Complying with or as required by any applicable law, governmental or regulatory requirements, or guidelines from regulatory or other authorities. This includes disclosing your personal data to such parties upon their request or direction.
  • Conducting research, analysis, and development activities (including data analytics, surveys, and/or profiling) to improve our products, services, and/or facilities, or to enhance your continued interaction with us related to the Website or your Transaction(s).
  • For marketing purposes, where you have provided consent, we may provide you with marketing, advertising, and promotional information, materials, and/or documents relating to products, services, and/or events (including those of third-party organisations like Healthcare Providers) that we or they may be selling, marketing, offering, organising, involved in, or promoting.
  • Storing, hosting, and backing up your personal data, whether within or outside Hong Kong SAR.
  • To facilitate and/or ensure the safety and security of our premises, customers, staff, and/or visitors; and to deal with disciplinary, security, crime prevention, and/or quality assurance processes. Surveillance cameras may collect your personal data for these reasons.
  • Maintaining and/or developing our IT or business systems and infrastructure, including testing and upgrading.
  • Creating reports with respect to your Transaction(s) and/or transactions we or a Healthcare Provider have with customers.
  • Facilitating, dealing with, and/or administering external or internal audits of Dickson's business, Transaction(s), and/or our customer transactions.
  • Dealing with and/or facilitating a business asset transaction or a potential business asset transaction where Dickson is a participant.
  • Record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements.
  • Dickson’s reporting purposes, including business performance.
  • Anonymisation of your personal data. You acknowledge that anonymized personal data is no longer subject to the PDPO.
  • To deal with or as part of a bankruptcy, winding up, reorganisation, restructuring, insolvency, receivership, or an assignment for the benefit of creditors, of Dickson.

Please note that new personal data about you may be created as a result of our processing of your existing personal data.

Who do you share my information with?

Dickson may/will need to disclose your personal data to third parties, whether located within or outside Hong Kong SAR, for one or more of the Purposes, as such third parties would be processing your personal data for these Purposes. You acknowledge, agree, and consent that we may/are permitted to disclose your personal data to such third parties for one or more of the Purposes, and for them to subsequently collect, use, disclose, and/or process your personal data for one or more of the Purposes.

Such third parties include:

  • Any of our agents, contractors, or third-party service providers that process your personal data on our behalf, such as mailing houses, telecommunication companies, information technology companies, and data centers. This also includes any party to whom Dickson outsources the performance of certain functions or activities.
  • Healthcare Providers.
  • Third parties with whom we enter into or may enter into any contractual or other arrangement relating to the products or services provided to you, or in relation to the Transaction.
  • Third parties to whom disclosure by Dickson is for one or more of the Purposes, and who would in turn be collecting and processing your personal data for one or more of the Purposes.

You consent to our using, disclosing, and/or processing personal data that we currently possess about you and/or that we had lawfully received or will lawfully receive in the future from third parties, for the Purposes.

How do we store Data?

The security of your personal data is important to us. We implement reasonable security arrangements to ensure your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage, and/or alteration of your personal data.

What are my Privacy Rights?

You may withdraw your consent for the collection, use, and/or disclosure of your personal data in our possession or under our control by emailing us at [insert email address]. We will process your request within 40 days, and thereafter will not collect, use, and/or disclose your personal data as requested, unless an exception or provision in the law permits us to do so.

However, your withdrawal of consent could result in certain legal consequences, including our inability to perform requested transactions or the termination of your relationship with us, depending on the extent of your withdrawal.

We take reasonable steps to ensure that any personal data we collect, disclose, and use is accurate and complete, particularly if it is likely to be used by us to make a decision that affects you, or disclosed to another organization. It is crucial that you inform us of any changes to your personal data or any errors in the data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data resulting from your failure to update us on changes to the personal data you initially provided.