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Personal Information Collection Statement

1. General

1.1 This Statement is made by ACESOBEE Limited in accordance with the provisions of the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region (“the Ordinance”) to set out matters relating to the collection, holding, processing and use of your personal data while you use our website at https://www.acesobee.com/.

1.2 In this statement, “the Company”, “we” or “us” refers to ACESOBEE Limited (艾草蜂有限公司). The terms referred to in this Statement shall have the same meanings as defined in the Terms of Use.

1.3 It is necessary for you to provide us with the personal data on this registration form, and in other circumstances when indicated as necessary, to use the services and products of the Company. In the event that you do not provide us with such personal data, we may not be able to provide you with our products or services.

2. Collection of Personal Data

2.1 We may obtain your personal data, directly or indirectly, including:
(A) information obtained about your computer, mobile device or other item(s) of hardware through which you access and use our website and the services and products provided on the website, including your IP address, geographical location, device identification codes and other features/data that can be used to identify a device, browser/platform type and version, internet service provider, operating system, referral source/exit pages, length of visit/usage, page views and any search term you use;
(B) information obtained by us or provided by you while you register as a user of our services or products, including your ID, date of birth, age, ethnicity, place of birth, educational level, telephone number, address, source of income, medical history, record of residence in residential care homes, hospitalization record, social welfare benefit, prescription and dispensing of medications, vital status and information, height, weight;
(C) information obtained by us or provided by you while you register as a professional practitioner, including user ID, user role, telephone number, professional title, department, email address;
(D) information obtained by us or provided by you while you register as a representative and/or an authorised person of an institution, including name, telephone number and email address, network IP; and
(E) information obtained by us through the use of cookies and other similar technologies which may include, but is not limited to, information about your mobile device, and your preferences and habits on language, for maintaining, managing and enhancing our products, services and user experience.
We will not collect more information from you than is necessary for us to provide you with our services or products, to perform the purposes set out in Section ‎3 of this Statement.

3. Purposes of Collection

3.1 Personal data provided by you will be used by the Company for one or more of the following purposes:
(A) enabling the Company to ensure smooth operation of its products and services;
(B) processing your registration and/or order for products and services provided by the Company, and maintaining and managing your registration or account;
(C) enhancing services or products delivered to you;
(D) designing new products or services to be offered to you;
(E) facilitating communications with you;
(F) handling your enquiries and/or complaints;
(G) tailoring your experience at the Company’s website;
(H) analyzing trends, usages and other behaviors, which helps us better understand how you and our collective user base access and use our services including for purposes of improving our services and responding to your queries and preferences;
(I) maintaining the security of our website, systems and products;
(J) subject to having obtained your consent in accordance with applicable law and as contemplated in Section ‎5 below, we may provide direct marketing information to you relating to the services and products offered by us;
(K) complying with any laws, regulations, court orders, or any requests by law enforcement agencies, government departments or regulatory authorities; and
(L) other purposes directly relating to any of the above.

4. Disclosure and Transfer of Personal Data

4.1 All personal data held by the Company in relation to you, whether provided by you and/or any other person, will be kept confidential. Only authorised directors, employees or agents of the Company will have access to and use the personal data. However, where such disclosure is necessary to satisfy the purposes listed in Section ‎3 above, the Company may provide such data to the following parties, subject to a duty of confidentiality:
(A) any professional practitioners (including doctors, nurses, physiotherapists, dietitians) and/or healthcare institutions that are involved in the planning and monitoring of your status in case you register as a user of our services or products;
(B) any registered users of our services or products in case you register as a professional practitioner or a representative and/or an authorised person of an institution;
(C) any business partners cooperating with the Company;
(D) any agent, contractor or third party service providers who provides administrative, telecommunication, or other services to the Company in connection with the operation or maintenance of our website or the provision of services and products on the website, such as for data storage and management, cloud servers; and
(E) any law enforcement agencies, government departments, regulatory authorities, or other persons to whom the Company is under an obligation to make disclosure under the laws or regulations applicable to the Company.
4.2 All personal data provided by you will not be transferred to places outside Hong Kong.

5. Use and Transfer of Personal Data for Direct Marketing Purposes

5.1 For the purpose specified in Section ‎3.1(J), we may use your name and contact details for direct marketing activities, including sending you relevant healthcare information.
5.2 We will solicit your consent by way of explicit indication of no objection and will use your personal data for direct marketing purposes after receipt of your consent.
5.3 We may provide your name and contact details to the Company’s business partners for use by them in marketing their own products and services, including sending you relevant healthcare information.
5.4 If at any time you do not wish for us to continue to use and/or provide your personal data to other persons for direct marketing purposes, you may at any time exercise your “opt-out” right by email to [email protected] or by post to:
Room 3, Cyberport Smart Space 8
25/F, CDW Building, 388 Castle Peak Road
Tsuen Wan, Hong Kong

6. Access to and Correction of Personal Data

6.1 In accordance with the Ordinance, you have the right to request access to, and correction of, your personal data. In general, you shall be entitled to:
(A) verify whether the Company holds, and if any, the types of personal data in relation to you;
(B) have access to your personal data within reasonable time;
(C) request the Company to correct any personal data in relation to you which is inaccurate;
(D) ascertain the Company’s policies and practices in relation to personal data; and
(E) in the event that your request for access to, or correction of, personal data is refused, request to be given reasons thereof and object to any such refusals.
6.2 Requests for access to, or correction of, personal data shall be made by email to [email protected] or by post to:
Room 3, Cyberport Smart Space 8
25/F, CDW Building, 388 Castle Peak Road
Tsuen Wan, Hong Kong

7. Privacy Policy Statement

7.1 You can find out more about the Company’s policies on privacy and personal data protection by accessing the Company’s Privacy Policy Statement available on the Company’s website at https://www.acesobee.com/privacy.

8. Changes to this Statement

8.1 We may update this Statement to reflect changes to our data practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account). Please review this page periodically for the latest information on our privacy practices. After we have issued a notice to you, if you continue to use our services and products on the website, you will be deemed to have agreed to and been notified of any updated version of this Statement.


Updated on 8th March 2022