PRIVACY STATEMENT
Wellness
Reimagined 2
(hereafter
referred to as “this Site/Application”)
This Statement was last updated on Jun 11th
1.
Introduction
PricewaterhouseCoopers
Digital Services (Shanghai) Co., Ltd OR PwC(hereafter
referred to as “we”) are strongly committed to protecting your personal
information. This Statement relates only to Wellness Reimagined (2) . It does not
relate to other technologies, products, services or sites of PwC Network Member
Firms or any other party.
This Statement describes why and how we
collect and process your personal information through this Site/Application and
provide information about your rights in relation to your personal information.
This Statement also applies to personal information (including other
individuals’) you provide to us through this Stie/Application.
We only collect what we need and be
transparent about why and how we process personal information. We may use the personal information provided
in connection with this Site/Application for any of the purposes described in
this Statement or as otherwise stated at the point of collection.
You are visiting this Site/Application as
you are one of the following:
·
Individuals having Employment, and/or had a
Contractual Relationship with
PwC
2.
Site/Application Operator
The PwC firm operating this
Site/Application is the entity with primary responsibility for the protection
of personal information and for ensuring compliance with applicable data
protection laws.
Name of Site Operator and contact person
are as follows:
PricewaterhouseCoopers Digital Services
(Shanghai) Co., Ltd
Company Address: Room 310, floor 3,
building 4, No. 222, Meiyue Road, China (Shanghai) pilot Free Trade Zone
Contact: +86 021-23238888
If you are not receiving Services from
the Site Operator, the PwC firm responsible for delivering services to you or
your organisation is the PwC firm providing you access to this Site/Application
3.
Definition
In this Statement, we use the following terms:
“This Site/Application” refers to Wellness Reimagined 2. Wellness
Reimagined 2 is an update version of existing Wellness Reimagined, aiming to
build a virtual community platform focusing on social & employee engagement
and provide an integrated consumer grade experience platform offering
enterprise grade solutions.
This Site/Application is hosted in Huawei Cloud in China (Shanghai).
“Personal
information” or “personal data” refers to various
information related to an identified or identifiable natural person recorded
electronically or by other means but does not include anonymized
information. “Anonymization" refers to irreversible technical process that
makes personal information subjects unidentifiable or unassociated.
"Personal information subjects” refers
to natural person identified by or associated with personal information.
"Personal information processor" refers to an organization or individual that autonomously
determines the purposes and means of personal information processing. This is
equivalent to the definition of “Data User” under Personal Data (Privacy)
Ordinance (Cap, 486) applicable to HKSAR and “Data Controller” under EU General
Data Protection Regulation (“GDPR”).
“Processing of personal
information”
means processing of personal information includes, without limitation, the
collection, storage, use, processing, transmission, provision, disclosure, and
deletion of personal information. Processing under GDPR means any operation or
set of operations which is performed on personal data or on sets of personal
data, whether by automated means, such as collection, recording, organisation, transferring,
structuring, storage, adaptation or alteration, retrieval, consultation, use,
disclosure by transmission, dissemination or otherwise making available,
alignment or combination, restriction, erasure, or destruction.
“PwC”
refer to the list of PwC Member Firms operating in Mainland
China, Hong Kong SAR, and Macau SAR responsible for delivering services to you
or your organisation and providing you access to this Site/Application.
For a list
of other PwC Network Member Firms, please see details at [https://www.pwc.com/gx/en/about/corporate-governance/legal-entities.html].
Each member firm in the PwC
network is a separate legal entity.
“Sensitive personal information” is personal information that once leaked or illegally used,
may easily lead to the infringement of the personal dignity of a natural person
or may endanger his personal safety or property,
including information such as biometrics, religious belief, specific
identity, medical health status, financial accounts, and the person’s whereabouts, as well as the personal
information of a minor under the age of 14 years.
4.
Collection of personal information
We may process your personal information for use of this
Site/Application. We may collect your
personal information either directly from you or the organization contracted
with PwC (e.g., your employer or authorized organization) authorizing you the
use of this Site/Application.
4.1
Categories of personal information collected
The personal information we collect includes:
(a)
Necessary
personal information
For you to use this Site/Application, you will need to
provide us or allow us to collect the following information:
|
Basic Business Function and Purpose of Processing |
Means of Processing |
Necessary Personal
Information |
|
Create
User Account |
Input by
User |
o
Email address o
Password |
|
Synchronized from PwC vProfile |
o
Worker ID o
Staff ID o
Location Code o
Staff Name o
City o
Gender o
Birthday o
Age o
Business Unit o
Job Title o
Email o
Expat o
Management Level o
Job Level o
Entity o
First Name o
Last Name o
English Name o
Chinese Name o
Division |
(b)
Additional
personal information
In order for you to use or for us to deliver the extended
business function(s), the following additional personal information will need
to be collected:
|
Extended Business Function(s) and Purpose of
Processing |
Means of Processing |
Additional Personal
Information |
|
Life
Store – HK – Marketplace – Buying Coupon and Delivery |
Reserved
by the system |
o
Email o
First Name o
Last Name o
Mobile |
|
Life
Store – HK – Marketplace – Buying Product and Delivery |
Reserved
by the system and input by user |
o
Email o
First Name o
Last Name o
Mobile o
Delivery
Address o
Recipient
Name o
Recipient
Mobile |
|
Life
Store – HK – Flexi Life Benefit – Buying Service |
Reserved
by the system |
o
Gender o
Email o
First Name o
Last Name o
Mobile |
|
Life
Store – HK – Request Personal Receipt |
Reserved
by the system |
o
Email o
First Name o
Last Name o
Mobile o
Delivery Address |
|
Life
Store – CN – Marketplace – Buying Coupon and Delivery |
N/A |
N/A |
|
Life
Store – CN – Marketplace – Buying Product and Delivery |
Reserved
by the system and input by user |
o
o
Email o
First Name o
Last Name Delivery
Address |
|
Life
Store – CN – Flexi Life Benefit – Buying Service |
Reserved
by the system |
o
Email o
First Name o
Last Name o
ID
Type o
ID Number |
|
Life
Store – CN – Flexi Life Benefit – Service Reservation |
Reserved
by the system and input by user |
o
Gender o
Date of Birth o
First Name o
Last Name o
Mobile o
ID Type o
ID Number o
Marital Status o
E-Signature (optional for online health
report) |
|
Life
Store – CN – Request Individual Fapiao |
Reserved
by the system and input by user |
o
Email o
Delivery Address |
Failure to provide us with such additional personal
information will not negatively affect your use of the basic business function
of this Site/Application.
By using this
Site/Application and providing the above personal information to us, you confirm
that you have read this Privacy Statement, and explicitly consent to the
processing of personal information by us and any third-party recipients as
set out in the Privacy Statement. We may rely on other legal grounds
of processing to the extent permitted under applicable law.
(c)
Sensitive
personal information
|
Purpose(s) |
Means of
Processing |
Sensitive personal
information |
|
Health Check Service
Reservation |
Collect from system
reserved and user input and will transit to third party for health server
booking. |
o
ID type (if applicable) o
ID number (National/Passport) o
Marital Status (If applicable) o
Date of birth (if applicable) o Signature
(if applicable) |
We do not collect sensitive personal information through
this Site/Application unless such information is required to meet the specific
purposes as stated above. Please do not provide any sensitive personal information unless you agree
such information is necessary for specific purpose(s).
For Mainland China: For collection of sensitive persona
information from individuals in Mainland China, we need to collect your
separate consent to the extent your consent is necessary.
(d)
Personal
information of other individuals
|
Purpose(s) |
Means
of Processing |
Personal information
of other individuals |
|
Life Store – HK
– Flexi Life Benefit – Buying Service and Reservation for other individuals |
Collect from system reserved and user input and will
transit to third party for health server booking. |
o
Name o
Contact Number o
Gender o
Email |
|
Life Store – CN
– Flexi Life Benefit – Buying Service and Reservation for other individuals |
Collect from system reserved and user input and will
transit to third party for health server booking. |
o
Name o
ID Type o
ID Number o
Contact Number o
Gender o
Marital Status o
Date of Birth o
Email |
If you are providing personal information
of other individuals, please make sure that:
(i)
the personal information
is from a legitimate and lawful source.
(ii)
the other individuals are aware of the categories of personal information and purpose(s) for collecting his/her personal
information and all other relevant
arrangement described in this Statement relating to the processing of personal
information, and that he/she has consented to disclosure
of personal information for processing by us.
We may contact you to inquire and confirm with you in relation to
(i) and (ii) above. If you receive such an enquiry from us, please kindly
assist and provide us with prompt response. We may have to discontinue your use
of this Site/Application if we are unable to obtain the verification needed.
By providing sensitive
personal information, you confirm that you provide your explicitly consent to
the processing of sensitive personal information by us and any third-party
recipients as set out in the Privacy Statement.
5.
Use of personal information
We use your provided personal information to provide you with our
products or services, to communicate with you, to maintain the security of this
Site/Application, and to comply with applicable law. We use your provided personal
information only when we have a legal basis to do so, including your prior
consent where necessary.
We may also use the personal information collected above for the
following purposes:
|
Use
of Personal Information directly or reasonably related to the following
purposes |
|
· To provide the services requested by you or your
organisation · To provide you or your organisation with use of this
Site/Application · To communicate with you · To maintain the security of this Site/Application o
Authenticating
the identity of users, authorising access to this Site/Application (including preventing
unauthorised access) and for other
security-related purposes, including system security monitoring. · To operate, administer, manage and improve this
Site/Application o
Administering
this Site/Application, troubleshooting issues and identifying areas of
improvement. · To maintain our administrative or client relationship
management systems o
Where
you are a business contact of ours, we may include your business contact
details on our administrative or client relationship management systems
(which may be located in secure data centres around the world), contact you
in relation to the products or services and we may send you other material
relevant to your interests (provided we have appropriate permission from you
to do this, as required by laws). · To analyse how this Site/Application and associated services perform,
we may analyse how this Site/Application and associated services perform by
reviewing the user data we capture. · To enhance our user experience · To comply with applicable law and regulation. |
6.
Third-party links
This
Site/Application may link to third-party sites via links which are not controlled
by us and which do not operate under our privacy practices. When you access to
third-party sites, our privacy practices no longer apply, and the third-party
site provider is responsible for the personal information collected from
you. We encourage you to review each
third-party site's privacy policy before disclosing any personal information.
6.1 Mixup Solution Company Limited
Mixup
Solution Company Limited (hereafter referred to as “MixCare”) is a comprehensive
health service provider in Hong Kong. MixCare provides services like health
check, goods purchase, and order delivery for users from Wellness Reimagined (2) in
Hong Kong.
Contact: +852 9856 7349 or cs@mixreward.com
The personal information transmitted to MixCare includes:
|
Personal information |
Purpose of collection |
|
This
Site/Application to third party o
Legal Name o
Mobile Number o
Email Address o
Gender (if applicable)Postal or delivery Address |
o
Create & deliver goods o
Health Check Service Reservation |
6.2 Foreign Enterprises Service Corporation
Foreign
Enterprises Service Corporation (hereafter referred to as “FESCO”) is a comprehensive
human resource service and product chain provider in China mainland. FESCO provides
services like health check, goods purchase, and order delivery for users from
Wellness Reimagined (2) in China mainland.
Contact: 400-8000-800 or benefit@fesco.com.cn
The personal information transmitted to FESCO includes:
|
Personal information |
Purpose of collection |
|
This
Site/Application to third party o
Legal Name o
Mobile Number o Email
Address o
ID type o
ID number (National/Passport) o
Marital status o Date of
birth o
Postal or delivery Address |
o
Create & deliver goods o
Health Check Service Reservation |
|
Third
party to this Site/Application o
Medical e-report |
o
View Medical e-report online |
7.
Our legal grounds for processing personal
information
Applicable
laws may require us to set out in this Statement the legal grounds on which we
rely in order to process your personal information. In such cases, we rely on
one or more of the following processing conditions:
(i)
With
your prior consent;
(ii)
It is
necessary for us to conclude or preform a contract with you;
(iii)
It is
necessary for us to perform the statutory duties or statutory obligations;
(iv)
It is
necessary for us to respond to a public health emergency or to protect the
life, health and property safety of any individual;
(v)
Such
acts as news reporting and supervision by public opinions are carried out for
the public interest, and the processing of personal information is within a
reasonable scope;
(vi)
it is
necessary to process the personal information disclosed by you or other
personal information that has been legally disclosed within a reasonable scope
in accordance with the laws; and
(vii)
Other
circumstances prescribed by laws and administrative regulations.
The
processing of personal information should be subject to your consent in
accordance with relevant laws, however, your consent is not required under the
circumstances set forth in Items (ii) to (vii) of the preceding paragraph.
8.
Sharing of personal information
Your personal information
may be transferred to, shared with, processed by and stored with other
organizations or individuals. In regard of the sharing
of your personal information, we will seek your separate consent to the extent
required by law.
(a)
Recipients of personal information: other PwC
Network Member Firms
We may share your personal information with other PwC
Network Member Firms where necessary in connection with the purposes described
in this Statement. For example, when providing products or services to a client
we may share personal information with PwC Network Member Firms in different
territories that are involved in providing products or services to that client.
(b) Recipients of personal
information: third-party providers
We may share or disclose the personal information we collect
to third-party contractors, subcontractors, and/or their subsidiaries and
affiliates. Third parties support the PwC Network in providing its products or services
and help provide, run and manage IT systems. Examples of third-party
contractors we use include providers of identity management, website
hosting and management, data analysis, data backup, security and cloud storage
services. The servers powering and facilitating our IT infrastructure may be
located in secure data centres around the world, and personal information may
be stored in any one of them.
It is our policy to use only third-party providers that are
bound to maintain appropriate levels of security and confidentiality and
process personal information only as instructed by PwC pursuant to the contract between PwC and such
third-party providers. Subject to the foregoing, third
party providers may also use their respective subsidiaries and affiliates, and
their own third-party subcontractors that have access to personal information (sub-processors)
to meet purposes of disclosure and/or transfer.
(c) Other recipients of personal information
We may also share your personal information under the
following circumstances to the extent permitted under applicable laws:
·
with
professional advisers, for example, auditors and law firms, as necessary to
establish, exercise or defend our legal rights and obtain advice in connection
with the running of our businesses. Personal information may be shared with
these advisers as necessary in connection with the products or services they
have been engaged to provide;
·
when
explicitly requested by you;
·
when
required to deliver publications or reference materials requested by you;
·
when PwC is involved in a merger,
acquisition, or sale of all or a portion of its assets (provided the recipient
agrees to be bound by the terms of this Statement);
·
with
law enforcement or other government and regulatory agencies or with other third
parties as required by, and in accordance with, applicable law and regulation;
and/or
·
occasionally,
we may receive requests from third parties with authority to obtain disclosure
of personal information, such as to check that we are complying with applicable
laws and regulations, to investigate an alleged crime or to establish, exercise
or defend legal rights. We will only fulfil requests for personal information
where we are permitted to do so in accordance with applicable laws and
regulations. This includes disclosures
outside the country or region where you are located.
9.
International transfers of personal
information
As PwC is a global network
with member firms and third-party service providers located around the world. Your personal
information may be transmitted and/or stored outside the country or region
where you are located when we (as a PwC Network Member Firm) provide products
or services to you. PwC Network Member Firms,
our service providers and sub-processors they engage may use servers and other
resources in various countries and territories to process your
information.
Since we provide products
or services through resources and servers all over the world, this means that
after obtaining your separate authorized consent, your personal information may
be transferred outside of the country where you use the Site/Application to the
extent permitted by laws.
For personal information collected from Mainland China:
In
principle, the personal information we collect and generate in Mainland China will be stored
within the Mainland China. With your consent, your
personal information might be transmitted to
or accessed from a jurisdiction outside of the country/region where you
are located. Under such circumstances,
we will ensure that your personal information will enjoy the same level of protection as it does in Mainland China.
We will satisfy the applicable
condition(s) for cross border transfer (if any) required by applicable law.
We will enter into contract or other
legally effective documents with the recipients of personal information or
implement other measures as required by laws of the People’s Republic of China
to
ensure that your personal information is adequately protected. For example, we will ask for your separate
consent to transfer personal information across borders, implement appropriate
security measures before cross-border data transfer, conduct personal
information protection impact assessment and obtain the approval of competent
authorities, where applicable.
10. Security
of personal information
We
adhere to internationally recognised standards of technology and operational
security to protect personal information from loss, misuse, alteration and
destruction. Only authorised persons are provided access to personal
information collected via this Site/Application. These individuals have agreed
to maintain the confidentiality of such information. We have a framework of policies
and procedures in place covering data protection, confidentiality and security
and regularly review the appropriateness of the measures we have in place to
keep the personal information we hold secure.
Although
we use appropriate security measures once we have received your personal information,
the transmission of personal information over the Internet (including by email)
is never completely secure. We endeavor to protect personal information, but we
cannot guarantee the security of information transmitted electronically over
the Internet.
Where a personal
information security incident arises, we shall respond to the incident, assess
the likely impact of the incident, and take necessary actions to bring the
incident under control. Where necessary, we will report to the appropriate
authority and notify you of the incident as may be required under applicable
laws and regulations.
11. Retention
of personal information
It is our policy not to
retain personal information longer than is necessary for the fulfilment of the
purposes for which the information is to be used. We will retain personal
information on our systems for as long as we need it, given the purposes for which
it was collected, or as required to do so by applicable laws. Personal information may be held for longer
periods where extended retention is agreed or are required by laws, regulations
or professional standards and to establish, exercise or defend our legal
rights. If the period necessary for the fulfilment of the purposes for which
the information is to be used, agreed retention period, or legal retention
period expires, we will erase the relevant personal information according to
law; if it is difficult to erase personal information technically, we will
cease the processing of personal information other than storing and taking
necessary security protection measures for such information.
12. Children
We are committed to
protecting children’s privacy. This Site/Application is not intentionally
designed for or directed at children (i.e., minor under age of 14; “children”
refers to the same group hereinafter), and we do not knowingly collect or store
personal information about children. In the case of collecting personal
information of a children in Mainland China, we will only use or publicly
disclose such information if we have obtained explicit consent of the their
parent or guardian. We will protect the
confidentiality and security of their personal information in accordance with
relevant applicable laws and regulations.
13. Your
rights in relation to your personal information
You may have certain
rights under applicable laws and regulations in relation to the personal information
we hold about you, including:
· Right to know and the right to decide
on the processing of their personal information
· Right to restrict or refuse the
processing of their personal information by others (except as otherwise
provided by any law or administrative regulation)
· Right to access your personal
information
You have the right to
consult and duplicate their personal information from us and request us to
provide to you:
(i)
a description of the type of personal information we
hold about you, including a general account of its use;
(ii)
the source of the above-mentioned personal
information, as well as the purpose for which it is used;
(iii)
what personal information has been made available to
third parties, and the identity or type of any third party who has obtained the
above mentioned personal information; and
(iv)
you may also request a copy of certain categories of
personal information
·
Right to data portability
Where you request the transfer
of your personal information which we have obtained to your designated personal
information processor, we or third parties instructed by us would provide
channels for such transfer if the conditions specified by the national cyberspace
administration are met.
·
Right not to subject automated decision making
Where a decision that has
a major impact on your rights and interests is made by means of automated
decision-making (if any), you have the right to request us to make explanations
and to refuse to accept that we make decisions solely by means of automated
decision-making.
·
Right to request personal information processors to
explain their personal information processing rules
·
Right to request deletion of your personal information
Your right to request us to
erase your personal information if:
(i)
the processing purpose has been achieved or cannot be
achieved, or it is no longer necessary to achieve the processing purpose;
(ii)
the retention period described in Section 12 of this
Statement has expired;
(iii)
you withdraw consent; or
(iv)
we collect or process personal information in
violation of any law or administrative regulation or the agreement.
In such circumstances, if we
receive your request to delete your personal information, we will also notify
third parties whom we have transferred your personal information to delete
personal information they hold about you.
However, where the retention period provided by any law or administrative
regulation has not expired, or it is difficult to realize the deletion of
personal information technically, we would just cease the processing of
personal information other than storing and taking necessary security
protection measures for such information.
·
Right to update/correct your personal information
which is inaccurate or incomplete
Under certain circumstances permitted by applicable laws and
regulations, we may refuse to accede to
your requests above. In such circumstances, we will promptly notify you of the
reasons for refusing to accede to your requests. We may charge a fee for your
request to access your information, if permitted by applicable laws and
regulations.
For security purposes, you may be required to provide written
requests or prove your identification in other ways.
When requested, and
provided that it is practical and commercially feasible to comply with the
request, we will respond to your request after we have verified your identity:
·
within 15
working days for
personal information collected from Mainland China; or
·
such a time frame
as prescribed under
other applicable laws.
14. Deactivation
of your account
Users
of this Site/Application may request their account be deactivated at any time
by request the application in App, or sending their request to Helpdesk@Asia. We
will respond to your request within the time required under applicable laws.
If you wish to submit a
request to exercise your rights, under applicable privacy law, or have
questions about how your information is handled at any time, or to make
complaints, please send your request to our Privacy Team https://www.pwccn.com/en/privacy-team-contact-form.html or
https://www.pwchk.com/en/privacy-team-contact-form.html.
Should you have any concerns with any matter in
respect of this Statement, you may also approach members of the PwC team who is
providing you or your organization with access to this Site/Application to
discuss.
Any unresolved dispute arising from or in
connection with this Statement shall be resolved in accordance with the
agreement (if applicable) between you/your organization and the PwC firm responsible
for providing you with access to this Site/Application.
16. Transfer
of business
We
reserve the right to transfer all data in its possession to a
successor-in-interest to its business or assets in accordance with applicable
law and regulation.
17. Changes
to this Statement
We
may update this Statement from time to time to comply with applicable laws and
regulations or other legitimate purposes. We may also separately advise you about the changes. Subject to
obtaining your explicit consent as may be required by applicable laws, the new modified Privacy Statement will apply from that
revision date. Therefore, we encourage you to review this Statement periodically
to be informed about how we are protecting your information.