Privacy Policy
1. Controller and contact
China Medical Trip Limited (registered address: 15/F, Room 1523A, Star House, 3 Salisbury Road, Tsim Sha Tsui, Hong Kong) is responsible for relevant processing on this website. Privacy contact: care@cmedtrip.com. Postal address: 15/F, Room 1523A, Star House, 3 Salisbury Road, Tsim Sha Tsui, Hong Kong.
2. Scope
This policy covers the public website, contact forms, consultation-call requests, embedded forms, calendars and chats, and non-clinical communication by email, phone or WhatsApp. Later medical-record, hospital, payment, e-signature or customer-centre processes will have separate notices.
3. Information we may collect
We may collect identity and contact details, country and communication preferences, request category, general messages, booking and interaction records, source and consent records, technical and security information, analytics information after consent, and cookie-choice records. Do not submit medical records, diagnoses, images, identity documents, bank details or other sensitive information through public channels.
| Category | Examples | Current purpose |
|---|---|---|
| Identity and contact | Name, email, phone or WhatsApp number | Respond to requests and arrange communication |
| Region and preferences | Country, language, contact time and channel | Assign suitable communication |
| Request category | General support, partnership or media request | Understand request type |
| General free text | General message that may accidentally contain sensitive content | Understand the request and handle misdirected content |
| Booking and interaction | Call time, submission status and non-clinical records | Arrange and follow up coordination calls |
| Source and consent | Reviewed source code, allowed UTM fields, consent version and time | Attribution and compliance evidence |
| Technical and security | IP, device/browser, time, request ID and security logs | Operation, security and abuse prevention |
| Analytics after consent | Page category, session and de-identified events | Understand and improve the website |
| Cookie choices | Category, time, language, region assessment and policy version | Implement and evidence choices |
4. Information the public website should not collect
Public forms, ordinary chat, WhatsApp and general email are not approved medical-information channels. If sensitive information is sent by mistake, we may restrict access, isolate or delete it, redirect the person to an approved secure channel and record the necessary handling status.
5. Sources
Information may come from forms and contact choices, non-clinical conversations, browser and security logs, analytics used after consent, reviewed source or advertising parameters, and an authorized family member, guardian or representative.
6. Purposes and legal bases
We use information to respond to requests, arrange calls, identify language, time zone and contact preferences, maintain non-clinical CRM leads, protect the website, record consent, send opted-in service information, measure the website after consent, comply with law and handle complaints. Bases may include consent, pre-contract steps, legal obligations and legitimate interests as permitted by applicable law.
7. Sharing
Necessary information may be shared with Shopify, Hydrogen, Oxygen and infrastructure providers; HubSpot forms, CRM, Meetings and approved chat; email, phone and WhatsApp providers; direct GA4 and Shopify Hydrogen analytics after consent gates; Search Console; authorized professional service providers; and public authorities where legally required. To ask for the current recipient or sub-processor list, contact care@cmedtrip.com.
| Recipient category | Current or planned products | Main purpose |
|---|---|---|
| Website and hosting | Shopify, Hydrogen, Oxygen and infrastructure | Pages, CMS, transmission and security logs |
| CRM, forms and booking | HubSpot Forms, CRM, Meetings and approved Chat | Leads, forms, bookings and non-clinical follow-up |
| Communication | Business email, phone and WhatsApp/Meta | Respond through the selected channel |
| Analytics and tags | Direct GA4 and Shopify Hydrogen analytics behind consent gates | De-identified website analysis |
| Search performance | Google Search Console | Verification, indexing and aggregate performance |
| Professional services | Authorized development, operations, legal, privacy and security providers | Support, audit and professional advice |
| Public authorities | Regulators, law enforcement, courts or other authorized bodies | Legal compliance and protection of rights |
8. Cross-border transfers
CMT Health and service providers may process information in Hong Kong and other countries or regions. Protection may differ from your location. Sensitive information is transferred only with required consent and a lawful cross-border mechanism. Where required, we will provide recipient, purpose, data-category and safeguard information.
9. Retention
We retain information for the shortest period needed for the purpose, legal duties, complaints, audits and security. The current retention periods are listed in the approved retention table for this policy and may be updated after legal and operational confirmation.
| Data category | Retention period | Deletion or anonymization trigger |
|---|---|---|
| Unconverted leads | Last interaction plus 6 months | Period ends, lawful deletion request or purpose ends |
| Contact preferences | General preferences with the lead for 6 months; opt-out records minimized and retained in principle for at least 3 years after the last marketing activity | Purpose and legal obligation end |
| Booking and non-clinical communications | Service completion or 2 years after the last interaction; legal hold for complaints or disputes | Service completion and no retention duty |
| Privacy and marketing consent | While valid and for 3 years after withdrawal, opt-out or the last related processing | Evidence duty ends |
| Website security logs | 6 months; incident-related logs until 3 years after closure | Security investigation window ends |
| GA4 and other analytics | Suggested 2 months; extend to 14 months only when annual analysis is necessary and assessed | Tool period ends or withdrawal, where technically possible |
| WhatsApp records | Device records deleted after 90 days; necessary CRM records retained for 2 years | Follow-up purpose ends, legal period ends or valid deletion request |
| Employee device records | Deleted within 30 days after synchronization | Synchronization completed |
| Misdirected sensitive originals/attachments | Deleted within 7 days after identification, notice and secure diversion | Necessary handling evidence retained without medical text |
| Misdirected sensitive-information handling record | De-identified handling evidence for 3 years | Legal and security evidence duty ends |
10. Cookies and similar technologies
Necessary cookies support sessions, security and website operation. Analytics cookies and third-party embeds are loaded only after the required consent. See the Cookie Policy for names, providers, purposes, retention and choices.
11. Security
We disclose security measures only after implementation and verification. Measures may include access controls, individual accounts, multi-factor authentication, transport protection, least privilege, log minimization, vendor management, backups and incident response. No internet or third-party system is absolutely secure.
12. Your rights and third parties
Depending on applicable law, you may request access, correction, copying, transfer or deletion; withdraw consent; object to or restrict processing; manage marketing and cookies; learn about cross-border recipients; and complain to the competent data-protection authority. Submit requests to care@cmedtrip.com. External hospital, government, HubSpot, WhatsApp and Google services operate under their own policies.
13. Minors, updates and contact
The website is not actively directed at children under 18. Do not submit a minor patient’s name, condition or records through public forms. We may update this policy when services, suppliers, technology or law changes. To request a prior version or raise a privacy concern, contact care@cmedtrip.com. The effective date and formal version remain pending confirmation.
