Cookie Policy

Information About Our Use of Cookies

Easy Care Group Limited ("the Company") uses cookies on its website to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.

Types of Cookies We Use

In accordance with the Hong Kong Personal Data (Privacy) Ordinance, we use the following cookies:

Strictly Necessary Cookies

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/Performance Cookies

These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality Cookies

These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

Targeting Cookies

These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Third-Party Cookies

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Your Cookie Choices

In accordance with the provisions of the Personal Data (Privacy) Ordinance:

• We will not collect any personally identifiable information (i.e. information that is about you and identifies you) from you unless otherwise stated

• You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies

• However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site

• We recommend that you may choose to disable or reject certain non-essential cookies

Cookie Information Transparency

When we use cookies to collect personal data, we will inform you:

• The kind of information stored in cookies

• The purpose of collecting information

• How information is collected

• Whether the website is accessible without accepting cookies

• Whether not accepting cookies results in loss of functionality

Data Protection Policy

1. Policy Statement

1.1 Policy Overview

Everyone has rights with regard to the way in which their personal data is handled. During the course of our activities we will collect, store and process personal data about our service providers, users and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.

1.2 Compliance Obligations

Data users are obliged to comply with this policy when processing personal data on our behalf. Any breach of this policy may result in disciplinary action.

2. About This Policy

2.1 Scope

The types of personal data that Easy Care Group Limited ("the Company") (We) may be required to handle include information about current, past and prospective service providers, users and others that we communicate with. Refusal to provide such information may deny you access to certain parts of the application or may render us unable to process any application and requests.

In accordance with the Personal Data (Privacy) Ordinance (Cap 486) ("Ordinance"), the personal data, which may be held on paper or on a computer or other media, is subject to certain legal safeguards.

2.2 Policy Basis

This policy and any other documents referred to in it sets out the basis on which we will process any personal data we collect from data subjects, or that is provided to us by data subjects or other sources.

2.3 Data Protection Rules

It sets out rules on data protection and the legal conditions that will be satisfied when we obtain, handle, process, transfer and store personal data.

2.4 Data Protection Compliance Manager

The Data Protection Compliance Manager is responsible for ensuring compliance with the Ordinance and with this policy. Any questions about the operation of this policy or any concerns that the policy has not been followed should be referred in the first instance to the Data Protection Compliance Manager.

3. Definition of Data Protection Terms

3.1 Data

Data is information which is stored electronically, on a computer, or in certain paper-based filing systems.

3.2 Data Subjects

For the purpose of this policy, data subjects include all living individuals about whom we hold personal data. All data subjects have legal rights in relation to their personal information.

3.3 Personal Data

Personal data means data relating to a living individual who can be identified from that data (or from that data and other information in our possession). Personal data can be factual, including a name, gender, date of birth, nationality, telephone number, postal address, email address, credit card information, bank account number, educational level, occupation, household income, personal income, details of online transactions, marital status and interests.

For Easy Care Group Limited's rehabilitation services, personal data may also include:

• Identification data (name, Hong Kong Identity Card number)

• Personal information (gender, date of birth, age)

• Contact information (telephone, address, email, fax)

• Educational background and employment history

• Financial and economic status

• Health and physical condition details

• Family circumstances, marital status and family member information

• Assessments and opinions regarding data subjects

• Service records and therapy data

3.4 Data Controllers

Data controllers are the people who or organisations which determine the purposes for which, and the manner in which, any personal data is processed. They are responsible for establishing practices and policies in line with the Ordinance. We are the data controller of all personal data used in our business for our own commercial purposes.

3.5 Data Users

Data users are those of our employees or contractors whose work involves processing personal data. Data users must protect the data they handle in accordance with this data protection policy and any applicable data security procedures at all times.

3.6 Data Processors

Data processors include any person or organisation that is not a data user that processes personal data on our behalf and on our instructions. It could include suppliers which handle personal data on the Company's behalf.

3.7 Processing

Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

4. Data Protection Principles

In accordance with the Hong Kong Personal Data (Privacy) Ordinance, anyone processing personal data must comply with the principles of good practice. These provide that personal data will be:

1. Processed fairly and lawfully

2. Processed in an appropriate way

3. Adequate, relevant and not excessive for the purpose

4. Accurate

5. Processed in line with data subjects' rights

6. Secure

5. Fair and Lawful Processing

5.1 Processing Principles

The Ordinance is not intended to prevent the processing of personal data, but to ensure that it is done fairly and without adversely affecting the rights of the data subject.

5.2 Legal Basis for Processing

For personal data to be processed lawfully, they must be processed on the basis of one of the legal grounds set out in the Ordinance. These include, among other things, the data subject's consent to the processing, or that the processing is necessary for the performance of a contract with the data subject, for the compliance with a legal obligation to which the data controller is subject, or for the legitimate interest of the data controller or the party to whom the data is disclosed.

When processing personal data as data controllers in the course of our business, we will ensure that those requirements are met.

6. Processing for Limited Purposes

6.1 Data Collection

In the course of our business, we may collect and process personal data, including data we receive directly from a data subject (for example, by completing forms or by corresponding with us by mail, phone, email or otherwise) and data we receive from other sources (including, for example, business partners, sub-contractors in technical, payment and delivery services, credit reference agencies and others).

6.2 Specific Purposes Only

We will only process personal data for the specific purposes specifically permitted by the Ordinance. We will notify those purposes to the data subject when we first collect the data or as soon as possible thereafter.

6.3 Data Use Purposes for Rehabilitation Services

For Easy Care Group Limited's home-based rehabilitation services, personal data may be used for the following purposes:

• Processing service applications from users

• Providing physiotherapy, occupational therapy, speech therapy and nursing care services

• Assessment and development of individualised rehabilitation plans

• Service quality monitoring and improvement

• Processing payments and billing

• Communication with medical professionals (with consent)

• Facilitating service-related research and development

• Assisting government departments with related matters

• Handling complaints and legal matters

• Compliance with legal and regulatory requirements

7. Notifying Data Subjects

7.1 Notification When Collecting Data Directly

If we collect personal data directly from data subjects, we will inform them:

• The purpose or purposes for which we intend to process that personal data

• The types of third parties, if any, with which we will share or to which we will disclose that personal data

• The means, if any, with which data subjects can limit our use and disclosure of their personal data

• Whether provision of data is mandatory or voluntary in nature

• The consequences of failure to provide the data

• Data subjects' rights to access and correct their personal data

7.2 Notification When Receiving Data from Other Sources

If we receive personal data about a data subject from other sources, we will provide the data subject with this information as soon as possible thereafter.

7.3 Identification as Data Controller

We will also inform data subjects whose personal data we process that we are the data controller with regard to that data.

8. Adequate, Relevant and Non-Excessive Processing

We will only collect personal data to the extent that it is required for the specific purpose notified to the data subject. For rehabilitation services, we ensure that data collected is adequate to provide safe and effective treatment, but we do not collect excessive unnecessary information.

9. Accurate Data

We will ensure that personal data we hold is accurate and kept up to date. We will check the accuracy of any personal data at the point of collection and at regular intervals afterwards. We will take all reasonable steps to destroy or amend inaccurate or out-of-date data.

For medical and rehabilitation service records, we place particular emphasis on data accuracy as this directly affects service quality and patient safety.

10. Timely Processing

We will not keep personal data longer than is necessary for the purpose or purposes for which they were collected. We will take reasonable steps to destroy, or erase from our systems, all data which is no longer required.

10.1 Medical Records Retention Period

Whilst the Ordinance does not specify a specific retention period for medical data, healthcare service providers should establish a data retention policy that complies with legal requirements, industry standards and best practices. The retention period depends upon:

• The need to handle complaints or potential litigation

• Compliance with legal requirements (for example, tax records)

• The need to provide continuity of care

• Research and educational purposes

11. Processing in Line with Data Subject's Rights

We will process all personal data in line with data subjects' rights, in particular their right to:

• Request access to any data held about them by a data controller (see also clause 15)

• Prevent the processing of their data for direct-marketing purposes

• Ask to have inaccurate data amended (see also clause 9)

• Prevent processing that is likely to cause damage or distress to themselves or anyone else

11.1 Special Requirements for Direct Marketing

In accordance with Part 6A of the Ordinance, before we use a data subject's personal data for direct marketing purposes or transfer their data to third parties for direct marketing purposes, we must obtain informed consent. Consent must be an express indication of the data subject's wishes, including an indication of not objecting. Silence cannot constitute consent.

We must inform data subjects:

• Our intention to use their personal data for direct marketing

• The types of personal data that will be used

• The categories of goods/services to be marketed

• The classes of persons to whom the data will be transferred

• The free response channels through which they can convey their consent

Data subjects have the right to opt out of direct marketing at any time, whether or not they have previously given consent.

12. Data Security

12.1 Security Measures

We will take appropriate security measures against unlawful or unauthorised processing of personal data, and against the accidental loss of, or damage to, personal data.

12.2 Procedures and Technologies

We will put in place procedures and technologies to maintain the security of all personal data from the point of collection to the point of destruction. Personal data will only be transferred to a data processor if he agrees to comply with those procedures and policies, or if he puts in place adequate measures himself.

12.3 Data Security Definitions

We will maintain data security by protecting the confidentiality, integrity and availability of the personal data, defined as follows:

• Confidentiality: Only people who are authorised to use the data can access it

• Integrity: Personal data should be accurate and suitable for the purpose for which it is processed

• Availability: Authorised users should be able to access the data if they need it for authorised purposes. Personal data should therefore be stored on the Company's central computer system instead of individual PCs

12.4 Security Procedures Include

• Entry controls: Any stranger seen in entry-controlled areas should be reported

• Secure lockable desks and cupboards: Desks and cupboards should be kept locked if they hold confidential information of any kind

• Methods of disposal: Paper documents should be shredded. Digital storage devices should be physically destroyed when they are no longer required

• Equipment: Data users must ensure that individual monitors do not show confidential information to passers-by and that they log off from their PC when it is left unattended

• Encryption: Sensitive medical and rehabilitation data should be appropriately encrypted

• Access controls: Restrict access based on the "need to know" principle

• Staff training: Provide relevant training to staff on proper handling of personal data

12.5 Data Breach Notification

In accordance with recommendations in the 2024 amended Ordinance, when a data breach event constituting a significant risk occurs, the organisation must notify the Privacy Commissioner's Office (PCPD) and affected individuals. This requirement ensures transparency and accountability.

13. Transferring Personal Data to a Country Outside HKSAR

13.1 Transfer Conditions

We may transfer any personal data we hold to a country outside HKSAR, provided that one of the following conditions applies:

• The country to which the personal data are transferred ensures an adequate level of protection for the data subjects' rights and freedoms

• The transfer is necessary for one of the reasons set out in the Ordinance, including the performance of a contract between us and the data subject, or to protect the vital interests of the data subject

• The transfer is legally required for the establishment, exercise or defence of legal claims

• The transfer is authorised by the relevant data protection authority where we have adduced adequate safeguards with respect to the protection of the data subjects' privacy, their fundamental rights and freedoms, and the exercise of their rights

13.2 Overseas Processing

Subject to the requirements in clause 13.1 above, personal data we hold may also be processed by staff or contractors operating outside HKSAR who work for us or for one of our suppliers. That staff may be engaged in, among other things, the fulfilment of contracts with the data subject, the processing of payment details and the provision of support services.

14. Disclosure and Sharing of Personal Information

14.1 Sharing Within the Group

We may share personal data we hold with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.

14.2 Disclosure to Third Parties

We may also disclose personal data we hold to third parties:

• In the event that we sell or buy any business or assets, in which case we may disclose personal data we hold to the prospective seller or buyer of such business or assets

• If we or substantially all of our assets are acquired by a third party, in which case personal data we hold will be one of the transferred assets

14.3 Legal Obligations

If we are under a duty to disclose or share a data subject's personal data in order to comply with any legal obligation, or in order to enforce or apply any contract with the data subject or other agreements; or to protect our rights, property, or safety of our employees, customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

14.4 Data Sharing Among Medical Professionals

For rehabilitation services, we may need to share personal data with the following parties:

• Third party service providers involved in patient treatment (for example, laboratories or technical services)

• Delivery services handling medication or equipment delivery

• Other medical service providers to whom the patient has consented to disclosure or transfer of data

• Hospital Authority Electronic Health Record System (with consent)

All sharing is based on the "need to know" principle and limited to health data relevant to the provision of medical services.

15. Dealing with Subject Access Requests

Data subjects must make a formal request for information we hold about them. This must be made in writing to the Data Protection Compliance Manager.

15.1 Response Timeline

In accordance with Ordinance requirements, we must respond to a data subject's request in writing within 40 days.

15.2 Standard Forms

Data subjects may make an access request using the "Personal Data Access Request Form" prescribed by the Privacy Commissioner's Office (PCPD).

16. Personal Data Access and Revision

Data subject may access and check the personal data which is retained by us. If the data user wants to revise the personal data he or she has provided with us, please contact our Data Protection Compliance Manager in writing either by post or email at:

By Post

Data Protection Compliance Manager
Easy Care Group Limited
Room 1703, Marina House
68 Hing Man Street
Shau Kei Wan, Hong Kong

By Email

enquiry@easycarehk.com

16.1 Rights of Access

In accordance with sections 18 and 22 of the Ordinance and Principle 6 of Schedule 1, you have the right to access and correct personal data. Your right of access includes the right to obtain a copy of personal data you have provided.

16.2 Access Fees

We may charge a prescribed fee for providing a copy of personal data.

16.3 Correction Requests

If you discover that personal data is inaccurate, you may request that it be updated/corrected. Please complete the relevant form provided by the service unit and submit it to the Company.

17. Changes to This Policy

We reserve the right to change this policy at any time. Where appropriate, we will notify data subjects of those changes by mail or email.

Contact Us

If you have any enquiries regarding this Privacy Policy or Cookie Policy, please contact:

Easy Care Group Limited
Address: Room 1703, Marina House, 68 Hing Man Street, Shau Kei Wan, Hong Kong
Website: https://www.easycarehk.com/
Email: [Please provide the actual email address for Easy Care Group Limited]

Last Updated: January 2026

This policy complies with the requirements of the Personal Data (Privacy) Ordinance (Cap 486) of Hong Kong and the proposed 2024 amendments to the Ordinance.