PRIVACY POLICY STATEMENT

Bright Sight Healthcare Limited and Bright Sight Healthcare (Tsuen Wan) Limited (collectively “Bright Sight”, both members of Optical 88 Limited group of companies (“the Group”)) shall fully comply with our obligations under the Personal Data (Privacy) Ordinance (Cap.486) of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”) and its amendments (collectively the “PDPO”). We shall at all times respect the confidentiality of and endeavour to keep safe Personal Data collected, stored, transmitted by us and/or used for or on our behalf.

In this Privacy Policy Statement, the meaning of the term “Personal Data” is as defined under the PDPO.

GENERAL STATEMENT OF POLICIES AND PRACTICES ON PERSONAL DATA

Collection of Personal Data

(a) For the purpose of carrying on our businesses, you may provide your Personal Data to us when you submit the patient registration form, when you purchase a product or use our services, when you submit any comments or feedback to us, when we ask you to verify your identity or when your image is captured by surveillance cameras at our Centres. (“Centres” refer to Bright Sight Ophthalmology Centres or other centres where professional services/products relating to hearing care and/or medical services relating to the eyes are provided).

(b) We will ask you to provide your Personal Data, including, name, HKID number, gender, contact number, email address, correspondence address, occupation, date of birth and medical information. We may ask you to provide the name and contact of your parent or legal guardian if you are under age 18 or name and contact of your emergency contact person if necessary. 

(c) We will collect Personal Data on a lawful, open and fair basis

(d) As to your medical record, we shall handle with strict compliance of the Code of Professional Conduct for the Guidance of Registered Medical Practitioners.

Purposes for Collection of Personal Data

We will collect and may use your Personal Data for the following purposes:

(a) the provision of our products, services to or making appointment for you at our website and Centres;

(b) the collation of information from the website for usage analysis;

(c) carrying out your instructions or responding to your enquiries, requests or complaints;

(d) forming part of our customer data base necessary for the operations carried on by us;

(e) research and analysis for marketing and promoting our products and/or services;

(f) general security reasons;

(g) transferring, disclosing or sharing your Personal Data or carrying out matching procedure (as defined in the PDPO) on your Personal Data* amongst our Affiliates (as defined below) and Business Partners (as defined below) within and outside of Hong Kong, for the purposes of carrying out (a) to (f) above in this section**;
(h) to allow our Business Partners or person or body corporate with whom our Business Partners enter into arrangements with to carry out the purposes set out in (a) to (g) in this section; 

(i) any purposes related to and/or for the furtherance of (a) to (h) above in this section; and 

(j) direct marketing purposes carried out in relation to the Optical 88 Stores (“Optical 88 Stores” refer to stores operated by the Group such as Optical 88 stores, Optical 88 Family Eyecare, eGG Optical Boutique stores and concept stores) and Optical 88 Centres (“Optical 88 Centres” refer to centres operated by the Group such as Optical 88 Professional Eyecare Centres or other centres where professional services/products relating to hearing care and/or medical services relating to the eyes are provided) in Hong Kong and Macau, on our Group’s websites, and such other online platform and social media channels managed by our Group (whether individually or jointly), our respective Affiliates and/or Business Partners. 

Without your consent, we shall not use your Personal Data for purposes other than those specified above.

Accuracy

We will take all practicable steps to ensure that Personal Data collected is accurate. Please endeavour to provide us with accurate Personal Data upon subscription of our products and/or services and where there are any changes to your Personal Data, please inform us as soon as possible.

Personal Data Sharing, Transfer and Disclosure

Your Personal Data may be processed and stored in territories outside of Hong Kong**.

All Personal Data held by us will be kept confidential and we will not sell your Personal Data to any person or company but we may, where sharing, transfer or disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected provide such information to the following parties:

(a) amongst our Affiliates and Business Partners within and outside of Hong Kong**

(b) amongst our Affiliates and Business Partners for direct marketing purposes if you have consented to do so**; and

(c) any person or persons pursuant to any statute or as required by any court of law in Hong Kong, provided such person or persons are able to prove the required right/authority to access such information.

Access and Correction

You may check whether we hold any of your Personal Data and, if so, may request

(a) access (i) by sending an e-mail to the Data Protection Officer at cs@brightsight.com.hk; or (ii) by mailing us at 27th Floor, Stelux House, 698 Prince Edward Road East, San Po Kong, Kowloon, Hong Kong (Attention: Data Protection Officer); 

(b) corrections (i) by sending an e-mail to the Data Protection Officer at cs@brightsight.com.hk.

We will take reasonable steps to verify your identity before granting access or permitting corrections to your Personal Data. We will endeavour to respond within 40 calendar days of your request in compliance with the PDPO. We will charge a reasonable fee to cover our administrative costs when you request access to your Personal Data. We will comply with your request after the imposed fee is paid. We will not charge a fee for corrections to your Personal Data. Should we refuse your request for access or correction, reason(s) will be given. You may object to our refusal to grant you access or correction.

Security

We strive to ensure that your Personal Data will be protected against unauthorised or accidental access, processing, erasure or other use. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your Personal Data.

Retention of Personal Data

Your Personal Data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless this is contrary to any applicable laws.

Amendment to this Statement

We may amend this Privacy Policy Statement from time to time without prior notice and any changes will be posted on Bright Sight’s website. You are advised to check for the latest version regularly. If there is any inconsistency or conflict between the version posted on the website and the previous version, this version shall prevail. All handling of personal data will be governed by the most recent version of the Privacy Policy Statement. 

Statement of Policies and Practices on Direct Marketing

We intend to use your name, email and contact number for direct marketing purposes as described below:-

(a) promotions relating to eyewear, eyecare and hearing care products/services sold/provided at the Optical 88’s Stores and the Optical 88’s Centres in Hong Kong and Macau, on our Group’s websites and such other online platforms and social media channels managed by our Group (whether individually or jointly), our respective Affiliates and/or Business Partners; 

(b) marketing activities relating to eyewear, eyecare and hearing care products/ services sold/provided our at the Optical 88’s Stores and the Group’s Centres in Hong Kong and Macau, on our Group’s websites and such other online platforms and social media channels managed by our Group (whether individually or jointly), our respective Affiliates and/or Business Partners; 

(c) cross-marketing and promotional amongst our Affiliates and Business Partners for any one of (a) to (b) above.
In future, if you do not wish to continue receiving our promotional materials for direct marketing purposes, please either send an email to the Data Protection Officer at cs@brightsight.com.hk to notify us accordingly. Our customer data base will be updated accordingly at no charge to you.

If there are any inconsistencies between the English version and the Chinese version of this Privacy Policy Statement, the English version shall prevail.

For the purposes of this Privacy Policy Statement:

(a) “Affiliates” mean in relation to us, another company that is a direct or indirect subsidiary of, or a direct or indirect holding company of, or another direct or indirect subsidiary of such a direct or indirect holding company of us.

(b) “Business Partners” mean those persons or bodies corporate with whom we enter into arrangements with (whether directly or indirectly) for the provision of our products and/or services to you. 

* For more information on matching procedure, please refer to the Information Leaflet issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong, as published from time to time. 

**Personal Data relating to your medical records will only be collected at the Centres and may be (i) used, shared or retained by and amongst the Centres; (ii) used, shared or retained by our Business Partners if this is necessary and/or ancillary to the products/services sold or provided at the Centres. Your medical records will not be used by, shared with or retained at our Stores.