**《**Privacy Policy Statement (“Privacy Policy”)

1. Introduction

Here at Take2 Health Limited ("we", "us" or "our"), privacy is a top priority. We are committed to ensure that your personal data is handled and protected in a reasonable manner and in compliance with the requirements of the Personal Data (Privacy) Ordinance (Cap.486) by having in place appropriate administrative, technical and physical safeguards.

Our privacy policy is founded on the following key principles:

• Transparency. We strive to be clear about the type of information we collect.
• Simplicity. We will write in easy-to-understand language to help you make informed decisions.
• Control. You own your personal data and we let you control how it can be used.

If you are under the age of 18 or are mentally incapacitated, we shall seek consent to collect, use or process your personal data from your parents, lawful guardian, next-of-kin and/or carer before providing you with our services and/or products.

Personal data refers to information that can identify you in a form which access to or processing of it is practicable. This Privacy Policy aims to address how we handle personal data collected in the course of providing our services and products to you.

2. Collection of personal data

Generally, our first interaction is when you receive medical services from your healthcare professional (usually at a clinic, hospital or other medical institutions) (collectively as “Healthcare Provider(s)”), and as part of that service, the Healthcare Provider, on your behalf, request us to provide certain services to you.

Your Healthcare Provider would have provided you with a Take2 Welcome Pack which, among other things, includes forms which we require you and the Health Care Provider to complete in order for us to provide our services and/or products as recommended or ordered by your Healthcare Provider. The table below depicts the type of information that we collect from you and/or from your Healthcare Provider.

Whilst your Healthcare Providers would have a separate agreement with you concerning their collection, use and processing of your personal data, you hereby represent to us that all such information provided to us on your behalf (including but not limited to your Healthcare Providers) are true and accurate, and that such third-parties are authorised to provide such information to us.

Use Descriptions

Type of information

• Personal Information

  full name in English and Chinese (if any)

Email address

Contact number

Contact address

Gender

Date of birth

• Contact Information full name in English and Chinese (if any)

Email address

Contact number

WhatsApp number

WeChat ID

• Payment Information

(Only applicable to certain individuals)

 credit card numbers and name

Billing and shipping address

Stored-value payment account details

• Additional User Information

Information that are provided to us:

(i) by your Healthcare Providers for us to provide our services and/or products; or

(ii) by you in your answers and/or response to any questionnaires, forms, surveys offered through our service, Take2 Extra Care or when you make enquires to or contact our customer service team.  personal health information

- disease conditions

- medical and clinical history

- physiological data

- medication history

- family medical history

- or all other relevant information related or not related to health

• Genetic Information

As part of our services, we extract your DNA from your biological samples provided to us by your Healthcare Providers and generate reports based on the findings.

Both your genotype and DNA Sample (collectively as “Genetic Information”) shall be stored at our facility for future testing and/or medical research purpose.

 biological samples stored in the form of blood

information concerning your genotype, and other genetic and genomic information

• Test Results

   Data and test results generated from your biological samples

Test reports

3. Purpose of collection

Type of information

Use Description

• Personal Information

   creating a unique identifying marker (e.g. a set of unique number / barcode) for each biological sample, such that a person’s identity cannot be readily ascertained by just looking at the label)

storage of Test Results and/or any Additional User Information

providing you with our test services and products

in relation to our Take2 Extra Care (if applicable),

(i) creating a member account (i.e. Participant Profile) for subscribing you to our Take2 Extra Care

(ii) authenticating access to your Participant Profile

(iii) following up on the Test Results

(iv) sending reminders to you in relation to any follow-up tests

(v) providing you with information of our products and services (if applicable)

(vi) issuing surveys and/or questionnaires to collect Additional User Information

(vii) offering our aftersales services (if applicable)

handling your enquiries and/or complaints on our products and/or services

issuing surveys and/or questionnaires to collect Additional User Information for providing test services to you

delivering to you directly any Test Results and/or reports

detecting and/or protecting against error, fraud, infringement and/or other criminal malicious activity

providing updates, news, developments and promotional campaigns (if applicable)

informing you of products and/or service changes (if applicable)

• Contact Information

• Payment Information

   processing payments for any Take2 products and/or services and/or any refund thereof when you make a purchase directly from us online or offline

• Additional User Information analysing samples (blood, saliva, urine) or a biopsy; generating a report with or without discussions on the results and delivery of the same

• providing you with insights of what your Genetic Information has revealed about you

• using and sharing de-identified Genetic Information and Test Results with other research collaborators, universities for the purpose of conducting medical research for future discoveries

• improving and developing new reports, tools, technologies, products, services and/or for internal analysis to enhance our user experience, technologies, products, and/or to evaluate our promotional campaigns

• aggregating and collating Genetic Information on an anonymous basis to better understand the population and certain conditions and conducting medical, scientific, technological and statistical research

• improving the functionalities, features and/or quality of our products and/or services

• mproving your user experience of our services and/or products

• Genetic Information

• Test Results

If you sign up for Take2 Extra Care, we may use all such information that we received or obtained from the provision of test services for membership account opening and delivery of our health management services under Take2 Extra Care.

4. Disclosure and transfer

If the products and/or services are provided to you as part of the Healthcare Providers’ services, we shall provide such Healthcare Providers with your tests results and/or information so that they can use such information in their provision of services to you, which may include health consultations, treatment, diagnosis, follow-up checks, testing and/or such other services as agreed between you and your Healthcare Providers.

We will keep your personal data confidential, however, you acknowledge and agree that for the purposes set forth in Section 3 above, we may provide information on a need-to-know basis to the following parties who are subject to contractual obligations governing data security and confidentiality comparable to this Privacy Policy and applicable laws:

(A) our holding companies, subsidiaries or affiliated companies in and/or outside of Hong Kong;

(B) independent contractors and/or other service providers for them to provide their services to us, including:

– third-party laboratory testing services providers

– courier services providers

– payment gateways or other payment processors

– cloud services providers which supports our database

– data storage and management services providers

– market research and profiling services providers

(C) research collaborators, universities, non-profit organisations that conduct and/or support scientific research, and/or research institutions that conduct scientific research with us;

(D) law enforcement authorities in order for us to comply with laws and/or regulations, or any valid orders of any competent courts.

For the purposes of optimising your experience and improving our products and/or services, we may also use your personal data for analysing spending patterns and choices and for conducting market surveys, and your personal data may be disclosed, transferred to third-party information technology, marketing data analysis and management services providers and related entities, some of which may be located abroad.

5. Security and retention

We will take commercially reasonable steps to ensure that your personal data is protected against unauthorized and/or accidental access, processing, erasure and/or use. In particular, we maintain a comprehensive security program designed to protect your personal data using appropriate administrative, physical and technical safeguards. The level of measures would be proportional to the sensitivity of the personal data collected.

We shall also review our security and privacy practice regularly and carry out all necessary actions to improve our practice in order to ensure that your personal data will not be subject to misuse, accidental loss or unauthorised access. While it is not possible for us to guarantee that such adverse events will not occur, we pledge to use reasonable efforts to prevent them from happening.

If you are given a sets of login credentials to access our services, we recommend that you maintain a strong password and do not share such information with anyone.

Unless your personal data is transferred to other third parties as described in Section 4, access to your personal data will be restricted to our employees, who are authorized and trained to handle such data, and are under strict confidentiality obligations.

Encryption technology will be employed for the transmission of your personal data collected.

Personal data will only be retained for as long as is necessary to fulfil the purpose(s) of collection.

6. Data access and correction

You have the right to request access to and correction of your personal data held by us. A reasonable administration fee for processing your personal data access may be payable by you in order to process such request.

You understand that there may be a slight delay for us to amend, correct, and/or delete your personal information or Genetic Information from the time we receive your request to its completion. We endeavour to process your request as soon as practicable.

In some cases, we may aggregate personal data in a de-identified form. Once aggregated, this information ceases to be personal and will not be subject to deletion requests.

You have the full rights to ask us to delete or destroy any biological samples provided to us or to be excluded from medical research by sending us an email at: customer.support@take2.health. Please note that it would not be possible for us to delete your Genetic Information in any on-going or completed research projects, but we will not include such information in any new research project upon receipt of your request.

To exercise the rights set forth in this Section 6 or to withdraw any consent you have previously given to us, please send your request by post or by email:

Mailing address: Unit 506, 5/F, Building 12W, Hong Kong Science Park, Sha Tin, N.T., Hong Kong

Email address: customer.support@take2.health

7. Language

The original English version of this Privacy Policy Statement has been translated into Chinese. In the event of a dispute about the contents or interpretation of this Privacy Policy Statement or inconsistency or discrepancy between the English version and the Chinese version of this Privacy Policy Statement, the English version shall prevail.

8. Amendments

This Privacy Policy may be amended from time to time and the updated policy will be published on our website and hard copies will be available for collection at our office. You are recommended to check for any update by assessing our website at www.take2.health or by writing to us.

If you object to any changes, please inform our customer services to remove your account with us.