This Privacy Policy (“Policy”) applies to the TrillionsMed website and app, and when you share your Personal Data with us through our in-app service subscriptions, by phone, or via other voluntary (the “Site”) effective 1 October 2023. It explains how we may collect, use and disclose your Personal Data, including our obligations and your rights in respect of our dealings with your Personal Data, consistent with our commitment to providing you with a satisfactory service experience.

TrillionsMed (“TM”, “we”, “us”, “our” and “Company”) and its subsidiaries and affiliates practice vary depending on our products or services we provide and the country-specific requirements for the countries in which we operate. For some products and services, where required, we will provide additional privacy statement before collecting your personal information.

Please read this Privacy Policy carefully. By visiting the Site and/or using our services made available to you through the Site, you are agreeing to this Privacy Policy which shall apply to all information that we have about you, and that any dispute over privacy is subject to this Privacy Policy and our Site’s Terms and Conditions.

Our privacy

1. Personal Data

• Personal data (“Personal Data”) includes your name, residential address, email address, phone number, gender, age, credit or debit card data, and any other information you may supply us for identification purposes.
• Our Site is intended for use by adults. We do not knowingly collect any Personal Data from children under the age of 13. Those under the age of 13 should not use the Site or provide us with any Personal Data.
• If you provide us with Personal Data about another person, you represent and warrant to us that you have obtained all necessary consents from that other person to permit us to use that Personal Data as set forth in this Privacy Policy.

2. Collection of Personal Data

• We may ask you to provide Personal Data when you use the Site, including when you voluntarily register or update your existing profile with us, subscribe to catalogues or newsletters, email us, use our customer services, answer surveys, enter promotional opportunities, post on our social networks’ message boards, or make any other submissions to our Site.
• Please note that it is mandatory for you to provide certain categories of Personal Data (as specified at the time of collection). In the event that you do not provide any Personal Data marked as mandatory, we may not be able to process your request, or provide you with our products or services.
• We may use cookies or similar technologies on our website to help us manage your website experience, and allow for customization of the web pages presented to you when you return to the website. We do not collect or store Personal Data from you under this circumstance. You can opt to disable cookies or similar technologies at any time by simply modifying your browser’s configuration, but certain functionality may become not available if you do so.

3. Purpose of Collection

• We collect and use Personal Data about you for the following purposes:

1. To provide you with and improve our services;
2. To personalise and improve your experience on the Site and App;
3. To process applications or requests made by you;
4. To register for an account with us to build an application;
5. To apply to become a partner;
6. To respond to and follow up on your enquiries and provide customer service;
7. To deliver service messages and other services and content you request and to send information related to accounts and services, including confirmations, invoices, technical notices, updates, security alerts and support and administrative messages;
8. To conduct statistical analysis, research, surveys, quality assurance and review;
9. To notify you of changes to our services that may affect you;
10. To send you information about new promotions, products and services offered by Payment Asia and our selected partners;
11. To conduct an aggregated analysis of the performance of promotions;
12. For internal record keeping;
13. To meet regulatory and/or compliance obligations; and
14. For other purposes directly relating to any of the above.

4. Management of Personal Data

• We take reasonable steps to make sure that the Personal Data we collect is protected from unauthorised access, disclosure, misuse or loss. We will collect, use or disclose your Personal Data only with your knowledge and consent, as set out in this Privacy Policy unless otherwise required or permitted by law.
• We take your privacy seriously. We have implemented security safeguards appropriate to the sensitivity of the information, including the use of the following measures:

1. Physical security measures, such as restricted access facilities and appropriate disposal of Personal Data; and
2. Electronic security measures, such as password protection, for accessing computerised Personal Data.

• Please note that we cannot be responsible for any Personal Data you share or post by way of submissions to the public spaces of our Site. These are public areas and may be consulted or viewed by anyone visiting these sections of our Site and, as such, falls outside this Privacy Policy.

5. Storage of Personal Data

• We will keep your Personal Data as accurate, complete and up-to-date as necessary and reasonably possible for the purposes for which it is to be used in accordance with Clause 3.
• We will only retain your Personal Data as long as necessary for purposes listed in Clause 3 or as required by law.

6. Log Data

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third-party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics.

7. Disclosure to Third Party

• Personal Data will not be used or disclosed for purposes other than those listed in Clause 3, except with your consent/indication of no objection, or as required/permitted by law.
• To fulfill the purposes in Clause 3, we may disclose or transfer (whether in Hong Kong SAR, Macau SAR or abroad) your Personal Data to third parties, including our parent, subsidiary and associated companies. In particular, we may share your Personal Data with third party contractors or service providers (“Third Party”) who help with our business operations, such as suppliers of technological services, financial transactions, logistics services, transportation, reward programmes, purchase order management, customer service, fraud investigations, and/or analysis of any transactions made through the Site.
• We may share the personal information you provide with the following third parties only as necessary for the third party to provide that service:

1. Credit card processing companies and payment providers to bill you for services;
2. Email service providers to send out emails on our behalf;
3. Employment resources companies to process your job applications;
4. Business partners, joint venture partners, service providers, vendors, agents, consultants and independent contractors who provide administrative or other services to us as required in the normal course and scope of our business:

• to comply with any applicable law, statute, governmental order or court order or respond to any lawful request and legal process;
• to protect the rights and property of Payment Asia, our agents, members and others including to enforce our agreements, policies and terms of use;
• in the good faith belief that disclosure is needed to respond to an emergency or protect the personal safety of any person; and
• in connection with any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.

• Please be assured that we shall implement contractual or other appropriate means to ensure compliance by such Third Party with this Privacy Policy and all applicable privacy laws when we disclose your Personal Data to Third Party.
• We may share aggregate data that does not allow you to be identified with Third Party for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services.
• If we consider it necessary to share your Personal Data with Third Party other than for the reasons specified in this Clause, we will notify you and will only proceed with your consent/ indication of no objection.
• In the event of suspected fraud, threat to personal safety, or violation against our Terms and Conditions or relevant laws, we shall take prompt and all appropriate measures to investigate and address such risks.
• By providing Personal Data through the Site or otherwise to us, you expressly authorise us to use and disclose your information as described. Please do not proceed if you do not agree on the abovementioned Personal Data usage.

8. Changes to the Privacy Policy

We may make changes to this Privacy Policy from time to time. You should check our website frequently to view recent changes of our Privacy Policy.

9. Your Right to Access Personal Data

• You have the right of access to or correction of, and to withdraw your consent concerning your Personal Data held by us.
• If you have any questions regarding this Privacy Policy, or if you wish to access or change your Personal Data, or withhold the information from us, you may login in your account through website or Apps to edit or update your Personal Data, or send your request in writing to the following:

Address : Unit 203, 2/F, No 19 Science Park West Avenue (19W), Hong Kong Science Park, Shatin, New Territories, Hong Kong

Email : info@trillionsmed.com

• We reserve the right to charge you a reasonable fee for the processing of any data access request.

10. Rights of Third Parties

Notwithstanding the Contracts (Rights of Third Parties) Ordinance (Cap. 623), and/or any comparable law in any jurisdiction, this Personal Privacy is personal to and is made solely for the benefit of you and us, and shall not create or give any rights to, or purport to confer any benefits on any third parties whatsoever. The application of the Contracts (Rights of Third Parties) Ordinance (Cap. 623), and/or any comparable law in any jurisdiction, giving to or conferring on third parties, the right to enforce any term of this Personal Privacy, is expressly excluded, and no term of this Privacy is, or is intended to be, enforceable by any person not being a party to it. The rights of the parties to terminate, rescind, or agree any amendment, waiver, variation or settlement under or relating to this Personal Privacy, are not subject to the consent of any third party.