Privacy Policy Statement

“GemVCare Limited” is a medical testing company located in Unit 628, Biotech Centre 2, 11 Science Park West Avenue, Hong Kong Science Park, Shatin, Hong Kong. We respect personal data privacy and are committed to full implementation of and compliance with the data protection principles and all relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance (Cap.486) (“Ordinance”). We shall ensure that our staff handling personal data will comply with the legally required standards of security and confidentiality.


We shall at all times fully observe the Ordinance in collecting, maintaining and using your personal data. In particular, we shall follow the following principles, unless otherwise required, permitted by law or agreed by you:

1. Collection

  1. We will collect personal data from you for lawful purposes relating to:

    • subscription to our testing service;
    • specimen and report identification;
    • generation of testing results;
    • internal improvement work including but not limited to R&D and quality control;
    • provision of our services or products to you; and
    • facilitating your access to the information and services in our application and website (the “Platform”).
  2. We will collect personal data from you directly through the Platform or by other means which are lawful and fair in the circumstances; and
  3. We will take practical steps to ensure that your personal data are and remain accurate, but your assistance may be required to enable us to know if there is any change.

2. Use

  1. Your personal data will be used for the purposes specified herein, including those set out in paragraph 1(a) above; and
  2. We will not be using your personal data for other purposes without your consent.

3. Storage

  1. We will take practical steps to ensure that your personal data will be destroyed immediately after the applicable prescribed retention period and will not be kept longer than necessary; and
  2. We will take practical steps to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure.

4. Security

  1. We will take all practical steps to ensure that your personal data are protected against unauthorized and accidental access and loss.
  2. We may from time to time engage one or more data processers, whether within or outside Hong Kong, to process your personal data on our behalf, but we will take practical steps to ensure that your personal data will be protected against unauthorised or accidental access, processing or erasure.

5. Access

  1. You have the right to access and correct your personal data held by us. Your request for access or correction will be dealt with in accordance with the Ordinance. You may contact us in the manner specified in “Contact Us” section for such purpose.
  2. Your personal data is classified as confidential and can only be disclosed by us in the manner specified herein or where we are permitted by the Ordinance or otherwise legally compelled to do so.You are not obliged to provide the personal data that we have requested, but you may be unable to access some of the information or services on this Platform and we may be otherwise unable to provide some or all of our services or products to you or to respond to any queries you may have without your personal data.

You are not obliged to provide the personal data that we have requested, but you may be unable to access some of the information or services on this Platform and we may be otherwise unable to provide some or all of our services or products to you or to respond to any queries you may have without your personal data.


When you make registration with us for purposes such as enquiries of and appointment for our service, you will be required to give us your personal data (such as your name, surname, phone number and email). We may also collect payment related information (such as credit card details) and other personal information that we believe to be relevant to the provision of our service to you.

  1. The Platform and our servers may automatically collect data about your internet address when you visit our webiste. Like most web servers, we store your IP address in a log file when you visit the Platform. Your IP address is used to help identify you and to gather demographic information about our customers, members and users as a whole. Our server may also record the date, time and referring page that linked you to us (e.g. another website or a search engine); the pages you visit on the website; the website you visit, if any, after the Platform; other information about the type of web browser, computer, related software and settings you are using; any search terms you have entered on the Platform or a referral site; and other web usage activities and data logged by our servers. We use this information for internal system administration, to help diagnose problems with our servers, and to administer our services. This information is for internal use only and will not be given out.
  2. We may use cookies in some areas of the Platform. Cookies are small pieces of information that we store on your computer’s browser or hard drive. Such information does not contain your name or address information or any information that will enable us to contact you via telephone, e-mail or any other means. The information stored is to enable the Platform to function correctly and give you additional features and benefits such as automatic log in. Most browsers give you the option of preventing cookies from being stored on your computer, though doing so may cause you to lose some of the benefits of the Platform.


  1. Your personal dara may be used for:
    1. verifying your identity
    2. processing of your request to use our testing and any other related services
    3. matching (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision of services
    4. marketing and advertising of any services to you by us, related companies, agents, contractors and third party suppliers upon your consent in accordance with the prevailing requirements in the Ordinance
    5. prevention, detection or investigation of crime
    6. disclosure as permitted or required by law
    7. any other purposes as may be agreed to between you and us, including the puropses set out in any application or terms and conditions for the supply of specific services.
  2. Your personal data may be transferred to, stored, processed or otherwise administered by our group members and/or third party agents, contractors or service providers who provide administrative, telecommunications, computer and other data mining and processing services to us. You may object to the above possible uses by giving us a prior notice in the manner set out in “Contact Us” section. After receiving such notice from you, we will cease to use your information in the said manner.
  3. Your personal data, including indentification information and contact details, collected may be used for our administrative, research, statistical, marketing, audit and prescribed purposes as permitted by us and the law from time to time. We shall reveal personal information to any external organization only if required by law or with your prior consent. However, your personal data may also be consolidate with other data and used in aggregate form for research and marketing purposes, and in such circumstances individual data shall not be revealed. Such data may be used by other companies under contractual activities with us for the abovementioned purposes.
  4. Your personal data supplied to us such as email addresses may be used for communication and promotion. You may object to the above possible uses by giving us a prior notice in the manner set out in “Contact Us” section. After receiving such notice from you, we will cease to use your information in the said manner.


    1. Your personal data held by us will be kept confidential by all reasonable steps but we may, where such disclosure or transfer is necessary to satisfy the purpose, or directly related purpose, for which the data was collected provide such information or copies to the following relevant parties:
      • member companies within our group
      • authorized personnel including contractors, consultants and lawyers for performing various buiness functions;
      • government bodies and other regulators as required under the law or pursuant to any regulatory arrangements between us and the relevant government body or regulator;
      • any person under a duty of confidentiality to us and who has undertaken to keep such information confidential, provided that such person has a legitimate right to such information; or
      • any person to whom we are required to make disclosure under any law applicable in Hong Kong.
    2. Your personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right or authority to access such information. In addition, personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned personal data are exempt from the provisions of Data Protection Principle 3 of the Ordinance.
    3. In accordance with the requirements of the Ordinance, we will honour a customer’s request not to use his or her personal data for the purposes of direct marketing. Upon customer’s consent, we may use his or her personal data for direct marketing and any other directly related purposes. For the avoidance of doubt, this consent is separate from and independent of customer’s services registered with us. Accordingly it can be withdrawn at any time in the manner specified in “Contact Us” section below without reference to the duration of the services, and will survive the termination or expiration of customer’s service contracts.
    4. We will do our best to ensure compliance with the Ordinance by providing guidelines to and monitoring compliance of the relevant parties listed above. However, we cannot control how third parties use your personal information and assumes no responsibility for the privacy protection provided by such third parties.


  1. We will destroy any personal data it may hold in accordance with its internal policy. Generally speaking, our policies cover the following principles:
    • personal data will only be retained for as long as is necessary to fulfill the original or directly related purposes for which it was collected, in normal circumstances, it will be retained for 7 years, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
    • personal data are purged from our electronic, manual and other filing systems in accordance with specific schedules based on the above criteria and our internal procedures.


  1. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the information we collect online.
  2. Physical records containing personal data are securely stored area and/or containers when not in use.
  3. The secure area of the Platform supports the use of e.g. 256-bit Secure Socket Layer (SSL) encryption technology or other industry standards for encryption over the Internet to protect data. When you provide sensitive information, such as credit card details, it will be automatically converted into codes before being securely dispatched over the Internet.
  4. Furthermore, our web servers are protected behind “firewalls” and our systems are monitored to prevent any unauthorized access.
  5. Practical steps will be taken to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of personally identifiable information.
  6. You should, however, be aware that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Therefore we cannot guarantee absolutely the security of any information that you transmit to us or recevie from us over the internet.


At times it may be necessary and prudent for us to transfer certain personal data to places outside of Hong Kong in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.


  1. Under the Ordinance, individuals have the right to request access to and correction of their personal data. It is also our intention to keep your personal information on our records accurate and up-to-date.
  2. We could also delete certain personal information held by us should you wish us to do so but this may affect your use of the Platform and/ or our services to you.
  3. Should you wish to access, correct or delete your personal information held by us or enquire about our privacy policy and practice, please contact us by post or email to:-
Name: Cadmon Lim
Title: Chief Operating Officer
Address: Unit 628, Biotech Centre 2, 11 Science Park West Avenue, Hong Kong Science Park, Shatin, N.T., Hong Kong

General Disclaimer

Gemomic Technology is a university-owned, patented technology which utilizes genetic tests to identify subjects who may develop diabetes and suffer its resulting complications. GemVCare Ltd (referred to herein as “GemVCare”) hereby expressly disclaims any and all liability as follows: Any and all data, information and result including without limitation in connection with the GemVCare services, whether medically based or otherwise, which is provided under the Gemomic Technology or otherwise (the “Services”) shall be used for reference purpose only. The Gemomic Technology is not intended in any shape or form to be used, construed, interpreted or applied as a substitute for professional medical care or advice which shall be provided by a doctor, physician or other qualified medical/health care professionals. The causes, treatments and consequences of diabetes and its complications are complex and multifactorial. The interactions between bio-genetic markers and other risk factors and treatments require professional interpretation for decision making.

Users of the Gemomic Technology (including without limitations to users and family members of users), who receive, believe, rely or make decisions regarding their health or medical care based on risk predictions provided by the Gemomic Technology do so at their own risk.

Users are reminded to seek professional medical care, health management or other types of advice provided by a doctor, medical practitioner, physician, qualified health care professionals or other professionals after receiving results or reports from the Gemomic Technology and all rights arising thereof and in relation to the Services include without limitation intellectual property shall belong to GemVCare.

The author(s) of the published reports relating to the risk associations of genetic variants and biomarkers and other relevant reports nor GemVCare including without limitations to its shareholders, directors, employees and consultants (if any) are liable or incur any duty of care for any decisions and/or consequences arising from or in relation to the assessment and/or interpretation of the results from the Gemomic Technology or otherwise.

The provision of Services is governed by terms and conditions contained in a respective separate document which this General Disclaimer forms part of and the respective liability caps described therein shall apply with respect to GemVCare’s liability stipulated in this General Disclaimer. No part of any publication may be reproduced or transmitted in any form without the prior written permission of GemVCare. In the event of any dispute or discrepancy between the English version and the translation of other languages of this General Disclaimer, the English version shall prevail.