Privacy policy

 

Last updated: May 16, 2026

By using the Website, Services, Confidential Materials and/or Public Content, you agree to be bound by this privacy policy (this Privacy Policy). If you do not agree with any part of this Privacy Policy, we cannot provide the Website, Services, Confidential Materials and/or Public Content for your use, and you should stop using the same.

We may update this Privacy Policy from time to time. Any changes will become effective upon posting of the revised Privacy Policy via the Website. If required by law, we will obtain your express consent to changes in how we use and/or disclose your Personal Data. Otherwise, your continued use of the Website, Services, Confidential Materials and/or Public Content shall constitute your acceptance of the updated Privacy Policy.


1. DEFINITIONS

Capitalized terms shall have the meaning given in the Terms and Conditions available on the Website unless otherwise herein defined:

Non-personal Information means any Personal Data that has been depersonalized such that the identity of the individual is no longer directly or indirectly ascertainable, either by combining it with information about other individuals (aggregating Users’ information), or by removing characteristics (such as the Users’ name) that make the information personally identifiable to the Users;

PDPO means the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong), as amended from time to time;

Personal Data means personal data collected from Users, held, processed and used by us and our Affiliates which (i) relates directly or indirectly to the Users; (ii) can be used to ascertain the Users’ identity as an individual; and (iii) is in a form where access to and/or processing of such data is practicable, including but not limited to, Users’ personal information such as Users’ full name, contact details, email addresses, payment information (such as credit card, shipping address and/or billing address), age, gender, date of birth, marital status, Users’ (and Users’ household and/or family members’ (as applicable)) health and wellness information (such as dietary and lifestyle habits, environmental exposures, health concerns, medical diagnoses, symptoms, medical and dental history, family history, medications, supplements, health data, health records, and other information relating to Users’ health, physiology and/or medical conditions), Users’ biometric data, information collected through cookies as set out in clause 8 and any information provided by or in relation to Users pursuant to this Privacy Policy;

Terms and Conditions means the Terms and Conditions available on the Website, as revised, modified or otherwise updated by us from time to time;

We refers to Wellness Blueprints Limited, the company responsible for the collection, holding, processing and/or use of Personal Data, and is the data user of this Privacy Policy (as such term is defined in the PDPO), and us and our shall be construed accordingly; and

You refers to any User or Client, as applicable, who is or may become the data subject of this Privacy Policy (as such term is defined in the PDPO) and whose Personal Data is or may be collected, held, processed and/or used, and your shall be construed accordingly.


2. PURPOSE OF COLLECTION, HOLDING, PROCESSING AND/OR USE OF PERSONAL DATA

2.1 We will ask you to voluntarily provide your Personal Data for the purposes set out in clause 2.2.

2.2 The collection (which shall be adequate and not excessive), holding, processing and/or use of your Personal Data shall be for the following specific and lawful purposes only:

(i) to enable your access and use of the Website, Services, Confidential Materials and/or Public Content;

(ii) to communicate with you, including but not limited to, for the provision of technical, administrative and operational information regarding the Website and/or Services, and handling of your requests and complaints;

(iii) to conduct surveys and customer reviews about your experiences with the Website, Services, Confidential Materials, Products and/or Public Content;

(iv) to operate, protect, improve and optimize the Website and/or Services and to improve and customize your experiences when using the same, including but not limited to the collection of Personal Data through cookies as set out in clause 8;

(v) to offer tailored content to you in accordance with your interests or other indications;

(vi) for our internal and external business and administrative purposes such as to conduct research and development for new products, features, services and applications in relation to the Website and/or Services;

(vii) where applicable and subject to compliance of the PDPO, to provide you with marketing and promotional materials for your enjoyment of the Website and/or Services;

(viii) only when you have provided the consents required under the PDPO, to send you personal newsletters, marketing and promotional messages and other information (either alone or in conjunction with products, features, services and/or applications offered by our Affiliates or business partners) that may be of interest to you in accordance with clause 6;

(ix) to enforce our and our Affiliates’ legal and/or contractual obligations and rights, and to resolve disputes between third parties, you and us (and our Affiliates);

(x) to derive, create or otherwise transfer Personal Data into Non-personal Information for the purpose of creating general depersonalized data statistics, reference materials, and protocols to assist in providing future services;

(xi) for our and our Affiliates’ compliance of relevant laws and regulations; and

(xii) other purposes directly relating to any of the above.

2.3 For the avoidance of doubt, we are entitled to collect, hold, process and/or use Non-personal Information for any lawful purpose relating to our function and activity, including but not limited to conducting research and analysis to improve the Website, Services, Confidential Materials, Public Content and/or our businesses.


3. DATA ACCESS AND CORRECTION REQUEST

3.1 In accordance with the terms of the PDPO, you have the right to (i) request access to your Personal Data, including being informed by us whether we hold your Personal Data and, if we hold your Personal Data, receiving copies of your Personal Data; and (ii) request us to correct your Personal Data which is inaccurate. 

3.2 In order to protect your Personal Data, you will be required to prove your identity in relation to your request to access and/or correct your Personal Data. Requests for access and/or correction of Personal Data are to be addressed in writing and sent to privacy@healthunboundhk.com. A reasonable fee shall be charged to offset our administrative and actual costs incurred in complying with the relevant data access requests. If there are reasonable grounds for believing that any of your Personal Data is inaccurate with regard to the purpose(s) for which the Personal Data is or is to be used, we shall (i) ensure that such Personal Data shall not be used for such purpose(s) unless and until those grounds cease to be applicable to such Personal Data or such Personal Data is erased; and (ii) inform any third party to whom such Personal Data was disclosed that such Personal Data is inaccurate and provide to them such particulars as will enable such third party to correct the Personal Data having regard to such purpose(s).


4. RETENTION OF PERSONAL DATA

4.1 Where any Personal Data held by us is no longer required for the purposes as stated under clause 2.2, we shall take practicable steps to cease processing and holding of such Personal Data as soon as reasonably practicable, provided that we may keep copies of such Personal Data as is reasonably required and permitted under the PDPO for (i) archival purposes; (ii) use in relation to any actual or potential dispute; (iii) compliance with applicable laws and regulations; (iv) enforcing any agreement we and our Affiliates have with you; and/or (v) protecting our and our Affiliates’ rights.

4.2 You may request removal of your Personal Data from our storage by sending an email to privacy@healthunboundhk.com. For the avoidance of doubt, we are entitled to retain, process and/or use any Non-personal Information for any purpose indefinitely.


5. DISCLOSURE AND TRANSFERRAL OF PERSONAL DATA

5.1 We may make certain Personal Data available to our Affiliates, who may be situated within or outside Hong Kong and all of whom are bound by this Privacy Policy, for the purposes as stated in clause 2.2.

5.2 We may also make certain Personal Data available to Third Party Service Providers, who may be situated within or outside Hong Kong, including but not limited to:

(i) Third Party Product Providers;

(ii) Third Party Test Providers;

(iii) data storage service providers, for the sole purpose of storing data collected by us; and

(iv) mail houses and email service providers, for the sole purpose of mailing and disseminating promotional materials.

5.3 All Third Party Service Providers are contractually (i) prohibited from using Personal Data for any purpose other than those specified in their respective arrangements and keeping Personal Data longer than is necessary for the fulfilment of such purpose(s); and (ii) required to prevent unauthorized or accidental access, processing, erasure, loss, use or disclosure of Personal Data.

5.4 In the circumstances where we reorganize our group structure and/or undergo a change of control or business combination, Personal Data may, at our sole discretion, be transferred to a third party who will continue to operate our business or a similar service under either this Privacy Policy or a different privacy policy statement of which we will notify you. Such a third party may be located, and use of Personal Data may be made, outside of Hong Kong in connection with such acquisition and/or reorganization.

5.5 By accepting this Privacy Policy, you understand and acknowledge that your Personal Data may be disclosed or transferred to our Affiliates and/or any such third party under clause 5. 


6. DIRECT MARKETING AND OPTING OUT

6.1 We may use Personal Data for direct marketing. Only when you have provided the consents required under the PDPO will we use your Personal Data for direct marketing to contact you and provide information about the Website, Services, Confidential Materials, Products, Public Content, and/or new health and wellness related products, features, services and applications (including but not limited to new health and wellness programs or services, product launches, special offers, workshops, webinars, events, wellness tips, and educational content) from us and/or our Affiliates that may be of interest to you.

6.2 Personal Data will not be shared with third parties for their own marketing purposes.

6.3 You may unsubscribe from all direct marketing communications from us. Every time you receive a direct marketing email, you will be provided with the choice to opt-out of future direct marketing emails. You may also opt-out of receiving personal promotional materials by sending an email to privacy@healthunboundhk.com at any time, without charge by us.


7. THIRD PARTY SITES

7.1 The Website may contain links to other websites and/or applications. You understand and acknowledge that these links do not constitute our and/or our Affiliates’ endorsement or authorization for the collection of Personal Data by such third parties, nor a representation of any affiliation between such third parties and us (and our Affiliates). Once you click on a link to a third-party website, application or advertisement, these third parties may collect information from you and follow different rules regarding the collection, use, holding, processing and/or disclosure of Personal Data. Accordingly, we and our Affiliates are not responsible for the content and/or activities of these linked websites, applications and/or advertisements (including any collection, use, holding, processing or disclosure of Personal Data by such third parties).

7.2 The Website and/or Services may contain features that interact with third-party social media sites, such as Facebook, Instagram and Google. You understand and agree that when you use these features, you are bound by the privacy and cookies policies (as applicable) (as may be amended from time to time) of these third-party social media sites.


8. COOKIES

8.1 You understand and acknowledge that you could become a data subject when you use the Website as we may use cookie files to collect information about you. Any information about you collected by means of cookies when using the Website would be Personal Data. We may use such information for compiling aggregate statistics on how you use the Website and/or Services. Such statistics are collected for managing, enhancing and improving your experiences when using the Website and/or Services. The providers of Third Party Tools may also use such information for compiling information in order to analyse your interests and searches to provide advertisements tailored to your interests and searches when accessing the Website and/or Services.

8.2 Most web browsers are initially set up to accept cookies. You may choose to reject cookies by changing the settings of your web browser. By choosing to reject cookies, certain features on the Website may not be accessible and available to you, and some of your preferences, including but not limited to your preferred languages and searches, may not be remembered by the Website.


9. CROSS-BORDER DATA TRANSFER

9.1 Where applicable, you understand and acknowledge that your Personal Data may be transferred to, processed and/or stored outside Hong Kong and we shall do so in accordance with the PDPO. Where applicable, you consent to the transfer, process and/or storage of your information, including Personal Data, to/in Hong Kong as set forth in this Privacy Policy by using the Website, Services, Confidential Materials and/or Public Content.

9.2 The Website, Services, Confidential Materials and/or Public Content are intended for Users located in Hong Kong. By using the Website, Services, Confidential Materials and/or Public Content, you confirm that you are located in Hong Kong. If you are located outside Hong Kong, you understand and acknowledge that (i) your Personal Data may not be subject to the same data protection laws as the country in which you provided the Personal Data and (ii) we and our Affiliates do not intend to comply with laws other than laws of Hong Kong when providing access and/or use of the Website, Services, Confidential Materials and/or Public Content.


10. STATEMENTS OF POLICIES IN RELATION TO PROTECTION OF USERS’ PRIVACY INTEREST

10.1 We will collect, hold, process and/or use Personal Data that you make available when assessing or using the Website, Services, Confidential Materials and/or Public Content. We will take appropriate steps to protect Personal Data collected and/or held by us against unauthorized or accidental access, processing, erasure, loss, use or disclosure.

10.2 We are committed to protecting the privacy, confidentiality and security of Personal Data we hold by complying with the requirements of the PDPO with respect to the management of Personal Data. We are equally committed to ensuring that our Affiliates uphold these obligations and we will ensure compliance by our staff with the strictest standards of security and confidentiality.


11. LEGAL DISCLAIMER

11.1 We and our Affiliates may need to disclose Personal Data when required by Hong Kong law or court order, or as requested by other government or law enforcement authorities. This also applies when we and/or our Affiliates have reasons to believe that disclosing such Personal Data is necessary to identify, investigate, protect, contact or bring legal action against someone who may be causing interference with you, other Users, or any third party, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

11.2 You understand and acknowledge that this Privacy Policy does not apply to any unsolicited information you provide to us and/or our Affiliates through the Website, Services, Confidential Materials and/or Public Content or through any other means. All unsolicited information shall be deemed non-confidential and we and our Affiliates shall be free to reproduce, use, disclose, and distribute such unsolicited information to others without limitation or attribution.

11.3 You understand and acknowledge that User Contents provided by you are transmitted to others at your own risk. You acknowledge that no security measures are perfect or impenetrable. You should exercise caution when using social networking features of the Website since the information you choose to make available may be seen by others on those third-party social media sites. Additionally, we and our Affiliates cannot control the actions of other Users with whom you may choose to share your information (which may include your Personal Data). Therefore, we and our Affiliates cannot and do not guarantee that your User Contents will not be accessed by unauthorized persons.