Your Privacy

Sow Fertility Limited is committed to protecting your privacy and will, at all times, observe the requirements of the Personal Data (Privacy) Ordinance (Cap.486, Laws of Hong Kong) (“Ordinance”) in the collection, use and maintenance of your personally identifiable information (“personal data”). Please visit the official website of the Office of the Privacy Commission (http://www.pcpd.org.hk) for more information about the Ordinance. By visiting this website (https://www.sowfertility.com/zh-hk) and/or downloading and accessing our application (“Platform”) and/or communicating with a practitioner through written, audio or video communications, whilst using our service (whether or not such communication uses our Platform or a third party tool), you accept and consent to the practices described herein.

If you have access to our services through your employer or health plan, please keep in mind that we receive certain personal information about you from your employer or health plan. We may also receive certain information from our partner providers who may provide services to you and/or assist us in providing our services to you (“Partner Provider”), or through third-party sites/applications that we use to help provide our services to you (including third-party AI transcription assistant tools, WhatsApp, Zoom, Instagram, LinkedIn, YouTube and more) (“Third-Party Tool”). We use this information to provide our services to you, communicate with you, confirm your eligibility to receive our services, process benefits and requests for reimbursement, and assess and improve the services we provide to you and your employer or health plan. If you have any questions about our use of this information, please refer to your employer’s and/or health plan’s and/or relevant Partner Provider’s and/or Third-Party Tool’s privacy notice.

Collection and use of personal data

Personal data collected from you on our Platform or through a Partner Provider and/or through Third-Party Tools will only be used for the specific purposes mentioned at the time of collection, or for purposes directly related to those specific purposes and/or in the relevant personal information collection statement (“PICS”). Our PICS is attached hereto as an appendix. Please be aware that if specific information is requested but not supplied by you, we may be unable to provide certain requested services.

Disclosure of your personal data

We will keep your personal data confidential within Sow Fertility Limited and will not disclose your personal data to any third party without your consent, except as is required by law. However, your personal data may be disclosed to any third parties (whether within or outside the Hong Kong Special Administrative Region) where such disclosure is necessary to satisfy the purposes of which the data were collected.

Retention of your personal data

Your personal data will only be retained for so long as is necessary to fulfil the purpose(s) for which they were collected. After those purposes have been fulfilled, your personal data will be permanently erased, unless any such erasure is prohibited under any law or it is in the public interest not to have the data erased. For the avoidance of doubt, data may be retained research and/or statistical purposes which is in the public interest and/or data may be anonymised for such purposes.

Use of cookies

We may use “cookies” on our Platform. A cookie is a small text file that is placed on your computer by a web server that can later be retrieved by a web server in the domain that issued the cookie to you. Cookies may be used to store your preferences and other information on your device in order to save your time by eliminating the need to repeatedly enter the same information and to display your personalized content and appropriate advertising on your later visits to these websites and/or applications. Cookies cannot be used to run programmes or deliver viruses to your device.

Analytical/performance cookies may be used to help us improve our Platform by tracking your visits to our Platform and recognising your web browser when you are a repeat visitor so that we can gather statistics on new and repeat visitors to evaluate site effectiveness.

The above cookies may be placed on your device by us or by third parties on our behalf, such as Google.

Most web browsers automatically accept cookies, but you may refuse to accept cookies by modifying your browser setting on your computer system. If you choose to decline cookies, you may be unable to sign in to our servers to use the services of our portal or unable to use other interactive features of our Platform.

Security

We will take all practicable steps to ensure that your personal data will not be subject to unauthorized access. In particular, access to your personal data will only be restricted to employees who have a need to use the data and who have been trained to handle such data properly and observe confidentiality.

Encryption technology may also be employed for the transmission of personal data collected on our Platform.

If you believe you have discovered a potential security vulnerability in any digital asset owned, operated, or maintained by Sow Fertility Limited or a circumstance that could reasonably impact the security of Sow Fertility Limited or our users, we encourage you to report this right away. We require you to report this to us before engaging in investigations that may be inconsistent with or not addressed by this policy. If in doubt, ask us before engaging in any specific action you think may go outside the bounds of this policy. We will investigate all legitimate reports and fix the problem as soon as we can. You may report potential security vulnerabilities to us by sending an email to hello@sowfertility.com. Please provide all known information related to the suspected security vulnerability you are reporting. Upon submission, we will acknowledge receipt of each vulnerability report, conduct a thorough investigation, and then take appropriate action for resolution, if any.

Links to Third Party Tools

Our Platform may contain links to other Third Party Tools. However, once you have used these links to leave our Platform, you should note that we do not have any control over that other Third Party Tool and cannot be responsible for the protection and privacy of any information which you provide whilst visiting such Third Party Tool. Please note that Sow Fertility Limited is not affiliated with, nor does it sponsor or endorse, any linking Third Party Tool owned by third parties and it does not endorse any product or service offered by such linking Third Party Tools. This privacy policy statement only applies to our Platform. Other Third Party Tools are not covered by this privacy policy and you are advised to refer to the privacy policy of the respective Third Party Tool. 

Contact us

You have the right to request access to and correction of your personal data held by us.

Requests for access to or correction of your personal data or for information in relation to our privacy policy and practices should be addressed to:

Sow Fertility Limited
Room 1505, 15/F, Yu Sung Boon Building
107-111 Des Voeux Road, Central
Hong Kong

In accordance with the Ordinance, we are entitled to charge a reasonable fee for processing any data access request.

You may also correct or update certain personal data by updating your profile on the relevant page(s) of this Platform where we have specified.

If you do not wish to receive information from us you may choose to opt out from our communications. You may contact us at hello@sowfertility.com.

IMPORTANT: By visiting our Platform, you agree to the terms set out above.

Note: This Privacy Policy may be amended by us from time to time and we will post the updated Privacy Policy on this page.

Appendix

Sow Fertility Limited. Personal Information Collection Statement (“PICS”)

Sow Fertility Limited recognises its responsibilities in relation to the collection, holding, processing and use of personal data. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by Sow Fertility Limited is secure and accurate and to avoid unauthorised or accidental access, erasure or other use.  The personal data that Sow Fertility Limited may collect from time to time includes:

• Identifiers, such as your name, home and work address, phone number, email address, username and password, employee or member identification number, policy or plan number, and IP address.
• Health information, such as you or your dependents’ wellness background, weight, height, lifestyle, medical history, medical condition, genetic information, healthcare providers, your reason for visiting a healthcare provider, date of visit, images or videos, diagnoses, treatment plans, laboratory results, payment data, insurance information, claims data, and information about your health and/or disability status, including pregnancy information.
• Demographic information, such as age, date of birth, sex, gender, national origin, citizenship, race, marital status, sexual orientation, medical condition, genetic information, and information about your health and/or disability status, including pregnancy information.
• Usage information, such as information about your usage of our platform or the Services.
• Device and electronic network activity information, including information from devices you use to connect to our Services, such as your mobile device. The information we receive from these devices may include browsing IP address, physical location including Global Position System (“GPS”) data, unique device identifiers such as MAC address, usage information, crash data, device performance characteristics and hardware information, battery status, WiFi network information, browsing history, search history, clickstream patterns, session information, browser and operating system type, navigation paths, date/time stamps, cookie identifiers, language preferences, profile or user information associated with your social media account, and other information about how you interact with our platform.
• Professional information, such as employer details and contact information, office location, and other details.
• Transaction information, such as claims information, information about payment methods, and related financial information.
• Information you submit to us and/or a practitioner via our service while communicating with our care team or practitioner network.

We collect personal data directly from you, and from other sources. Depending on how you use our services, we may collect information via the following means:

• Directly from you. We may collect personal data directly from you through your use of our services, completion of registration, feedback, or offboarding forms, account creation, practitioner/coaching visits, communications with Sow Fertility Limited, content that you post on the services, or your engagement on social media platforms.
• Directly from your device. We may collect personal data directly from your device using automated technologies. For example, when you access our website we automatically collect your device IP (Internet protocol) address and other information about your device including your browser type, operating system, and information about cookies that may be located on your device.
• From third parties (including your employer, health plan, Partner Providers and Third Party Toos (for example, receiving certain information from AI assistant transcription tools used to record video/audio appointments with practitioners)). We may receive your personal data from third parties, such as your employer, health plan, Partner Providers, Third Party Tools, and from family members and personal representatives who are registered with or interact with Sow Fertility Limited. If you are interacting with our Platform as a potential business customer of Sow Fertility Limited, we may supplement your personal data with information we receive from marketing partners and social media companies that we use to market our services to our business customers. We may combine this information with the information we collect about you to help us tailor our communications and improve our services.

The uses for which data may be collected include: 

1. To provide our services, connect you with practitioners and coaches, refer you to clinic partners, process payments, reimbursements, and claims, communicate with your employer, group health plan, or insurer to verify eligibility for our services, coordinate care, administer your health benefits, provide you access to our resources through the Platform, enrolling you in programmes and groups or other events, and respond to your questions and comments.

2. Sending communications including newsletters, information about programmes, education materials, groups, events and other activities delivered by Sow Fertility Limited or other agencies in conjunction with Sow Fertility Limited.

3. To improve our services, perform market research and analysis, assess how our services are being used, and develop new services.

4. To improve our services, understanding of the Sow Fertility Limited website traffic, perform market research and analysis, assess how our services are being used, and develop new services.

5. To maintain the security and integrity of our services, detect potential security vulnerabilities and incidents, protect our services against fraudulent and illegal activity, and enforce our Terms of Use.

6. For research and development. We may de-identify, pseudonymize, or anonymize your personal data by removing certain identifiable data points (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through other means. We do this so that, where permitted by law, we can conduct research (for example exploring how to improve clinical outcomes) and develop our products and services.

7. To comply with our legal obligations, including maintaining records of our compliance with law requirements, and responding to court orders. We may also use your personal data to establish, exercise, or defend legal claims.

We may share your personal data with third parties as described herein:

1. Your representatives, advisers and others you have authorised to interact with us on your behalf.

2. Our staff members who need the information to discharge their duties.

3. Our affiliates within the same corporate group, third-party partners and/or business affiliates.

4. Our agents and service providers that assist us in operating the Platform, providing services to you, or otherwise conducting our business.

5. Competent court of law, law enforcement agencies and/or regulatory bodies for compliance with applicable laws and regulations and protection of our legal rights.

6. Sow Fertility Limited Platform may use cookies with third-party software.

7. Practitioners. When you choose to engage with a clinical or wellness professional or facility offering their services via our services, we may share your personal data with them so that they may provide virtual consultations to you.

8. Your employer or health plan. If you access our services through a programme offered by your employer or health plan we may share certain personal data with your employer or health plan. In certain circumstances, when permissible under applicable laws, your employer or group health plan may ask that we share certain personal data with a third party designated provider to use for their own purposes, such as cost analysis and understanding care outcomes or providing incentives. We may also share your personal data with your employer, group health plan, or insurer.