Lulusmiles Limited (hereinafter collectively referred to as “Lulusmiles”, “we”, “us” or “our”) is committed to protecting your privacy. We undertake to properly manage, protect and process your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”).
This Privacy Policy applies to our website (www.lulusmiles.com and its subdomains), mobile applications, social media channels, and any other platforms or services that link to this Policy (collectively, the “Services”). By accessing or using our Services, you indicate that you have read, understood and agree to the terms of this Privacy Policy and the manner in which we collect, use and disclose your personal data. If you do not agree, please do not use our Services or provide us with any personal data.
Personal Data We Collect
We may collect the following categories of personal data, including but not limited to:
- Identity and contact information (e.g., name, age, email address, phone number, postal address, date of birth)
- Health and dental information (e.g., dental records, photographs, 3D scans, treatment history and other medical-related data)
- Payment information (processed through secure third-party payment platforms)
- Device and usage information (e.g., IP address, browser type, device identifier, browsing history)
- Communication records (e.g., enquiries, feedback, appointment records)
We collect data directly from you (e.g., when you register an account, submit enquiries, make appointments or upload photos/scans), or from third parties (e.g., partnering dentists or service providers).
We do not intentionally collect personal data from persons under the age of 18. If you are under 18, please use the Services only with the consent of a parent or guardian.
Purposes of Collection and Use
We collect and use your personal data primarily for the following purposes (including any directly related purposes):
- Providing and managing dental alignment and smile-related services (e.g., treatment assessment, plan formulation, product delivery and follow-up)
- Processing appointments, orders and payments
- Communicate with you (e.g., service confirmations, updates, customer support and security notifications)
- Where we have obtained your consent (or you have not indicated objection) during your first purchase of services, for displaying relevant content and advertising, market research, marketing, promotion and publicity purposes.
- Improving the Services, conducting internal research and analysis
- Complying with legal obligations or corporate restructuring needs
Disclosure and Transfer of Personal Data
We may disclose or transfer personal data to:
- Our affiliated companies and related entities
- Third-party service providers (e.g., dental professionals, laboratories, payment processors, IT and cloud service providers)
- Professional advisors, regulatory bodies or law enforcement agencies (when required by law)
Data may be transferred outside Hong Kong. We will take all practicable steps to ensure that recipients provide a comparable level of data protection, and that your personal data continues to be protected in accordance with the PDPO and this Policy. By using the Services, you consent to such transfers.
Data Security and Retention
We implement reasonable technical and organisational measures to protect personal data against unauthorised access, loss or misuse. We retain data only for as long as necessary to fulfil the collection purposes or as required by law. When no longer required, we will securely delete or anonymise it.
Cookies and Tracking Technologies
Our Services use cookies and other tracking technologies to enhance user experience and analyse usage. You may adjust cookie settings in your browser, but this may affect Service functionality.
Third-Party Links
The Services may contain links to third-party websites. We are not responsible for their privacy practices.
Your Rights
- Request access to the personal data we hold about you (we may require identity verification and charge a reasonable fee).
- Request correction of inaccurate personal data (we may require identity verification and charge a reasonable fee).
- Withdraw consent for specific uses of your personal data, or request that we cease collecting, using or disclosing your data. Please note that if the withdrawal or cessation involves data necessary for providing the Services, we may be unable to continue offering the relevant Services.
Please exercise these rights by emailing info@lulusmiles.com in writing. We will process your request within a reasonable time.
Changes to this Policy
We may update this Policy from time to time. The latest version will be posted on our website.
CONTACT
For any enquiries, please contact info@lulusmiles.com.