This policy explains how China Medical Guides ("CMG", "we", "us") handles personal data when you use chinamedicalguides.com, contact us, or engage our coordination service. It sits alongside our terms of service and our medical disclaimer. If anything here is unclear, ask us before you send your records.
1. Who is responsible for your data
China Medical Guides is the data user (controller) for the information described in this policy. Our registered office is Suite 1203, 12/F, Tower 1, Admiralty Centre, 18 Harcourt Road, Hong Kong, and the person accountable is our Data Protection Officer at hello@chinamedicalguides.com. We handle personal data in line with the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region, and we apply the stricter standards of your own jurisdiction — for example the GDPR or UK GDPR — where they apply to you.
2. What we collect
2.1 Medical records and health information
Whatever you choose to send: diagnoses, clinical summaries, discharge letters, imaging and radiology reports, laboratory and pathology results, medication lists, allergies, operation notes and, where relevant, genetic or molecular results. We also keep the notes our coordinators write while arranging your care and the questions and answers exchanged with hospitals. This is special-category data, and we treat it as such.
2.2 Contact and identity details
Names, email addresses, telephone and WhatsApp numbers, country of residence, passport nationality, preferred language, and the details of any companion travelling with you. If you write on behalf of a patient, we record your relationship to them and your authority to act.
2.3 Coordination, travel and logistics details
Treatment preferences, hospital and department choices, your budget band, expected travel dates, appointment times, hotel and transfer bookings, and the correspondence between you, us and the hospital.
2.4 Payment metadata
Amounts paid, dates, currency, invoice references and the last four digits of a card where a processor passes them back to us. We do not store full card numbers; card payments are handled by a regulated payment provider on its own infrastructure.
2.5 Website data
Our servers keep standard access logs — IP address, browser type, pages requested, timestamps — for security and troubleshooting. We run no advertising trackers, we do not sell data, and we do not build behavioural profiles of visitors.
3. Our lawful basis for processing
We rely on different bases for different activities, and we say which applies when we ask for something:
- Consent — for sharing your records with a hospital, and for marketing email. You can withdraw consent at any time; that stops the processing but does not undo what was lawfully done before.
- Steps towards a contract, and performance of it — to review your case, obtain a hospital proposal and deliver the coordination you have asked for.
- Explicit consent for health data — because medical information needs a higher threshold than ordinary personal data.
- Legal obligation — for tax, accounting and anti-fraud records, and to answer a lawful request from a regulator or court.
- Legitimate interests — to secure our systems, prevent misuse and improve our own service, balanced against your rights and never used to override them.
We do not use your medical information for advertising, and we do not use it to train any profiling system. No automated decision produces legal or similarly significant effects for you.
4. How medical records are shared
Only with hospitals you approve. Concretely:
- We prepare a file for a named hospital or department, and we name it to you before anything is sent.
- Nothing goes to a second hospital, an insurer, an employer or a family member without your separate written instruction — except where a companion you have nominated already acts with your authority.
- A translation vendor, where one is used, works under a written confidentiality and data-processing agreement, receives only the document it must translate, and deletes it afterwards.
- Payment providers, accountants and lawyers see billing information, not medical records.
- We may disclose information where the law requires it, and we will tell you unless the law forbids us to.
Once a hospital receives your records it becomes responsible for them as its own controller, under its own notices and the law of mainland China. We choose hospitals with a dedicated international department and a documented records practice, but we cannot control what happens inside their systems.
5. International transfers
Records you send us are the subject of a deliberate transfer. Our coordination desk and case files are based in the Hong Kong Special Administrative Region; treatment means transferring your file to a hospital in mainland China. Our email, cloud storage and backup providers may process data in Hong Kong, Singapore or the European Union, and we choose providers that offer contractual transfer safeguards and encryption.
Where data moves from the European Economic Area or the United Kingdom, we rely on the appropriate transfer mechanisms and on your explicit consent for health data. By sending us records after reading this policy, you consent to those transfers for the purpose of obtaining a clinical opinion and arranging treatment. You may ask us to send records by encrypted link rather than email.
6. How long we keep things
- Enquiries that do not proceed: deleted 12 months after the last contact, unless you ask us to keep them for a future decision.
- Medical records and imaging: kept for 24 months after your trip ends, so we can answer follow-up questions and brief your own doctor, then deleted. You receive your own complete copy before you fly home.
- Coordination and billing records: kept for seven years after the engagement ends, for tax, accounting and limitation purposes. Clinical attachments are stripped out before archiving.
- Marketing preferences: kept until you unsubscribe, plus a suppression record so that we do not contact you again by mistake.
- Website access logs: kept for 90 days.
You can ask us to delete your records sooner at any time. If the law requires us to keep a specific record, we will tell you which one and for how long.
7. Your rights
Subject to the law that applies to you, you have the right to:
- Access the personal data we hold about you, and receive a copy within 30 days.
- Correct anything inaccurate, incomplete or out of date. We correct a hospital's clinical document only by adding your statement to the file, since we cannot alter it.
- Delete your records, where we are not required to keep them for a legal reason.
- Restrict or object to processing, including to marketing at any time.
- Portability — receive your file in a structured, commonly used format (PDF and JSON), and have it sent to another provider where technically feasible.
- Withdraw consent for future sharing with hospitals, without affecting treatment at a hospital that already holds your file.
- Complain to us first, then to the Privacy Commissioner for Personal Data in Hong Kong or the supervisory authority in your own country.
To exercise any of these rights, write to hello@chinamedicalguides.com. We respond within 30 days, we do not charge for a first request, and we may ask you to confirm your identity so that we do not release records to the wrong person.
8. Cookies and local storage on this site
This site is deliberately light. It sets no advertising or tracking cookies, and this build runs no third-party analytics.
- Language preference. If you choose a language from the switcher, we store it in your browser's local storage under the key
mbc-lang, so the choice survives a page reload. - Estimate list. If you add hospital price lines to an estimate on the cost pages, that list is stored in local storage under the key
mbc-estimate. It never leaves your browser unless you copy it yourself. - Typefaces. Pages load fonts from Google Fonts, so your browser contacts Google's servers and your IP address is visible to them. No cookie is set by that request.
Both local-storage items stay on your device until you clear your browser data, and you can delete them from your browser settings at any time. We never read them for marketing purposes.
9. Security
Records move over TLS, are encrypted at rest, and sit in a folder that only the coordinators assigned to your case can open. Staff use multi-factor authentication, access is logged, and permissions are reviewed quarterly. Files go to hospitals by encrypted link rather than plain attachment wherever the hospital can accept one. No system is perfect: if you believe your information has been exposed, tell us at hello@chinamedicalguides.com and we will investigate, contain the problem and notify you and any regulator as the law requires.
10. Contact the Data Protection Officer
Write to the Data Protection Officer at hello@chinamedicalguides.com, marking the subject line "For the DPO", or by post to Suite 1203, 12/F, Tower 1, Admiralty Centre, 18 Harcourt Road, Hong Kong. For anything urgent, including a suspected data breach, call +852 3500 0000 and ask for the Data Protection Officer.
11. Changes to this policy
We review this policy at least annually and whenever our processing changes. The version in force is the one published here when you send us data, and the "last updated" date above shows the current version. Where a change materially affects records we already hold, we email you before it takes effect.