Privacy Policy

Last Updated: February 6, 2025

Protecting your privacy is of great importance to MedEx Technology Co., Ltd. and its affiliates (collectively, "the Company"). Accordingly, the Company has established this Privacy Policy ("this Policy") to explain how the Company collects, processes, and uses your personal data in the "Holo Wellness" app ("this App") and related websites/services ("this Service"). Please read and understand this Policy carefully. By starting to use this Service or checking your consent, you indicate that you have read, understood, and agree to this Policy. If you are a minor, you and your legal representative should read and understand it; by starting to use or checking consent, you and your legal representative are deemed to have read, understood, and agreed to this Policy.

If you do not agree to all or part of this Policy, the Company may be unable to provide you with this App’s related services in many circumstances, or to respond to your inquiries. In such case, please stop using this App.

1. Data and Purposes of Collection, Processing and Use

(1) Data or information you provide

refers to the following data or information that can identify an individual (as detailed under the "Specific Purposes and Categories of Personal Data under the Personal Data Protection Act" announced by the competent authority; codes and items shall be updated in accordance with any subsequent announcements):

1. Basic information: C001–C003 identification (e.g. name, national ID number, contact address, phone number, email); C011–C012 characteristics (e.g. gender, date of birth, blood type, height, weight); C038 social (e.g. occupation);

2. Health: C066 health and safety records (e.g. occupational disease, accident records); C111 health records (e.g. medical reports, treatment and diagnosis records, test results, type and level of disability, validity period, disability ID, contact person, various measurements such as exercise and rehabilitation).

(2) Scope of specific purposes

Subject to this Policy and applicable laws, the Company collects, processes, and uses all data or information you provide within the following specific purposes (as detailed under the competent authority’s announced categories; codes and items shall be updated accordingly), and you agree to authorize the Company for the provision and improvement of this App’s services, including but not limited to combining other information (e.g. the Company’s products, services, marketing notices):

  • 1. Marketing: 040 Marketing; 152 Advertising or commercial conduct management
  • 2. Billing, audit and operations: 069 Contract and similar matters; 090 Consumer/customer management and service; 095 Tax administration; 104 Account management; 150 Auxiliary and logistics management
  • 3. Fraud prevention and system security: 025 Crime prevention, criminal investigation, etc.; 137 Information and communications security and management
  • 4. Data analysis and product optimization: 135 Information services; 136 Information and database management; 157 Survey, statistics and research; 159 Academic research
  • 5. Healthcare and health strategy: 064 Healthcare services; 182 Other consulting and advisory services

(3) Due to the health-service nature of this App, the Company must collect your personal data to develop and optimize system services, analyze personal health data to provide personalized health assessments and recommendations, and to ensure the accuracy of this App’s related services and content.

(4) When you use this App, this App will, as necessary for providing related services, automatically collect, process, and use activity information relating to you, including but not limited to search and query records on this App and services or products used or purchased, to better understand the systems, products and/or services you care about and to ensure the accuracy of this App’s related content.

(5) The Company may from time to time use your personal data to send you various notices related to this App’s services (including but not limited to changes to terms of use, consumption conditions and other policies, latest service announcements, software updates, and upcoming events) to improve your experience with this App.

2. Protection of Personal Data

(1) Your personal data is stored in full in the Company’s data storage systems and protected by strict measures against unauthorized access. Any personnel who breach confidentiality obligations will be subject to relevant laws and internal Company discipline.

(2) To protect the integrity and security of your personal data, the systems that store your personal data are equipped with information security measures and necessary safeguards so that your personal data is not improperly obtained or compromised. Where the Company engages third parties to provide services, it will require them to comply with confidentiality obligations and will take necessary steps to ensure such compliance.

(3) You may exercise your rights under the Personal Data Protection Act to query, access, obtain copies, request supplementation or correction, and request cessation of collection, processing or use and deletion of your personal data. To protect the security of your personal data, please contact the Company’s customer service to submit an application and complete the required forms. The Company will process your request in accordance with the law, the Company’s operating rules and service terms, and will handle it as soon as legally practicable under Articles 10, 11 and 13 of the Personal Data Protection Act.

(4) If you have special requests or become aware of any information security or personal data breach incident, please report it to the Company immediately (contact personnel or send an email to daisy.lin@holowellness.net). The Company will process or contact you as soon as possible after receipt.

3. Integrated Use

When you use this App, this App may record your personal data to provide you with a more convenient and personalized experience. For example, if the Company knows your name, it can offer you a personalized welcome on your next use; or when you complete questionnaires, redundant entries can be reduced. Consistent with most digital services, this App automatically collects certain information and stores it in log files, including IP address, browser type and language, ISP, referring and exit systems and applications, operating system, date/time stamps and click-through data. The Company uses this information to understand and analyze trends, manage systems, understand user behavior, assess focus on specific topics, measure communication effectiveness, and improve the Company’s products and services. This App may use such information for related activity notices, quick form and questionnaire filling, product and service notices, and choice of delivery method and timing.

4. Disclosure to Third Parties

You authorize the Company and the following third parties to view your information on this App:

(1) Affiliates: Affiliates means the Company, entities that directly or indirectly control the Company, and entities that are directly or indirectly controlled by the Company.

(2) Telecommunications operators: When you use telecommunications operator services through this App, you authorize this App and your operator to exchange the information you provide during the period of use to provide the services (e.g. payment mechanisms). Your account will be governed by the respective privacy policies and/or terms of service of this App and your operator. Personal data shared between this App and the operator is limited to providing or improving the Company’s products, services and matching suitable services for you, and will not be provided to the operator for marketing purposes unless otherwise stated in this Policy.

(3) Government authorities: Under applicable laws and legal process in your place of residence, government authorities may require this App to disclose your personal data. The Company may disclose your personal data when it determines it is necessary and appropriate for national security, legal requirements or other important public interests.

5. Period, Region and Recipients of Use of Personal Data

(1) Period: The Company and this App will continue to use the personal data you provide until you request cessation or this App ceases to provide the service.

(2) Region: Within and outside the territory of the Republic of China (excluding where prohibited by the competent authority).

(3) Recipients: The Company, this App, affiliates and partners entrusted or necessary to provide this Service within the necessary scope, and authorities with legal authority.

6. Right to Amend This Policy

This Policy may be amended as appropriate in response to social and technological developments, regulatory changes or other environmental changes to give effect to the protection of privacy. When this Policy is amended, the Company will notify you by posting the update on this App’s pages or by email for material changes. You should check for updates from time to time. Your continued use of this App after any change or amendment will be deemed acceptance of the revised Policy; if you do not agree to the revised Policy, please stop using this App immediately.

7. Company Reorganization, Merger or Sale

If the Company is reorganized, merged or sold, the Company may transfer the personal data it has collected to a third party that succeeds to the relevant rights and obligations. If you do not agree, you may exercise your rights in accordance with the Personal Data Protection Act.

8. Integrity and Retention of Information

Except as otherwise required by law or where you consent to a longer retention period, the Company will retain your personal data during the operation of this App and for the duration necessary for the purposes described in this Policy, so that your personal data remains accurate, complete and up to date.

9. Important Notice

Please keep your account and password secure to prevent others from collecting and using your personal data without consent. You are responsible for the account and password provided to this App. The Company shall not be liable for any damage arising from misuse or disclosure due to your failure to keep them secure.