1. Overview

SmartClinic AI HK Limited ("the Company", "we", "us") provides a WhatsApp AI assistant service ("the Service") to private medical clinics in Hong Kong. This Privacy Policy explains how we collect, use, store and protect personal data involved in delivering the Service, including data relating to patients and clinic staff.

The Service is introduced by clinics for their patients' optional use. By contacting a clinic via WhatsApp through the Service, a patient is taken to accept that their data will be handled in accordance with this Policy. If you have any questions about how your data is handled, please contact us using the details below.

2. Data We Collect

Through the WhatsApp Business Platform (provided by Meta), we help clinics collect the following data:

• Patient's WhatsApp phone number
• Content of messages sent by the patient (text, images such as insurance cards)
• Appointment-related details (name, appointment date and time)
• Activity logs from clinic staff using the administrative dashboard

3. How We Use Data

Data is used, on the clinic's instruction, solely for the following purposes:

• Processing and confirming patient appointments
• Providing queue management functionality
• Sending follow-up, vaccination or other reminders requested by the clinic (patients may opt out at any time by replying "STOP")
• Assisting clinic staff in responding to patient enquiries, including manual takeover of conversations
• Service usage statistics and platform improvement

We do not use patient data for promotional or advertising purposes unrelated to the above.

4. Data Storage and Security

Data is stored on cloud infrastructure (Google Cloud Platform) and protected using encrypted transmission (TLS/SSL). We continuously improve our security measures to help keep your data safe.

Data is generally retained for up to 90 days after a clinic stops using the Service, after which it is scheduled for deletion, except where longer retention is required by law. Individual clinics may request adjusted retention arrangements suited to their needs.

5. Third-Party Services

Delivering the Service involves the following third-party providers, each processing data under its own privacy policy:

• Meta Platforms, Inc. — WhatsApp Business Platform, for sending and receiving messages
• Google Cloud Platform — server infrastructure and AI language processing (Vertex AI)
• Google Workspace — storage of appointment and conversation records (Google Sheets)

We select providers with regard to their security standards and industry reputation.

6. Data Sharing

We do not sell or rent patient personal data. Data may be accessed or disclosed in the following circumstances:

• To comply with applicable law, court orders, or lawful requests from government authorities
• To protect the legitimate interests of the Company, a clinic, or other persons (e.g. preventing misuse of the Service)
• On the instruction of the clinic, which remains primarily responsible for the data collected through its use of the Service

7. Patient Rights

Under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486), patients generally have the right to:

• Request access, via the relevant clinic, to personal data we hold about them
• Request correction of inaccurate personal data
• Request deletion of their personal data, subject to legally required retention periods
• Opt out of automated reminders at any time by replying "STOP"

We recommend contacting the clinic providing your care in the first instance, or reaching us directly using the details below; we will do our best to assist.

8. Regulatory Reference

The Service has been designed with reference to:

• Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486)
• Meta's WhatsApp Business Platform policies, including its Business Policy

This Policy describes our general practices and does not constitute legal advice. Clinics remain responsible for ensuring their own use of the Service complies with their professional and regulatory obligations.

9. Changes to This Policy

We may update this Policy from time to time to reflect changes in law, technology, or our business. Material changes will be announced on this website, and the "Last updated" date above will be revised accordingly. Please check back periodically for the latest version.

10. Contact Us