Privacy Policy

Vantage Global Health (“Vantage”, “we”, “our” and “us”) operates the website and platform through which international patients can discover, compare and connect with accredited hospitals and medical specialists across China (the “Platform”). Our Platform is owned, operated and monitored by Vantage.

We are not a medical service provider, healthcare provider, healthcare insurance provider or healthcare agent, and we are not responsible for any of the healthcare services which are presented on, and made available via, our Platform (“Healthcare Services”). All such Healthcare Services are provided by accredited independent hospitals and clinics that are bound by our Healthcare Provider Terms and Conditions (“Healthcare Providers”).

In this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person, as set out in the applicable data protection and privacy laws and regulations of the jurisdictions in which we operate (“Data Protection Laws”).

We understand your privacy is important. We respect and value the privacy of everyone who visits the Platform, or shares data with Vantage, and we will only collect and use Personal Data, including special categories of personal data, in a manner that is consistent with our obligations and your rights under the law.

This document (“Privacy Policy”) describes:

We collect personal information from you in the ordinary course of our business, including through your use of our Platform and services, when you contact or request information from us, when you engage Healthcare Services, or as a result of your relationship with one or more of our staff, users, or affiliates.

The personal information that we process includes:

Where necessary, and with appropriate legal justification, we may also collect and process special categories of personal data (as defined under applicable Data Protection Laws). This can include information relating to your health, genetic or biometric data, or other sensitive information (“Special Category Personal Data”). For instance:

We only process this Special Category Personal Data where the law allows us to do so (see Legal grounds for processing below).

We collect Personal Data from you and others as necessary in the course of providing our services.

We gather information about you when you provide it to us via our Platform, or interact with us directly — for instance engaging with our staff or corresponding with us by phone, email or otherwise — or automatically when you visit our website (see our Cookies Policy).

We may obtain Special Category Personal Data about your physical or mental health, including but not limited to genetic or biometric information, from application forms, notes and reports about your health and any treatment and care you have received or need, notes from calls and other communications you have had with us, records of medical services and treatment you have received, or when you provide it to us via our Platform.

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purpose we collected it for, including for the purpose of satisfying any legal, regulatory or medical-record retention requirements.

We may share your Personal Data with certain trusted third parties in accordance with contractual arrangements in place with them, including:

Where necessary, or for the reasons set out in this Privacy Policy, Personal Data may also be shared with regulatory authorities, courts, tribunals, government agencies and law enforcement agencies. Whilst unlikely, we may be required to disclose your Personal Data to comply with legal or regulatory requirements. We will use reasonable endeavours to notify you before we do this, unless we are legally restricted from doing so.

We do not sell, rent or otherwise make Personal Data commercially available to any third party.

We use a variety of technical and organisational measures to help protect your Personal Data from unauthorised access, use, disclosure, alteration or destruction, consistent with applicable Data Protection Laws. Because our core activities involve processing health data, we apply heightened safeguards to that data and restrict access to those staff and partners who need it to coordinate your care.

Under applicable Data Protection Laws, we must ensure that each use of your Personal Data is supported by a lawful basis. In some cases, we process your Personal Data because it is necessary for a contract to which you are a party, or to take steps at your request before entering into a contract (for example, to arrange Healthcare Services). In other situations, we may process your Personal Data where it is necessary for our legitimate interests or those of a third party, provided that your interests and fundamental rights do not override those interests — for example administering and managing our services and ensuring network and information security.

We may also process your Personal Data where required for compliance with legal obligations (for instance under health, safety or other regulatory requirements). In certain circumstances, particularly where we handle Special Category Personal Data not covered by the above grounds, we rely on your explicit consent (for example, if we need to process specific health data). You have the right to withdraw this consent at any time.

We may also process Special Category Personal Data, such as health data, which enjoys enhanced protection under Data Protection Laws. In addition to relying on one of the lawful bases mentioned above, we must have an additional justification for processing these categories. Processing may be necessary for the provision of Healthcare Services, including medical diagnosis or the management of healthcare systems; for reasons of substantial public interest; or for establishing, exercising or defending legal claims. If none of these justifications apply, we will seek your explicit consent before processing these special categories of Personal Data.

We collect, process, hold and use Personal Data provided to us by or on behalf of our users or affiliates in the course of, and in connection with, the services we provide. In particular, we use your Personal Data to:

The minimum age to use our Platform is 18 years of age. We do not knowingly collect or use Personal Data from anyone under 18 years of age. If we learn that we have collected Personal Data from anyone under 18 years of age, the personal data will be deleted as soon as possible. If a child under 18 years of age has provided us with Personal Data, their parent or guardian may contact us.

In order to provide our services, we may need to transfer your Personal Data to locations outside the jurisdiction in which you provide it or where you are viewing the Platform, for the purposes set out in this Privacy Policy. Because our Healthcare Providers are based in China, coordinating your treatment will generally involve transferring relevant Personal Data (including health data) to China.

The level of information protection in countries outside your own may be less than that offered within it. Where this is the case, we will implement appropriate measures to ensure that your Personal Data remains protected and secure in accordance with applicable Data Protection Laws.

The main safeguards we use are:

Applicable Data Protection Laws provide certain rights for data subjects. We would like to make sure you are fully aware of all of your rights. Every user has the following rights:

You are entitled to request details of the data we hold about you and how we process it. You may also have a right, in accordance with applicable Data Protection Laws, to have it rectified or deleted, to restrict our processing of that data, to stop unauthorised transfers of your Personal Data to a third party and, in some circumstances, to have Personal Data relating to you transferred to another organisation.

If you object to the processing of your Personal Data, or if you have provided your consent to processing and you later choose to withdraw it, we will respect that choice in accordance with our legal obligations. Your objection (or withdrawal of any previously given consent) could mean that we are unable to perform the actions necessary to achieve the purposes set out above, or that you may not be able to make use of the services and products offered by us. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or otherwise permitted by law, in particular in connection with exercising and defending our legal rights or meeting our legal and regulatory obligations.

If you have any concerns about our use of your Personal Data, you can make a complaint to us at the contact details at the end of this Privacy Policy. Subject to legal and other permissible considerations, we will make every reasonable effort to honour your request promptly, or inform you if we require further information in order to fulfil your request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled or required to deal with the request in a different way.

If you remain unhappy with how we have used your Personal Data after raising a complaint with us, you may also have the right to complain to the data protection supervisory authority in your jurisdiction.

We must ensure that your Personal Data is accurate and up to date, therefore please advise us immediately of any material changes to the information we hold.

In addition, if you have any questions about the processing of your Personal Data or this Privacy Policy, please get in touch with our privacy team using the details on our Contact Us page.