PRIVACY POLICY FOR TOP EMINENT HEALTHCARE GROUP LIMITED

Top Eminent Healthcare Group Limited (“Top Eminent Healthcare”) may from time to time collect personal information from shareholders that are natural persons and/or individual as part of Top Eminent Healthcare operation of as a listed company. Given that Top Eminent Healthcare is incorporated under the laws of the Cayman Islands and is registered as a non- Hong Kong company under Part 16 of the Companies Ordinance, Top Eminent Healthcare is also subject to both the Cayman Islands Data Protection Law, 2017 and Chapter 486 Personal Data (Privacy) Ordinance of Hong Kong.

Protecting your privacy is important to us. We ask that you read this privacy policy carefully as it contains important information about what to expect when we collect personal data about you and how we will use your personal data. Your provision of personal data is voluntary.

However, if you do not provide us with your personal data, we may not be able to provide you with the services and products requested.

Personal Data collected

If you are a shareholder and are a natural persons/ individuals, we may collect the following personal data from you –

· name, address, contact details such as phone number and email address or other similar data.

We may also collect this information if you are a natural person/individual connected with the shareholder, such as the ultimate beneficial owner or representative of the shareholder.

Apart from personal data, we may collect other types of information which is not linked to an individual and which is anonymous. For example, the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our customer services.

Purpose for Collection and Use of Personal Data

The personal data collected will be used generally for the following purposes:

1. to maintain various statutory registers relating to shareholders;

2. conducting identity checks;

3. should the company undergo corporate action or part or all of our business is acquired by a third party and shareholders information is required to be provided in association with the restructure and acquisition;

4. in connection with any verification of information;

5. complying with any present or future requirements or commitment (whether statutory, contractual or otherwise) of any legal, regulatory, governmental, tax, law enforcement or authorities;

6. enforcing our legal and/or contractual rights against you; and

7. all other incidental and associated purposes relating to the above and any other purpose which a customer may from time to time agree.

Disclosure of Personal Data

We may disclose your personal data to other group companies of Top Eminent Healthcare Group, third party service providers (including those providing administrative, telecommunications, computer, financial intermediary, payment or securities clearing or other services to Top Eminent Healthcare in connection with the operation of its business), financial institutions with which you have or propose to have dealings, any actual or proposed assignee of Top Eminent Healthcare or participant or sub-participant or transferee of Top Eminent Healthcare’s rights in respect of the customer, any potential investor in or purchaser of any interest in any group companies of Top Eminent Healthcare Group or in its business in connection with any potential reorganisation, merger or disposal, credit reference agencies, debt collection agencies, charity or charitable organisation, our professional advisers and agents and legal, regulatory, governmental, tax, law enforcement or other authorities pf applicable jurisdictions for the purposes stated above.

In addition, there are certain circumstances under applicable laws where we are permitted to collect, use and disclose your personal data without your consent. You may obtain more information by contacting us.

We will not sell, rent or otherwise disclose your personal data to any third party not referred to above without your consent except in the following circumstances:

1. we may share non-personal, non-individual information in aggregate form with third parties for business purposes, for example, we may tell our business partners the number of customers in certain demographic groups who purchased certain products or who carried out certain transactions.

2. as permitted under the laws of the applicable jurisdiction.

“Top Eminent Healthcare Group” means for the purpose of this privacy policy, any entity controlled, directly or indirectly by Top Eminent Healthcare, any entity that controls, directly or indirectly Top Eminent Healthcare or any entity directly or indirectly under common control with Top Eminent Healthcare. For this purpose, “control” of any entity or person means ownership of a majority of the voting power of the entity or person.

Transfer Of Personal Data Overseas

To the extent that we may need to transfer personal data outside of an applicable jurisdiction, whether to the permissible parties set out above or simply to data storage facilities, we shall do so in accordance with the obligations required under the applicable laws of such applicable jurisdiction.

Consent

In some circumstances and as required by applicable laws, we will seek your express consent when collecting your personal data. For example, we will seek your consent where there are new purposes for the use of your personal data or where we use and transfer your personal data for direct marketing purposes. In addition, you are able to withdraw your consent at any time by contacting us.

Use and Transfer of Personal Data in Direct Marketing

Where in circumstances where we may share your personal data with any other companies within the group companies of Top Eminent Healthcare Group or our business partners who provide the same products and services for direct marketing purposes. Your consent is required before we do so.

Access And Correction And Your Rights

You are entitled to certain access and correction rights to your personal data under the applicable laws. In exceptional circumstances, we reserve the right to deny you access to your personal data and may provide an explanation as required under applicable laws.

You also have the right to:

· be informed about the purposes for which your personal data are processed;

· restrict the processing of your personal data;

· have incomplete or inaccurate personal data corrected;

· ask us to stop processing your personal data;

· be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you);

· complain to the Cayman Islands Data Protection Ombudsman; and

· require us to delete your personal data in some limited circumstances.

Retention

Personal data will be held for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to conclude that the purpose for which that personal data was collected is no longer being served by retention of the personal data and retention is no longer necessary for legal or business purposes.

Accuracy

In order to ensure that your personal data is current, complete and accurate, please update us by contacting us.

Security Safeguards

We have put in place adequate security procedures and technical and organisational measures to safeguard your personal data. We will use all reasonable efforts to safeguard your personal data. However, you should be aware that the use of the internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the internet.

Updates To The Privacy Policy

We keep our privacy policy under regular review. If we change our privacy policy, we will post the changes on our website. Such changes to our privacy policy shall apply from the time that we post the same on this website. We will seek your fresh consent if we wish to use or disclose your personal data for new purposes.

Cookies

A cookie is an alphanumeric identifier which we transfer to your hard drive through your web browser when you visit our website. It enables our own system to recognise you when you visit our website again and improve our service to you. The information is used to track visitor use of the website and to compile statistical reports on website activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. Cookies may also be used to compile aggregate information about areas of our website that are visited most frequently. This traffic information can be used to enhance the content of our website and make your use of it easier. If you wish to reject our cookie, you can configure your browser to do so. However, in a few cases some of our website features may not function if you remove cookies from your browser.

Contact Us

If you any comments or questions about this Privacy Policy, please contact us in writing at the address below referencing ‘Privacy Policy’:

Address: Suite 5406, 54/F., Central Plaza, 18 Harbour Road, Wanchai, Hong Kong

Email: info@tehealth.com

Tel: +852 2151 5799

Disclaimer

Top Eminent Healthcare website may contain links to other websites. Please note that Top Eminent Healthcare is not responsible for the privacy practices of such other websites and you are advised to read the privacy statement of each website you visit which may collect your personal data.