Privacy Policy

1. Information We Collect

The information we collect may vary depending on the services you use.

1.1 Personal and Contact Information

This may include:

• Name;
• Country or region;
• Email address;
• Telephone number;
• WhatsApp contact information;
• WeChat contact information;
• Other contact details you choose to provide.

We primarily use this information to identify and manage your service request and to communicate with you.

1.2 Medical and Health Information

When you request a Free Assessment, China Treatment Opportunity Review, Second Opinion, Plan Your Care in China, Medical Navigation, or another related service, we may collect medical information that you voluntarily provide, including but not limited to:

• Medical conditions or diagnoses;
• Symptoms and current health status;
• Pathology reports;
• Imaging reports;
• Laboratory test results;
• Genetic or molecular test results;
• Previous treatment records;
• Current treatment plans;
• Medication information;
• Allergies;
• Surgical records;
• Hospital discharge records;
• Medical opinions from doctors;
• Medical imaging files;
• Other information related to your condition and healthcare needs.

Health and medical information is generally considered sensitive personal information. We collect and process this information only when reasonably necessary to provide the services you request.

1.3 Documents and Content You Submit

You may provide information to us through our website, email, messaging platforms, or other communication channels, including:

• Medical records;
• PDFs, images, and scanned documents;
• Medical imaging;
• Identity or travel-related documents;
• Information entered into forms;
• Questions you submit to us;
• Records of your communications with us.

1.4 Service and Transaction Information

When you purchase a paid service, we may collect information such as:

• The service you purchased;
• Order and payment status;
• Transaction date and time;
• Invoice or billing information;
• Information relating to refunds or customer support.

We may use third-party payment providers to process payments.

Unless otherwise stated for a particular service, we generally do not directly store complete payment card numbers, card security codes, or other full payment credentials. Such information may be processed directly by third-party payment providers.

1.5 Website Usage and Technical Information

When you visit our website, certain technical and usage information may be collected automatically, such as:

• IP address;
• Browser type;
• Device type;
• Operating system;
• Date and time of access;
• Pages visited;
• Referring pages or sources;
• Website usage activity;
• Information generated through cookies or similar technologies;
• Log file information, such as HTTP status codes and clickstream data.

We primarily use this information to operate and secure the website, analyze usage, troubleshoot technical issues, and improve the user experience.

2. How We Collect Information

We may collect information when:

• You complete a form on our website;
• You upload medical records or other documents;
• You purchase or request one of our services;
• You contact us by email, WhatsApp, WeChat, or another communication channel;
• You participate in an online consultation, second opinion, or other service;
• A hospital, doctor, or other healthcare provider provides information to us with your authorization;
• Information is collected automatically through cookies, analytics tools, or similar technologies;
• An authorized family member, caregiver, or representative submits information on your behalf.

If you provide information on behalf of a patient, you should ensure that you have the appropriate authorization or are otherwise legally permitted to provide that information on the patient’s behalf.

3. How We Use Your Information

We may use the information we collect for the following purposes.

3.1 Providing the Services You Request

This may include:

• Processing a Free Assessment;
• Completing a China Treatment Opportunity Review;
• Arranging a Written Second Opinion;
• Arranging a Video Second Opinion;
• Arranging a Multidisciplinary Second Opinion;
• Assisting with planning medical care in China;
• Helping you connect with hospitals and doctors in China;
• Coordinating appointments, consultations, hospital admission, and treatment;
• Providing medical navigation and coordination support while you receive care in China;
• Supporting follow-up care and related communications.

3.2 Organizing and Processing Medical Information

We may process the information you provide by:

• Classifying records;
• Organizing documents;
• Formatting information;
• Translating materials;
• Preparing summaries;
• Checking whether records appear complete;
• Preparing materials for review by hospitals or doctors.

These activities are intended to improve the efficiency of medical communication and service coordination. They do not mean that China Medical Navigation independently makes a medical diagnosis or clinical decision.

3.3 Communicating With Hospitals and Doctors

Depending on the services you request, we may provide necessary personal and medical information to hospitals, doctors, or other healthcare providers for purposes such as:

• Determining whether a provider may accept your case;
• Allowing a provider to understand your medical situation;
• Providing a second opinion;
• Assessing potential eligibility for treatment;
• Preparing information on available medical services or treatment arrangements;
• Providing estimated costs or timelines;
• Coordinating online or in-person medical services.

3.4 Communicating With You

We may use the contact information you provide to:

• Respond to your inquiries;
• Provide service updates;
• Request additional information or records;
• Send assessment results or other service deliverables;
• Provide appointment and medical arrangement information;
• Handle payments, refunds, or service-related issues;
• Send communications directly related to services you are using.

3.5 Improving Our Services

We may use appropriately processed information to better understand:

• The medical topics and concerns users commonly seek help with;
• Which pages and services are most frequently used;
• Whether our website and forms are easy to use;
• How we can improve our service processes and patient experience.

Where reasonably practicable, we prefer to use de-identified, aggregated, or otherwise non-identifiable information for these purposes.

3.6 Website Security and Risk Management

We may process information as reasonably necessary to:

• Prevent fraud;
• Detect or prevent malicious activity;
• Maintain the security of our website and systems;
• Investigate technical problems;
• Protect the legitimate rights and interests of users, China Medical Navigation, and third parties.

3.7 Legal and Compliance Obligations

Where required by applicable law, we may retain, use, or disclose information to:

• Comply with legal obligations;
• Respond to lawful governmental, regulatory, or judicial requests;
• Address disputes or legal claims;
• Protect or enforce legal rights.

4. Medical Information and Sensitive Personal Information

Because our services involve healthcare, some of the information we process is highly sensitive.

We process medical and health information only to the extent reasonably necessary to provide the services you request, complete necessary medical coordination, or comply with applicable legal obligations.

We do not automatically use medical information you submit for advertising targeting unrelated to the healthcare services you request.

We do not sell patients’ personal medical information to advertisers.

Access Controls: Access to your medical information is limited to authorized personnel and service providers who need the information to perform relevant services.

Security Measures: We take reasonable technical and organizational measures to protect medical information during transmission and storage.

5. When We Share Your Information

We do not disclose your personal information publicly without reason.

To provide our services, we may share relevant information with the following categories of third parties where reasonably necessary.

5.1 Hospitals, Doctors, and Healthcare Providers

This is one of the primary circumstances in which we share information as part of our cross-border medical services.

For example, to determine whether a hospital may be suitable for your situation, we may need to provide that hospital with relevant portions of your medical records.

To arrange a Second Opinion, we may provide the participating doctor with your medical history, test results, and questions.

To arrange treatment in China, we may need to provide a hospital with more complete medical and identification information.

We generally seek to limit the information shared to what is reasonably necessary for the relevant healthcare service.

5.2 Medical and Service Support Providers

In some circumstances, we may work with third-party service providers that help us deliver our services, including:

• Medical translation providers;
• Medical record organization services;
• Technology service providers;
• File storage providers;
• Communications providers;
• Video conferencing services;
• Patient coordination providers;
• Other service providers reasonably necessary to fulfill your request.

These providers are generally permitted to process information only to the extent necessary to perform their respective services.

Where appropriate, we enter into data protection arrangements with service providers requiring them to implement appropriate safeguards and process information only in accordance with our instructions.

5.3 Payment Service Providers

When you purchase a paid service, payment information may be processed by third-party payment platforms, banks, or other payment service providers.

These providers may process payment-related information in accordance with their own privacy policies.

5.4 Legal Requirements

We may disclose information where required by applicable law or in response to a lawful request from a court, regulator, government agency, or other competent authority.

5.5 Protection of Legal Rights and Safety

Where permitted by law, we may disclose information if we reasonably believe it is necessary to protect the safety, property, or legal rights of users, China Medical Navigation, healthcare providers, or other third parties.

6. International Data Transfers

China Medical Navigation provides cross-border medical services to international patients.

As a result, your personal information and medical records may need to be transferred, stored, or processed in countries or regions other than the one in which you live.

In particular, when you ask us to help connect you with hospitals or doctors in China, or to arrange medical care in China, relevant information may be transferred to hospitals, doctors, healthcare institutions, or service providers located in China.

Data protection laws may differ between countries and regions.

Where applicable, we take reasonable steps to protect information transferred across borders. These measures may include data protection agreements, standard contractual clauses, or other lawful transfer mechanisms intended to provide an appropriate level of protection.

We also seek to limit information sharing to what is reasonably necessary to provide the relevant services.

7. Cookies and Similar Technologies

Our website may use cookies or similar technologies to:

• Enable the website to function properly;
• Remember necessary website settings;
• Understand website traffic and usage;
• Improve website performance and user experience;
• Identify technical problems;
• Help protect against security risks.

Some cookies may be placed by third parties that provide analytics, hosting, or other website-related services to us.

You may be able to restrict or delete cookies through your browser settings. However, disabling certain necessary cookies may affect the functionality of some parts of the website.

8. Third-Party Websites and Services

Our website may contain links to third-party websites or services, including:

• Hospital websites;
• Doctor or healthcare provider pages;
• Payment platforms;
• Video conferencing platforms;
• WhatsApp;
• WeChat;
• Other third-party services.

When you leave the China Medical Navigation website and use a third-party service, that third party may collect and process your information under its own privacy policy.

China Medical Navigation does not control the privacy practices of third-party websites or services. We encourage you to review their privacy policies before using them.

9. How We Protect Your Information

We take reasonable technical and organizational measures designed to protect personal information against unauthorized:

• Access;
• Use;
• Modification;
• Disclosure;
• Loss;
• Deletion.

These measures may include access controls, authentication measures, file and system security, restrictions on employee access, and other reasonable safeguards.

However, no method of transmission over the internet, electronic storage system, or information system can be guaranteed to be completely secure.

Accordingly, we cannot guarantee that electronic transmission or storage of information will be entirely free from security risks.

10. Data Breach Notification

Although we take reasonable measures to protect your information, internet transmission and electronic storage cannot completely eliminate security risks.

If we become aware of a data breach that may affect the security of your personal information, we will provide notice, where and to the extent required by applicable law, as promptly as reasonably practicable. Such notice may include information about the incident and recommended steps you may take in response.

11. How Long We Retain Your Information

We retain personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, provide our services, or comply with legal obligations.

The specific retention period may depend on factors such as:

• The type of service you use;
• Your ongoing relationship with us;
• Whether medical coordination or follow-up services remain necessary;
• Financial, tax, or transaction record requirements;
• Legal, regulatory, or dispute-resolution requirements.

When personal information is no longer reasonably required, we may delete, anonymize, or otherwise appropriately dispose of it.

12. Your Privacy Rights

Depending on the laws applicable in your country or region, you may have one or more rights regarding your personal information, including the right to:

• Ask whether we hold personal information about you;
• Request access to your personal information;
• Request correction of inaccurate or incomplete information;
• Request deletion of certain personal information;
• Request restriction of certain processing activities;
• Object to certain processing activities;
• Withdraw consent you previously provided;
• Request a copy of certain information you provided to us;
• Make a complaint regarding the processing of your personal information.

These rights are not absolute in every circumstance.

For example, we may need to retain certain information where it is necessary to complete a service you have purchased, comply with legal obligations, maintain payment records, or resolve a dispute.

To exercise an applicable privacy right, please contact us using the information provided at the end of this Privacy Policy.

We may take reasonable steps to verify your identity before granting access to, modifying, or deleting personal information in order to prevent unauthorized requests.

We will respond to valid requests within the time period required by applicable law, which is generally within 30 days where such a period applies.

13. Withdrawal of Consent

Where we process personal information based on your consent, you may withdraw that consent where applicable.

Withdrawal of consent does not affect the lawfulness of processing that occurred before the withdrawal.

Please note that if you ask us to stop processing information that is necessary to provide a medical-related service, we may no longer be able to complete that service.

For example, if you withdraw authorization for us to provide your medical records to a doctor you have asked us to consult, we may be unable to continue arranging that Second Opinion.

14. Family Members, Caregivers, and Authorized Representatives

In cross-border healthcare situations, a patient’s family member, caregiver, or other representative may contact us, submit medical records, or assist with healthcare arrangements on the patient’s behalf.

If you submit personal or medical information on behalf of another patient, you should confirm that you have the patient’s authorization or are otherwise legally authorized to act on the patient’s behalf.

Where appropriate, we may request additional information to verify your identity or authority to act for the patient.

15. Children and Minors

Our services may involve patients who are minors. However, services for a minor should be requested and managed by a parent, legal guardian, or another adult who is legally authorized to act on the minor’s behalf.

We do not knowingly seek to collect sensitive medical information directly from children under the age of 16 without appropriate authorization.

If you believe that information about a minor has been provided to us without appropriate authorization, please contact us.

16. Marketing and Service Communications

We may send users who have contacted us or used our services communications that are directly related to their service, including:

• Service status updates;
• Requests for additional records or information;
• Medical arrangements;
• Appointment information;
• Payment information;
• Important service notifications.

For promotional messages, news, content updates, or marketing communications that are not directly related to an active service, we will provide appropriate ways to unsubscribe or stop receiving such communications where required by applicable law and supported by our business processes.

You may contact us at any time to request that we stop sending non-essential marketing communications.

Even if you opt out of marketing communications, we may still send transactional or service-related communications that are necessary to provide services you have requested.

17. We Do Not Sell Your Personal Medical Information

China Medical Navigation does not sell patients’ personal medical records, diagnosis information, pathology records, test results, or other identifiable medical information to advertisers.

If our business model changes materially in the future in a way that significantly affects how personal information is used, we will update this Privacy Policy and obtain any authorization required by applicable law.

18. Updates to This Privacy Policy

We may update this Privacy Policy from time to time as our services, technology, business relationships, or legal requirements change.

The updated version will be posted on this website and will identify the date of the latest update.

If we make a material change that significantly affects how we process personal information, we may provide notice through the website, email, or another appropriate method.

We encourage you to review this Privacy Policy periodically.

19. Governing Law and Jurisdiction

This Privacy Policy will be interpreted and applied in accordance with applicable law, without regard to conflict-of-law principles.

If a dispute arises in connection with this Privacy Policy, the parties should first attempt to resolve the matter through good-faith discussions. If the dispute cannot be resolved through such discussions, it may be submitted to a court of competent jurisdiction.

20. Contact Us

If you have questions about this Privacy Policy, your personal information, or how China Medical Navigation handles personal information, or if you wish to request access, correction, deletion, or exercise another applicable privacy right, please contact us.