1. Operator and Scope of this Policy
ELITE MEDICAL CLINIC LIMITED (the “Company”, “we”, “us” or “our”) operates the mobile application and associated services (the “App”). This Privacy Policy applies to the App, related websites, accounts, AI health-analysis functions, membership and rewards features, and supporting systems provided by the Company.
This Policy describes the personal data we collect, why we use it, to whom it may be disclosed, where it may be processed, how long it is kept and how it is deleted, and how you may request access, correction or other privacy assistance. It does not replace any brief notice or consent screen shown when a particular feature collects information.
Privacy contact: admin@elitemedclinic.ai. Official website: https://elitemedclinic.ai.
2. Personal Data We Collect
The information collected depends on the features you use. We aim to limit collection to what is reasonably necessary for the relevant service. Installing the App alone does not mean that you must provide all data associated with features you do not use.
- Account and contact information: membership number, nickname or username, mobile number, email address, login and verification status, and language settings.
- Personal and health-related information: age, sex, height, weight, questionnaire responses, lifestyle, symptoms, health concerns and other information you choose to enter.
- Images: tongue and facial photographs that you take or select, and their associated analysis results.
- AI-related information: questions, conversations and necessary context, analysis requests, original responses, displayed or translated results, request times and necessary technical identifiers.
- Device health data, if the feature is enabled and you authorise it: specific categories of data you permit us to access through Apple Health / HealthKit, Android Health Connect or compatible wearables, potentially including sleep, activity, heart rate and weight.
- Rewards and transaction data: free-use allowances, reward points and redemption records. If paid AI Credits are introduced, we may also process purchased products, platform transaction identifiers, payment status, refunds and credit balances.
- Necessary technical and security information: IP address, device and operating-system version, App version, login time, error records, abuse-prevention information and server security logs.
3. Purposes of Collection and Your Choices
We use relevant information to create and administer accounts; send one-time verification codes; perform tongue or facial analysis requested by you; respond to AI health questions; display and retain analysis history; provide language switching and translation; support health-data integrations you have authorised; calculate free-use allowances and reward points; process redemptions or paid transactions; provide customer support; protect system security; and handle matters required by law.
Your mobile number or email address may be necessary to create and verify an account. Tongue or facial photographs and questionnaire answers are needed only when you request the corresponding analysis. Declining to provide information may make that feature unavailable, but does not necessarily affect unrelated features.
We do not sell your tongue or facial photographs or personal health information. We do not use Apple Health / Health Connect data, tongue or facial photographs, or private health conversations for targeted advertising. For new purposes that are not directly related to the original purpose, we will provide any further notice and obtain any consent required by applicable rules.
4. Tongue and Facial Images; Access to Photographs
New tongue and facial photographs are stored in private Tencent Cloud Object Storage (COS) in the Hong Kong region. User accounts, health information and analysis records are stored primarily in MySQL in the Hong Kong region.
Photographs are not made permanently public. When you request an AI analysis, our systems may generate a time-limited signed image URL so that an authorised analysis service can retrieve a particular image during the URL’s validity period. A signed URL does not mean that an image stays solely in Hong Kong: the third party may temporarily process it in its own computing environment after retrieval.
We collect tongue and facial images to provide the health analysis you request. This feature is not used for facial identity verification, Face ID login, surveillance or creation of facial templates for identification. If we change these purposes, we will update the relevant notice beforehand and take the steps required by applicable rules.
5. Third-Party AI: XunAi Traditional Chinese Medicine AI Open Platform
When you use tongue or facial analysis, the App uses the XunAi Traditional Chinese Medicine AI Open Platform (寻艾中医AI开放平台, “XunAi”) to process information necessary to complete that analysis. Under the current system flow, a tongue-analysis request may include a signed tongue-image URL, age and sex. A facial-analysis request may include a signed facial-image URL and relevant questionnaire responses. Our code does not deliberately append a mobile number, email address or membership number as an identification field in these requests.
According to XunAi’s written response to the Company, XunAi does not retain customers’ tongue or facial photographs or other customer data after recognition is completed and the result returned; it does not use customer data to train models; and it states that it supports No Training / Zero Data Retention. These statements reflect information currently provided by that supplier and must not be assumed to apply to other AI suppliers.
Although our original image files are stored in Hong Kong, information used by XunAi may be transmitted to service facilities in mainland China for real-time recognition and processing. We will update this Policy if the supplier further confirms a different processing location or if the location changes.
6. Third-Party AI: DeepSeek and Chat Content
The App also calls DeepSeek for AI chat and question-and-answer functions. To generate responses, we may send DeepSeek the conversation you enter and personal health information relevant to the question. Our systems do not deliberately append your telephone number, email address or membership number as separate identification fields; however, if you put such information into the chat yourself, it may be transmitted with your conversation.
XunAi’s statements about non-retention and non-training do not apply to DeepSeek. We do not currently promise that DeepSeek provides Zero Data Retention, zero logging, no model training or storage in any particular location. Its retention and other data processing depend on the API service we actually use, account settings, contracts and applicable supplier policies. Until those arrangements are specifically verified, please do not enter unnecessary directly identifying information in AI chat.
We seek to send only information needed for the service, applying data-minimisation principles. If a supplier changes or third-party processing materially affects your data, we will update this Policy and, where applicable, provide further notice or obtain required consent.
7. Cross-Border Processing and Other Service Providers
The main application servers, user database and image storage controlled by the Company are hosted on Tencent Cloud in Hong Kong. Nevertheless, information supplied to third-party AI, communications, translation or technical-support services to fulfil a feature you request may be accessed or processed outside Hong Kong. Storage in Hong Kong does not mean that every operation takes place there.
Recipients of necessary information may include Tencent Cloud infrastructure providers; SMS and email verification providers; XunAi; DeepSeek; software developers and maintenance personnel authorised by us; and medical, beauty or merchant service providers you choose to use, where applicable. We limit authorised access by role and take reasonable contractual or other protective measures.
If we introduce a new third-party translation, analysis, mapping, payment or other data-processing provider, we will first examine the actual data flow and update applicable notices and platform declarations.
8. Camera, Photos, Health and Location Permissions
Tongue and facial analysis features request camera or photo-selection access when needed and are intended to use only images you take or choose. Permission to access photos does not by itself authorise us to upload unrelated images from your library. When you first use image analysis, the App should clearly disclose third-party AI use before transmission and obtain any applicable consent.
If Apple Health / HealthKit, Health Connect or wearable integrations are offered, we read the particular data categories only after the feature is enabled and you grant permission. You can revoke access in your phone or the relevant platform’s settings. If a nearby-clinic feature is enabled, location information is used only where needed and authorised; if manual area entry is available, you may choose not to grant location access.
Withdrawing permission may affect the relevant feature but does not automatically delete information previously sent to our systems. To request deletion of stored data, use account deletion or contact us.
9. Chinese-English Translation and AI Analysis Records
The App may automatically translate questions you enter or analysis results between Chinese and English. Direct identifiers unrelated to translation should not be transmitted unnecessarily. Automated translations can contain mistakes or differences in meaning; consult a qualified healthcare professional when making decisions that affect your health.
To provide history, investigate complaints, support operations and maintain security, we may keep your original questions, responses, associated analysis results, translations and timestamps within our systems until the relevant purpose ends or you request deletion under this Policy. A third party’s own processing is separate from the records that we store.
10. Verification, Rewards and WhatsApp
For account registration or login verification, we may provide an SMS or email service with your mobile number or email address, the necessary verification message and delivery status. We do not intentionally include a full health report or tongue or facial photograph in routine one-time-password messages.
To administer rewards, we may retain membership numbers, qualifying activities, point balances, redemption status and booking status. If you choose to request a reward through WhatsApp, the App may pre-fill your membership number and redemption request. You must choose to send the message yourself; tongue photographs, facial photographs and AI health reports are not automatically attached. WhatsApp also applies its own privacy rules to messages you send through it.
If you use clinic booking or merchant features, we disclose to the relevant recipient only information necessary to complete the service you request. Merely displaying clinic or product information does not cause us to send your full health record to the clinic or merchant.
11. Future Paid AI Credits
If paid AI Credits are introduced, we may process the quantity purchased, product identifier, purchase time, platform transaction identifier, payment or refund status, and used and remaining credits, for accounting, delivery, dispute resolution and necessary legal obligations.
Where payment is made through the Apple App Store or Google Play, the relevant platform processes the payment instrument. We generally do not directly receive or store your full card number or security code from those transactions. Usage rules, refunds and the treatment of unused paid entitlements after account deletion are addressed in our Terms & Conditions and the conditions displayed when you buy.
12. Retention, Account Deletion and Backups
While your account remains active, we retain information as reasonably needed to provide the service, maintain security and fulfil other relevant purposes. We delete or de-identify information no longer required, in accordance with its purpose and applicable requirements.
You may initiate account deletion through Settings / Account / Delete Account in the App. According to our development team’s current confirmation, following account deletion the Company’s primary active MySQL systems immediately remove associated user information, AI questions and answers, and analysis records; COS immediately removes related tongue and facial photographs. Free reward points and free AI-use allowances end with the account. Paid but unused entitlements are handled under the purchase conditions, the payment platform’s rules and applicable law.
Immediate deletion from active systems does not mean that every disaster-recovery backup or necessary technical record held by a third party disappears at the same instant. Backups that still contain deleted information are removed under the actual backup retention and rotation arrangements and are not used for ordinary business restoration. Where necessary for law, transaction disputes, security or fraud prevention, we may retain limited records to the extent required. We do not promise a uniform backup-deletion period that has not been verified.
If you cannot access your account, email admin@elitemedclinic.ai to request deletion. We may reasonably verify your identity first to avoid deleting someone else’s data.
13. Data Security and Incident Response
We take measures proportionate to the sensitivity of the information, including HTTPS / TLS transmission, private storage in the Hong Kong region, private database connections, limited validity for signed URLs, access controls, account verification and necessary technical monitoring. Authorised maintenance personnel should access information only as required for their work.
We aim to avoid recording passwords, one-time codes, API secrets or complete sensitive health conversations in ordinary application logs. Technical and infrastructure logs may still contain necessary request and security metadata. No internet or cloud system can guarantee absolute freedom from risk; if an incident occurs, we will take reasonable remediation and notification measures according to its impact, applicable law and platform requirements.
14. Access, Correction, Withdrawal and Contact
You may request access to and correction of personal data we hold through the App, where available, or by email. You may also stop using particular features, withdraw revocable permissions, or request deletion of your account and data. We may charge any data-access fee permitted by law and will handle requests as legally required.
Send privacy enquiries, access or correction requests, withdrawal requests and deletion requests to admin@elitemedclinic.ai. To safeguard account security, we may reasonably verify your identity before disclosing or deleting information.
If you do not agree to particular information being transmitted to a third-party AI service, please do not use features that depend on that transfer. Where applicable, you may still use other features that do not rely on that information.
15. Minors, Third-Party Links and Policy Updates
The App is not specifically designed for children. If a minor seeks to use a feature involving health information or images, the user must meet the age and consent arrangements then published by the App, applicable law and platform requirements. We discourage uploading another person’s or a minor’s tongue or facial images or health information without appropriate authorisation.
The App may link to doctors, clinics, merchants, WhatsApp and other third parties. After leaving the App, those third parties process information you provide directly to them under their own policies.
We may update this Policy because of changes in features, suppliers, data flows or legal requirements and will display the latest date. For material changes, we will provide appropriate notice and obtain fresh consent where required. This Policy is interpreted in accordance with the applicable Hong Kong Personal Data (Privacy) Ordinance and other mandatory rules.
ELITE MEDICAL CLINIC LIMITED · https://elitemedclinic.ai · admin@elitemedclinic.ai