Privacy Policy


Last modified on 28 January 2019


We are committed to protecting your privacy. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”) of the Laws of the Hong Kong Special Administrative Region (“Hong Kong SAR”). This Privacy Policy governs your use of our service of HEALTH Club (the “HC”) official website ( (the “HC Website”) as HC member, and forms part of, and should be read together with our TERMS AND CONDITIONS and FAQs for HC and the HC Website. Please read them carefully before you use the HC Website.




1.1       We are Reckitt Benckiser Hong Kong Limited, a company incorporated and registered in the Hong Kong ("we", "us", "our"). We act as data controller in respect of the processing of your personal data (including but not limited to your name, e-mail, phone number, date of birth and address) obtained through your registration as our HC member and use of the HC Website. You may at any time refuse to provide the personal information that we request. However, this may limit or prohibit our ability to provide our products and services to you. You may withdraw your consent for us to process your personal information by contacting us in accordance with our ‘CONTACT INFORMATION’ section (point 8) below.


1.2       We have the right to change or modify this Privacy Policy at any time. If we make material changes to this Privacy Policy you will be notified via email or otherwise in another manner that we deem will reasonably likely to reach you (such as posting the new Privacy Policy on HC Website). Please always verify whether you have consulted the latest version of the Privacy Policy. Any modifications to this Privacy Policy will be effective upon our publishing the new terms and/or upon implementation of the new changes on our service (or as otherwise indicated at the time of publication). In all cases, your continued use of the HC Website constitutes your acceptance of the modified Privacy Policy. The date on which the Privacy Policy was last modified is indicated at the top of the document.


1.3       The service of HC and/or the HC Website should only be used by people over the age of 18. We do not knowingly solicit data from or market to anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files upon request within a reasonable time.


1.4       Your personal data may be processed in the country/area in which it was collected and in other countries/areas, where laws regarding processing of personal data may be less stringent than the laws in your country/area  Please be advised that we reserve the right to transfer your data (including personal data) to and from any country, including the United Kingdom. We do this in order to provide high performance of our products and services, and also to process data and prepare it for processing in accordance with this Privacy Policy. You agree to your data being transferred to other country/area when you share your data with us. If you later wish to withdraw your consent, you can delete your account as described in the ‘DATA RETENTION AND YOUR RIGHTS’ section and CONTACT INFORMATION’ section (point 8) below.


1.5       We may use your personal data for direct marketing purposes as described in accordance with our ‘OUR USE OF YOUR PERSONAL DAT’ (point 3) section below. We will not do so unless we have obtained your consent. If you change your mind and no longer agree with such use of your personal data, you can object and "opt out" by contacting us as described below:




Our HC Website obtains information that you provide us with when you download, register and use the HC Website. You will not be able to use our service of HC and/or the HC Website unless you register with us. When you register and use the HC Website, you will need to provide us with your name, e-mail address, phone number, date of birth, address, etc. accordingly.




3.1       For personal information subject to the PDPO, we rely on several legal bases to process your personal information. These are:

•           where you have given your consent;

•           when the processing is necessary to perform a contract that we have with you, like the Terms of Use; and

•           our legitimate business interests, such as improving and developing our services and marketing new features or products.


3.2       We use your personal data in the HC Website over time, to respond to your requests and to aid us in serving you better. We may also use your personal data to contact you from time to time to provide you with important information, required notices and marketing promotions. Ways we use your personal data include, but are not limited to:


           to facilitate the creation of and secure your account on our network;


•           to identify you as a user in our system;


•           to enable you to connect our service of HC and/or the HC Website to you;


•           to improve the quality of experience when you use our service of HC and/or the HC Website;


•           to send you an e-mail if you request to create or reset a password for the HC Website;


•           to send you administrative e-mail notifications, such as security or support and maintenance advisories; and


•           to send newsletters, surveys, offers, and other promotional materials related to our HC and/or the HC Website, MoveFree products and our other products which we believe are useful for you.


3.3       We may create anonymous data records from personal data by excluding information (such as your name) that make the data personally identifiable to you. We may also collect anonymous data directly from the HC Website. We use this anonymous data to analyze request and usage patterns so that we may enhance the content of the HC Website and to improve our service on the HC Website. We may use this anonymous data for research and analysis purposes to improve our products and membership services. We reserve the right to use such anonymous data for any purpose and disclose anonymous data to third parties, including but not limited to our research partners, in our sole discretion.




4.1       Third Party Service Providers. Outside of authorised personnel employed by us, we only disclose personal information to third parties that meet our data privacy requirements (in accordance with the PDPO). When this occurs, it occurs in a secure and contractually-regulated manner.  These third party service providers are required not to use or transfer your personal data other than to provide the services requested by us.  If you opt-in to receive Marketing material via subscription from HC website your details may be stored within a third-party electronic direct messaging service such as mailchimp. We do not disclose personal information to third party marketing services.


4.2       Acquisitions. We may share your personal data with our parent company, subsidiaries, joint ventures, or other companies under a common control ("Affiliates"), in which case we will require our Affiliates to comply with this Privacy Policy. If another company acquires our company, business, or our assets, that company will possess the personal data collected by us and will assume the rights and obligations regarding your personal data as described in this Privacy Policy. In the unlikely event of an insolvency, bankruptcy or receivership, your personal data may also be transferred as a business asset.


4.3       Other Disclosures. Regardless of any choices you make regarding your personal data (as described below), we may disclose personal data if we believe in good faith that such disclosure is necessary (a) in connection with any legal investigation; (b) to comply with relevant laws or to respond to court orders, subpoenas or warrants served on us; (c) to protect or defend our rights or property or the rights of users of HC Website; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or any applicable TERMS AND CONDITIONS and/or FAQs.




5.1       We may periodically send you free newsletters, surveys, offers, and other promotional materials related to our service of HC and/or the HC Website, MoveFree branded products and our other products through e-mail which we believe are useful for you. We will not do so unless you have consented to this when you registered with the HC Website or at a later stage.


5.2       If you do not wish to receive such newsletters or promotional communications, you may choose not to tick the opt-in box upon registration. If you have chosen to receive marketing communications, you will always have the opportunity to "opt out" at a later stage by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below). Unsubscribe instructions will be included in every e-mail.


5.3       Despite your indicated e-mail preferences, we may send you notices of any updates to our Privacy Policy.




6.1       We and the Third Party Service Providers will retain your personal data for as long as you are HC member and for a reasonable time thereafter.


6.2       You may access, review, update, rectify or delete their personal information in your profile by logging into your account. Please note that removing your information may limit our ability to provide the service to you. If you opt to completely delete all such information, your account will be deactivated and you will lose access to the service.


6.3       You may contact us directly to request data modification outside of our services or if you have additional questions, please contact us as described below in CONTACT INFORMATION’ section (point 8) and we will respond within a reasonable time. We will delete such data within a reasonable time or anonymize the personal data so that it can never be linked back to you.


6.4       Notifying us promptly when any of your personal details change or where you realise that any information we are holding about you is incorrect will assist us in ensuring the information we hold is as accurate as possible. You may also contact us directly to receive (in a commonly used file format) the personal data you have provided to us.


6.5       In addition to your right to object to our use of your personal data for direct marketing purposes, you have the right to request information about our processing of your personal data and the right to request rectification of incomplete or inaccurate data. Please contact us as described below in  CONTACT INFORMATION’ section (point 8) if you wish to exercise these rights, and we will respond within a reasonable time.


6.6       We will respond to all requests within 30 days.


6.7       Please note that some or all of your personal data may be required in order for the service of HC and/or HC Website to function properly, and we may be required to retain certain information by law.




7.1       We are committed to protecting the security of your personal data. We follow generally accepted industry standards to protect the personal data submitted to us, both during transmission and once we receive it (including encrypted storage and password protection).


7.2       Each of our employees is aware of our security policies, and we limit access to your personal data to those employees and contractors who need to know that information for the purposes we described above.


7.3       Please be aware that, although we endeavour to provide reasonable security for information that we process and maintain, no security system can prevent all potential security breaches. Therefore, while we use reasonable efforts to protect your personal data, we cannot guarantee its absolute security.




We welcome your comments or questions regarding this Privacy Policy or our processing of your personal data. You can contact our support staff at the following address: 25/F, Chubb Tower, Windsor House, 311 Gloucester Road, Causeway Bay, Hong Kong or at 2507 9931.