Privacy Policy

Asa Central is an integrated health and wellbeing centre bringing together different forms of clinical care, therapeutic services and movement practices.

Services available at Asa Central include Physiotherapy, Sports Massage, Traditional Chinese Medicine, Yoga Therapy, Yoga, Pilates and Strength Training.

Some services are provided directly by Asa Central, while others are provided by independent practitioners or collaborating organisations.

In particular, Yoga and Yoga Therapy programmes are provided by Pragya Yog School, with whom Asa Central collaborates. Pilates programmes may be provided by either Asa Central or Pragya Yog School, depending on the particular programme and practitioner.

For the purposes of this Privacy Policy, “Asa Central”, “we”, “us” or “our” refers to the relevant Asa Central entity responsible for collecting and using personal data.

Depending on how you interact with Asa Central and the services you use, we may collect the following types of personal data:

Contact and identification information

This may include:

• Name
• Telephone number
• Email address
• Preferred contact method
• Emergency contact details, where relevant

Appointment, class and service information

This may include:

• Appointment or class dates and times
• Services or programmes requested or received
• Booking, cancellation and rescheduling records
• Membership, package and session information
• Communications relating to appointments, classes or services

Health and clinical information

Where relevant to the service you receive, we may collect information such as:

• Medical and health history
• Presenting symptoms and physical concerns
• Injury history
• Medications and allergies, where relevant
• Previous treatment or rehabilitation information
• Imaging or clinical reports provided by you
• Clinical assessments and treatment records
• Information about physical activity, lifestyle, movement or wellbeing goals where relevant to the service

We seek to collect information that is relevant and reasonably necessary for the purposes for which it is collected.

Payment and transaction information

This may include:

• Services or programmes purchased
• Invoices and receipts
• Payment status
• Information required to administer insurance or reimbursement claims

Where payment is made through a third-party payment provider, your payment information may be processed directly by that provider. We do not ordinarily store complete payment-card details ourselves.

Website and technical information

When you use our website, we may collect information such as:

• IP address
• Browser and device information
• Operating system
• Pages visited and interactions with our website
• Cookie and analytics information

We may use personal data for the following purposes:

Providing services

To:

• Understand your needs and requirements
• Provide the services or programmes you request
• Arrange and manage your care, classes or appointments
• Maintain appropriate service and clinical records
• Monitor progress where relevant
• Support continuity and coordination of care

Appointment and class administration

To:

• Arrange and manage appointments and classes
• Confirm and remind you about appointments or classes
• Process cancellations and rescheduling
• Respond to enquiries
• Communicate changes to appointments, classes or services

Coordinating care

Where appropriate, relevant information may be shared between authorised practitioners involved in your care where reasonably necessary to provide safe and coordinated services.

Payments and administration

To:

• Process payments
• Issue invoices and receipts
• Administer memberships, packages and class credits
• Process or assist with insurance claims where requested
• Maintain appropriate accounting and business records

Customer service

To respond to your enquiries, requests, feedback and other communications.

Legal and regulatory purposes

To comply with applicable laws, regulations, court orders, professional obligations and other legitimate legal requirements.

Safety and protection

Where reasonably necessary to protect the health, safety or vital interests of you or another person, or to prevent fraud, misuse or other unlawful activity.

Yoga and Yoga Therapy

Asa Central collaborates with Pragya Yog School. Yoga and Yoga Therapy programmes offered at Asa Central are provided by Pragya Yog School.

Depending on the particular programme and booking arrangement, you may register and pay for a Yoga or Yoga Therapy service:

1. directly with Asa Central, or
2. directly with Pragya Yog School.

The organisation through which you book or pay may therefore be responsible for collecting and processing certain personal data relating to your booking, payment and participation.

Where you book or pay through Asa Central

Where Asa Central receives your booking or payment for a Yoga or Yoga Therapy programme, Asa Central may collect and process information necessary to administer your booking and payment.

We may share relevant information with Pragya Yog School and its authorised practitioners where reasonably necessary to provide and administer the programme.

This may include information such as your name, contact details, booking information and other information reasonably necessary for the provision of the service.

Where health or wellbeing information is required for the safe and appropriate delivery of a Yoga Therapy service, only relevant information should be collected and shared for that purpose.

Where you book or pay directly with Pragya Yog School

Where you register or pay directly with Pragya Yog School, Pragya Yog School may collect and process your personal data in its own capacity for purposes including registration, payment, programme administration, communication and delivery of its services.

In such circumstances, Pragya Yog School's own privacy policy will apply to its processing of your personal data.

Where Asa Central receives or processes information relating to your participation, we will handle that information in accordance with this Privacy Policy and applicable privacy requirements.

Shared collaboration

Asa Central and Pragya Yog School may exchange limited information where reasonably necessary to administer a jointly offered programme, coordinate a service, communicate with participants or provide an appropriate and connected experience.

We will seek to limit any information shared to what is reasonably necessary for the relevant purpose.

The specific organisation responsible for your personal data may therefore differ depending on the service you choose and how you register and pay for it.

Pilates programmes at Asa Central may be provided by Asa Central or by Pragya Yog School, depending on the particular programme and practitioner.

Where a service is provided by an independent practitioner or collaborating organisation, the relevant provider may collect and process personal data in its own capacity.

We will make reasonable efforts to ensure that you understand which organisation or practitioner is providing the service and, where relevant, which organisation is responsible for collecting your personal data.

We recognise that health and clinical information is particularly private and take appropriate measures to protect its confidentiality.

Clinical information collected in connection with services provided by Asa Central will only be accessed by authorised persons who require the information for your care, appointment administration or other legitimate purposes.

Where relevant information needs to be shared between practitioners or collaborating organisations involved in your care or service, we will limit the information shared to what is reasonably necessary for that purpose.

We will not disclose your clinical information to unrelated third parties without your consent unless disclosure is permitted or required by law or otherwise permitted under the PDPO.

Where you provide health information directly to Pragya Yog School in connection with Yoga or Yoga Therapy, that information may be processed by Pragya Yog School in accordance with its own privacy policy and applicable privacy requirements.

Depending on the circumstances, relevant personal data may be disclosed to:

• Asa Central practitioners and authorised staff
• Pragya Yog School and its authorised practitioners, where relevant to Yoga, Yoga Therapy or a related programme
• Other healthcare professionals or providers involved in your care
• External healthcare providers where you request or consent to a referral
• Insurance providers or claims administrators where necessary for a claim requested by you
• Payment service providers
• Booking, appointment and customer-management service providers
• Electronic record-management and technology providers
• IT, website hosting, communications and technical service providers
• Professional advisers, auditors and insurers where reasonably necessary
• Government, regulatory or law-enforcement authorities where required or permitted by law

Some of our technology, hosting, booking, payment or other service providers may process or store information outside Hong Kong.

Where this occurs, we take appropriate steps to protect your personal data and require relevant service providers to handle the information appropriately and in accordance with applicable privacy requirements.

We may wish to send you information about Asa Central's services, programmes, workshops, events, offers or other activities.

We will only use your personal data for direct marketing where we have obtained the consent or indication of no objection required under the PDPO.

Marketing communications may be sent by email, telephone, WhatsApp, SMS or other communication channels you have provided to us.

You may withdraw your consent or opt out of marketing communications at any time. This will not affect your ability to receive services from Asa Central.

Where appropriate, you may also receive information about programmes or events offered jointly with Pragya Yog School or other collaborating organisations. Where direct marketing involves another organisation, we will comply with the applicable requirements of the PDPO.

Service-related communications, including appointment confirmations, reminders, invoices and important information relating to your care or booking, are not treated as promotional marketing.

We may use WhatsApp, email, SMS or telephone to communicate with you regarding appointments, bookings, administration and general enquiries.

While electronic communication platforms may use security measures such as encryption, no electronic communication method can be guaranteed to be completely secure.

Please avoid sending detailed medical information, sensitive clinical records or other unnecessary personal information through WhatsApp unless specifically requested by our team or the relevant service provider.

Where appropriate, clinical information will be maintained within designated clinical or record-management systems.

We take reasonable and practicable steps to protect personal data against unauthorised or accidental access, processing, loss, destruction, alteration or disclosure.

Depending on the nature of the information and system involved, safeguards may include:

• Access controls and user permissions
• Secure passwords and authentication measures
• Secure electronic systems
• Encryption where appropriate
• Physical security measures for paper records
• Staff confidentiality obligations and privacy training
• Appropriate controls over third-party service providers

Access to personal and clinical information is limited to authorised persons who require it for legitimate purposes.

We retain personal data only for as long as is reasonably necessary to fulfil the purposes for which it was collected, or for any longer period required or permitted by applicable law, regulatory requirements, professional obligations, insurance requirements or legitimate business purposes.

Different types of information may therefore be retained for different periods.

Clinical, appointment, payment, membership, administrative and marketing information may each have different retention periods depending on the purpose for which the information was collected.

When personal data is no longer required, we will take reasonable steps to securely delete, destroy or anonymise it, unless retention is required or permitted by law.

Where Pragya Yog School processes personal data independently, its retention of that information will be governed by its own applicable privacy policy and requirements.

Our website may use cookies and similar technologies to:

• Enable essential website functions
• Maintain website security
• Remember certain preferences
• Understand how visitors use our website
• Improve website performance and user experience

Some cookies may be provided by third-party analytics or website service providers.

You can manage or disable cookies through your browser settings. Disabling certain cookies may affect some website functions.

We take reasonable steps to ensure that personal data we hold is accurate and up to date for the purposes for which it is used.

If your personal information changes, or if you believe information we hold about you is inaccurate or incomplete, please contact us so that we can update our records.

Subject to the requirements and exemptions under the PDPO, you have the right to:

• Request access to personal data that we hold about you
• Request correction of personal data that is inaccurate or incomplete
• Request information about our policies and practices in relation to personal data
• Withdraw consent previously given for direct marketing

You may have other rights or protections under the PDPO depending on the circumstances.

If you wish to request access to or correction of your personal data, please contact us in writing using the contact details below.

Please provide sufficient information to allow us to identify you and understand the information you are requesting or seeking to correct.

We may need to verify your identity before processing your request.

A reasonable fee may be charged for processing a data access request where permitted by the PDPO.

We will handle valid data access and correction requests in accordance with the requirements of the PDPO and applicable statutory time limits.

If you submit an enquiry or appointment request through our website, the information you provide will be used to respond to your enquiry, arrange an appointment and, where applicable, provide or administer the services you request.

Information marked as mandatory is required for us to process the relevant enquiry or appointment. Other information is generally voluntary, although providing relevant additional information may help us better understand your needs.

Please do not provide more health or personal information through a general website enquiry form than is reasonably necessary for your enquiry.

Where an enquiry relates specifically to Yoga or Yoga Therapy, information may be shared with Pragya Yog School where reasonably necessary to respond to your enquiry or arrange the requested service.

Where our services are provided to children or young persons, we may collect information from a parent, guardian or other authorised person where appropriate.

We take particular care when handling information relating to minors and will use and disclose such information only for appropriate purposes connected with their care, administration, safety or legal requirements.

Our website may contain links to third-party websites or services.

Those websites operate independently from Asa Central and may have their own privacy policies. We are not responsible for the privacy practices or content of third-party websites.

We recommend reviewing the privacy policy of any third-party website before providing personal information.

We may update this Privacy Policy from time to time to reflect changes to our services, technology, legal requirements or privacy practices.

The latest version will be published on our website with the date of the most recent update.

We encourage you to review this Policy periodically.

If you have any questions about this Privacy Policy, how we handle your personal data, or wish to exercise your rights under the PDPO, please contact us:

We will do our best to address your enquiry and handle any request in accordance with applicable Hong Kong privacy requirements.

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