Privacy Policy

Last updated: 19 October 2026 | Demonstration model — finalize with legal counsel before publishing.

1. Scope and Basis

This policy explains how HiCreate Technology1 ("we") processes personal information in connection with our services, in compliance with China's Personal Information Protection Law, Cybersecurity Law, and Data Security Law.

2. Information We Collect

We collect the information you provide in the pre-application and service process, which may include: name, passport number, nationality, email, contact details (e.g. WhatsApp), planned arrival date, target hospital and department, and a description of your needs (which may contain health information).

3. Purpose and Legal Basis

We process this information solely to perform the service you request: to coordinate hospital appointments (with your authorization), provide interpretation and companion, and communicate with you. This is based on your consent and/or the necessity of performing the contract with you.

4. Sensitive Personal Information

Health information is sensitive personal information. We process it only with your separate, specific consent and only as necessary for the service. We do not use it for unrelated purposes and do not sell it.

5. Sharing and Provision to Third Parties

We share your information only to the extent necessary: (a) with a hospital, with your written authorization, to coordinate your appointment; (b) with a licensed travel agency, with your consent, if you book a tour; (c) with processors we engage, under binding arrangements. We do not otherwise disclose your information except as required by law.

6. Storage and Retention

We keep personal information only as long as necessary to fulfill the purposes described in this policy or as required by applicable law, after which it is deleted or anonymized.

7. Security Measures

We take reasonable technical and organizational measures to protect your information from unauthorized access, loss, misuse or alteration, in line with the Cybersecurity Law and Data Security Law.

8. Your Rights

You have the right to inquire, access, copy, correct, or delete your personal information, to withdraw your consent, and to file a complaint. To exercise any of these rights, contact jklfdas@llda.com. Withdrawing consent or requesting deletion may affect our ability to provide the service.

9. Cross-Border Transfer and Minors

Where information needs to be transferred across borders (e.g. to a hospital or agency abroad or outside mainland China), we will inform you and obtain the required consent or complete the required procedures under applicable law. Our services are directed at adults; we do not knowingly collect personal information of minors without a guardian's consent.

10. Changes and Contact

We may update this policy from time to time and will indicate the date of the latest update. For any questions about this policy or data protection, contact jklfdas@llda.com.