Privacy Policy

Updated on: 30/08/2020

TrioClear™ , (“TrioClear™” or “we” ‘us’ or “our”) respects your privacy and is committed to protecting it including through our compliance with this policy. We will handle your personal information only in accordance with the Personal Data (Privacy) Ordinance (Cap. 486)) (“PDPO”), the Data Privacy Principles and related applicable laws in Hong Kong (collectively, Hong Kong privacy laws’).

This Privacy Policy (“Privacy Policy”) describes the types of personal information we may collect from you when providing our Services to you, including personal information that you may provide or disclose to us when you visit the Website (our “Website”), communicate with us through email, text, SMS and other electronic communications; and (ii) our practices for collecting, using, handling, maintaining, storing, protecting, and disclosing your personal information.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will handle it. If you do not agree with our policies and practices, you should not use our Website or acquire our Services. By accessing or using our Website, you agree to the terms and conditions of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Website and Services after we make changes shall constitute your acceptance of those changes, so please check this Privacy Policy periodically for updates.

By visiting this Website, you agree to accept unconditionally the terms of this Disclaimer and as they may be revised and/or amended from time to time by TrioClear™ without prior notice to you. Please check this page regularly for any revisions and/or amendments which may be made.

Children Under the Age of 18

Our Application and Website are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Website. We do not knowingly collect personal information directly from children under 18. If you are under 18, please ask your parent or guardian to access and use the Website or Application for you, and please do not use, or provide any information on our Website, Application, or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. Please notify us and stop using our Services immediately if you do not consent to this Privacy Policy, or do not have consent from your parent(s) or legal guardian(s).

Personal information collected from you

We may collect personal information from our customers, patients (former, potential and current), patients’ parents/guardians, doctors, dentists, orthodontists and other medical or healthcare practitioners, and/or visitors to our Platforms; for instance, when they register to become a partner of any of our Platforms, via on-line forms, when they contact us on any of our Platforms, when they sign up to receive news alerts from us, to undergo an assessment on any of our Websites. The kinds of personal information collected from patients (former, potential and current) who visit our Platforms include names, contact information, dates of birth, health information, digital scans and photographs.

We may also collect personal information from doctors, dentists, orthodontists and other medical or healthcare practitioners including names, profiles, practice names, addresses, phone numbers, Website URLs, and other details such as their tier experience, for specific purposes such as to provide services to our consumers, customers, and other users of the Platforms.

We may also collect personal information about your use of our Platforms as described in the section “Cookies and advertisements” below.

By accessing or using our Services or otherwise providing us with your personal data, we shall be entitled to assume that you understand and agree to the terms of this Privacy Policy and consent to the collection, use and disclosure of your personal data by us. If you do not consent to any of these terms, please do not access or use any of our Services, or provide us with any of your personal data.

Purposes for collection, use, disclosure & processing of personal data

We use your personal data to provide you with relevant Services and to operate our business. We may also use the data collected to communicate with you, for instance, to inform you about new features of the Services, security updates, or to inform you about your account. Your personal data may also be used to show you more relevant information, content, advertisements, whether through the Services or third-party applications and in combination with information from other sources.

Some examples of how we generally use your personal data include:

  • to provide our Website and present their contents to you;
  • to provide you with our Services and information on our products and Services that you request from us;
  • to provide personal information to your health provider, including licensed dentist or orthodontist including as may be requested by them from us;
  • to fulfill any other lawful purpose for which you provide it;
  • to comply with applicable laws and regulations and to operate our business;
  • to provide you with notices about your account or membership, including expiration and renewal notices;
  • to notify you about changes to our Website or any products or Services we offer or provide though them;
  • to enable the marketing of products and services to you using our marketing tools and platform, including to personalize our products and services, including Website optimization, personalized emails and optimize our dynamic marketing and advertising strategies;
  • to manage the security of our Website, platform, networks and systems;
  • in any other way we may describe when you provide the information; and
  • for any other purpose with your prior written consent.

Sharing your personal data with third parties

We may partner with other businesses to assist us in our marketing, communications, and sales efforts, and may share personal information about you for these purposes where you have given us consent to do so or where permitted by law. These partners are not allowed to use your personal information for any other purpose.

In addition, any information we collect including personal information may be disclosed as part of any merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.

We may also disclose personal information about you if we believe that doing so is legally required or is necessary to protect our property or other legal rights. Such disclosure will be made within the parameters of the privacy legislation in Hong Kong.

Where we disclose your personal data to third parties, we will employ our best efforts to require such third parties to protect your personal data.

By using our Services, you agree that the transfer of your personal data to various countries is reasonably necessary for us to provide you with these Services.

Sharing of personal data via channels

Where you are a user of any of the Channels and/or other social media platforms with public account settings and you use any hashtags which may be related to TrioClear™, the TrioClear™ Treatment or any of its campaigns and/or products or services, we will be able to retrieve your reviews of our services from the Channels and post them on our Website or Channels, for the purposes of sharing your opinions about our products with the visitors of our Website and Channels. You hereby agree not to use such hashtags if you do not wish for your reviews/feedback/content to be made available on any of our Website or Channels. By posting or otherwise making available any content on the Channels or a social media platform about your experience in relation to the TrioClear™ Treatment, and responding “yes” where we request your permission to share your content on any of our Website or Channels, you represent and warrant that you are 18 years of age or older and that you agree to the terms and conditions listed on the Website and Channels.

Overseas Disclosure

Information we collect about you may be disclosed to recipients located outside of Hong Kong, including to each TrioClear™ group company located throughout the world, including, but not limited to, in the Netherlands, France, Germany, Spain, Sweden, Denmark, Ireland, Norway, Madagascar, the United States, Australia, Canada, Hong Kong, Macau, China, Taiwan and Singapore.

We take reasonable steps to ensure that the personal information stored offshore is handled in accordance with applicable privacy laws and strict privacy safeguards to protect your privacy rights and interests and that transfers are limited to countries which are recognized as providing an adequate level of legal privacy protection or where we can be satisfied that alternative arrangements are in place to protect your privacy rights in accordance with Hong Kong privacy laws.


Our Platforms have appropriate technical and organizational security measures in place to protect against the destruction, loss, misuse and alteration, unauthorized disclosure of or access to the information under our control. In regard to our web portals, such as the TrioClear Submission Platform, patient information (including any personal data) is transmitted securely via HTTPS. These portals require customer accounts and are not available to the general public.

Your Rights

You have rights concerning access to and disclosure, amendment, or deletion of personal information that is in our possession or under our control. You may contact us at the address or email listed in the section entitled “Contact us” in this regard.


If you have a complaint about the way in which we have handled any privacy issue, including your request for access or correction of your personal information, you should contact us using the Contact Information set out below.

We will consider your complaint and determine whether it requires further investigation. We will notify you of the outcome of this investigation and any subsequent internal investigation.

If you remain unsatisfied with the way in which we have handled any privacy issue, you may approach an independent advisor or contact the Office of the Privacy Commissioner for Personal Data ( for guidance on alternative courses of action which may be available.

Cookies Use

Acceptance of cookies is not required to visit TrioClear™ websites, we do use cookies. Cookies are small text files stored on computer hard drives and are regularly used to analyze individual website activity. By collecting and remembering information about your visit to a website, cookies allow web applications to recognize and respond to your individual preferences. A cookie file may contain information that the Website uses to respond to you as an individual and to tailor a website experience to your preferences. If you have provided your contact information as part of your website visit, we may utilize the cookie file to collect information about your specific website activity. This information will only be used for marketing purposes by TrioClear™ and will not be sold or shared with any third party not contracted with TrioClear™.

TrioClear™’s Website use cookies. This enables us to determine the usefulness of information provided to our users and to analyze the effectiveness of our navigational structure in providing you that information. In the end, cookies help us provide you with a better website experience.