Privacy Policy

This Privacy Policy is issued by Inner Mongolia Mingyan Health Management Service Co., Ltd. (the "Company") and explains how the Company collects, uses, stores, shares, transfers, and protects your personal information when you use the services on iveelvita (the China–Mongolia health service platform, https://iveelvita.com and its escort workbench).

This Policy, together with the Terms of Service and the Personal Information Collection Notice, constitutes the complete agreement and forms an integral part of those Terms. This Platform involves Sensitive Personal Information of a health-related nature, such as medical records, diagnostic conclusions, and examination reports, and you are asked to read Articles 3, 4, 8, 10, and 13 of this Policy item by item before you submit a consultation, upload materials, or place an order.

The processing principles of this Policy are: defined purposes, minimum necessity, separate consent (for sensitive information), no sale of personal information, revocability, and verifiability.

Table of contents

1. Article 1 Terms and Scope of Application
2. Article 2 The Personal Information Handler (Data Controller)
3. Article 3 Inventory of the Personal Information We Collect
4. Article 4 Sensitive Personal Information and Separate Consent
5. Article 5 Purposes of Processing and Legal Bases
6. Article 6 Information We Obtain from Third Parties
7. Article 7 Cookies, Similar Technologies and Usage Statistics
8. Article 8 How We Share, Entrust and Disclose Information
9. Article 9 Access to Information by Escort Staff and Other On-Site Personnel
10. Article 10 Cross-Border Transfers
11. Article 11 Retention Periods and Deletion
12. Article 12 Security Measures We Adopt
13. Article 13 Your Rights and How to Exercise Them
14. Article 14 Minors and Other Cases Requiring a Guardian's Consent
15. Article 15 Information You Publish and Publicly Visible Information
16. Article 16 Notification of Personal Information Security Incidents
17. Article 17 Updates to This Policy
18. Article 18 Contacting Us and Personal Information Protection Matters

Article 1 Terms and Scope of Application

• Personal information: any information recorded electronically or by other means that, alone or in combination with other information, can identify a particular natural person, including name, e-mail address, mobile number, passport number, itinerary information, device information, and log information.
• Sensitive Personal Information: information that, once leaked or unlawfully used, is likely to infringe the personal dignity of a natural person or to endanger his or her personal or property safety. On this Platform it comprises principally medical and health information (condition, medical history, diagnostic conclusions, examination reports, prescriptions and medication, and visit records) and entry-exit document information (passport number and visa information).
• Processing: includes collection, storage, use, further handling, translation, transfer, provision, disclosure, and deletion.
• Anonymisation: the process by which personal information can no longer identify a particular natural person and cannot be restored. Information that has been anonymised no longer constitutes personal information.
• This Policy applies to the websites, pages, back office, e-mail and SMS notifications, and escort workbench of this Platform. Information collected by third-party institutions (Medical Institutions, payment institutions, airlines, hotels, and social platforms) is governed by their own respective rules, which you should read separately.

Article 2 The Personal Information Handler (Data Controller)

• The personal information handler (data controller) is Inner Mongolia Mingyan Health Management Service Co., Ltd. (place of business: Xincheng District, Hohhot, Inner Mongolia Autonomous Region, China; ICP filing: ICP Filing No. Meng ICP Bei 2025026867).
• Contact details are set out in Article 18. The Company has designated personnel responsible for personal information protection matters, who receive in a single channel requests for access, rectification, deletion, withdrawal of consent, and complaints.
• Where the Company entrusts a specific processing activity to a third party, the entrusted party may process information only within the entrusted purpose and scope, and the Company shall bear supervisory responsibility for its processing activities.

Article 3 Inventory of the Personal Information We Collect

The list below sets out, by category, the information we collect, its source, and its necessity. "Required" means that without it the corresponding function cannot be used; "optional" means that not providing it does not affect basic use.

• Account and identity (required): e-mail address (login account), password (stored in an irreversible form, which the Company cannot read in plain text), display name, gender, date or year of birth, country and service city; and the name, gender, and year of birth of the Patient or of Escort Staff.
• Contact details (required): mobile number (used for consultation communication, appointments, and result notifications), e-mail address, WeChat account, and Messenger account (used for cross-border contact, collected according to the content you enter).
• Medical and health information (sensitive, requiring separate consent): the chief complaint, symptoms and disease course, personal and family history, allergy history, medications currently in use, diagnostic conclusions, laboratory and imaging results, and medical orders that you enter in the medical-care consultation; and the original files you upload, such as medical records, laboratory reports, imaging reports, and discharge summaries, together with their file names, types, and sizes.
• Documents and entry-exit information (sensitive, where necessary for the Services): passport number and passport data page, visa and invitation-letter information, and the identity information of the person being treated, used for real-name registration, admission registration, cross-border formalities, and verification for escort services.
• Itinerary and arrangement information (required): planned date of arrival in China, the city and Medical Institutions to be visited, pick-up and drop-off points and accommodation arrangements, the number of accompanying persons, and language requirements.
• Transaction and fee information (required): order number, package content and price, payment status and the transaction number returned by the payment channel, refund records, details of points earned and applied, and invoice or voucher requirements. Full bank-card numbers and payment passwords are handled by licensed payment institutions such as WeChat Pay and Alipay, and the Company neither collects nor retains them; if you enter a receiving account (for withdrawals by Escort Staff or agents), it is used only for payment verification.
• Service performance information (required): dispatch and acceptance records, service times and places, service events (including necessary on-site photographs taken with your consent), replacement and termination records, settlement and deduction records, and the communications and relaying between the parties.
• Communication records (required): customer-service sessions, on-site messages, e-mail correspondence, and customer-service telephone records. Where audio recording is required, we will inform you and obtain your consent before recording.
• Reviews and user content (optional): ratings, review text, the body text and images of patient stories, likes and comments, feedback content, and the screenshots you upload.
• Log and device information (collected automatically): the pages and interfaces accessed, request time, response status, referring address, IP address, browser and device type, language settings, login IP, and login-anomaly alerts. These are used for security auditing, fault troubleshooting, and performance optimisation.
• Location inference (automatic): inference of your country from your IP address, used to determine the default language, currency, and service scope. We do not collect precise geolocation and do not continuously track your movements.

Article 4 Sensitive Personal Information and Separate Consent

• Medical records, examination reports, diagnostic conclusions, and medication information constitute Sensitive Personal Information. The Company collects, translates, transmits, and stores them only after obtaining your (or the Patient's guardian's) separate consent, and uses them only for the defined purpose of arranging care assistance for you, of translation verification, and of follow-up communication.
• The consent you give in the Personal Information Collection Notice in respect of the processing of your mobile number is not equivalent to authorisation in respect of medical records and medical materials; conversely, your authorisation in respect of medical materials does not extend to marketing or other purposes.
• When you submit a medical-care consultation, the page requires you to select "I have read and agree to the personal information processing terms above" before you may continue; if you do not select it, you may still browse the Platform's public information, but you cannot submit a consultation.
• You may withdraw your consent to the processing of Sensitive Personal Information at any time (see Article 13). Withdrawal does not affect the validity of processing already carried out on the basis of consent before the withdrawal, but the Company will thereafter cease the corresponding processing and will, upon your request, delete the relevant materials (except where retention is required by law).

Article 5 Purposes of Processing and Legal Bases

The Company processes personal information for the following purposes, and each processing activity has a corresponding legal basis:

• Concluding and performing the service contract (contractual necessity): compiling Care Plans, confirming orders, dispatching orders, organising on-site accompaniment, handling collection and payment matters on your behalf, and verifying and settling the Services.
• Obtaining your explicit consent: processing the mobile number for consultation communication and appointment notifications; processing medical records and examination materials for care assistance and translation; contacting you by telephone or e-mail; and on-site records of the Services made with your consent.
• Performing legal obligations: retaining transaction information and order records for the periods required by the E-Commerce Law of the People's Republic of China and other laws; providing or retaining specific information in response to requirements lawfully made by tax, regulatory, judicial, or competent authorities; and cooperating with investigations of emergencies.
• Legitimate interests (to the extent necessary and without affecting your rights and interests): safeguarding account and website security, identifying and preventing fraud and abuse, troubleshooting faults and optimising performance, improving the Services and training Escort Staff, and handling complaints and dispute coordination (see Article 13 of the Terms of Service).
• Statistics and research: using only anonymised or aggregated data for statistics on service volume, cost ranges, and satisfaction, and making no medical determination concerning a particular individual.
• Processing we do not undertake: we do not sell personal information; we do not use your health information for advertising targeting or user profiling; we do not issue medical conclusions or diagnostic advice on the basis of this Platform's materials; and we do not refuse to provide basic Services because you exercise your data rights (except where otherwise provided by law or where performance of the Services genuinely requires it).

Article 6 Information We Obtain from Third Parties

• Social sign-in: where you log in with a third-party account such as Facebook, we obtain from that third party the name, e-mail address, and avatar that you have authorised it to disclose; if the e-mail address matches an existing account, it will be linked automatically to that account.
• Payment institutions: payment status, transaction reference numbers, and refund results returned by WeChat Pay and Alipay, used for order reconciliation.
• IP geolocation databases: inference of your country from public commercial geographic databases.
• Medical Institutions and partners: information published by hospitals concerning departments, physician consultation schedules, and fee standards; and service confirmations provided by partner institutions.
• Invitations and channels: where you register through another person's invitation code or through a channel link, we record the invitation relationship and the channel source for the issuance of points and for service tracking.

Article 7 Cookies, Similar Technologies and Usage Statistics

• Sessions and login: this Platform uses cookies to store your login session and security protection tokens (CSRF), and stores session state on the server side (in Redis and in session tables). Such cookies are necessary for the basic functioning of the website; if they are disabled, you will be unable to log in or to submit orders.
• Language and preferences: used to remember preferences such as the display language you have selected (Chinese, Mongolian, or English), so that you need not reset them at each visit.
• Access statistics: this Platform deploys Google Analytics (gtag.js, measurement ID G-19RLWYYJJ2) to measure page views, traffic sources, and performance, and that provider may process the relevant identifier information on servers outside China, for example in the United States. Such statistics do not constitute a medical assessment of you, and the contents of your medical records are not provided to that provider.
• No cookie-consent management platform has yet been deployed on this site. You may block or delete third-party cookies through your browser settings, use private-browsing mode or browser extensions (such as the official Google Analytics opt-out add-on) to limit statistics, or choose to log in and use the Platform only when you require the Services.
• We do not use persistent fingerprinting technologies that can identify you and that are stored locally on your device for a long period, and we do not, without consent, share your identifiable information with third parties for advertising purposes.

Article 8 How We Share, Entrust and Disclose Information

The Company does not sell, rent, or exchange your personal information. Except as set out below, the Company will not provide your identifiable personal information to third parties; before any such provision, where Sensitive Personal Information or a cross-border provision is involved, your separate consent will additionally be obtained (except in mandatory circumstances required by law).

• Medical Institutions and physicians (necessary to perform the Services): in order to complete registration, consultation, examinations, admission, and follow-up, we disclose the Patient's identity information, condition materials, and contact details to the relevant Medical Institutions and physicians. Those institutions are independent liable parties for their own diagnostic and therapeutic acts.
• Escort Staff (necessary to perform the Services): we disclose to the dispatched escort the minimum information necessary to perform the on-site Services (name, contact details, time and place of the visit, department, necessary key points of the condition, and document information). Escort Staff must sign a confidentiality undertaking, must return to you in full the paper materials you have delivered to them after the Services end, and must not retain, copy, or photograph them privately.
• Payment and financial services institutions: WeChat Pay, Alipay, banks, and similar institutions, for the purposes of collecting payments, issuing refunds, and making compliant payments to service personnel.
• Infrastructure and cloud services: server hosting, object storage (used for the storage of medical-record attachments, service photographs, and user content), content delivery networks, and backup services, using servers located principally in China, all of which employ access controls and transmission encryption.
• Translation and technical processing services: to help you communicate with Medical Institutions, we may use machine translation and text-processing services to handle and organise medical records, Care Plans, and communications. Such processing is used only for language conversion and information summarisation and is not relied upon as a basis for diagnosis, medication, or treatment; for important medical documents, a qualified translator or the formal documents of the Medical Institution shall be treated as controlling.
• Customer service and notification services: instant-messaging customer-service channels, e-mail dispatch services, and SMS channels, used solely to handle your enquiries and to send business notifications.
• Partners and agents: agents, channel partners, or service co-operating parties contracted by the Company for the completion of orders, to whom necessary information is provided to the extent that they assume equivalent confidentiality obligations.
• Disclosures required by law: we may disclose necessary information pursuant to laws and regulations, to rulings of courts or arbitration institutions, or to mandatory requirements of competent administrative or judicial authorities; where permitted by law we will then notify you, or will disclose only the minimum necessary content.
• Business transfers: in the event of a merger, division, acquisition, or asset transfer, the Company will require the transferee to remain bound by this Policy and will notify you before the change.
• Other than as set out above, we will not make your personal information (including mobile number, medical records, and visit records) publicly available. Information that has been anonymised such that no particular individual can be identified and that cannot be restored may be used for service improvement and statistical analysis.

Article 9 Access to Information by Escort Staff and Other On-Site Personnel

• Access permissions are configured on a role-based minimum basis: an escort may view only the necessary information of the orders dispatched to him or her personally; customer-service personnel may view full records only to the extent required to handle enquiries and dispute coordination; and access by back-office personnel is subject to audit records.
• Escort Staff are required, in the course of the Services, to shield documents when they are used and to prevent viewing by others; not to read or discuss your condition in public places such as corridors, lifts, and restaurants; not to photograph you, your medical records, or your examination reports without your express permission; to secure the documents you have delivered to them when resting or stepping away temporarily; and, after the Services end, to return in full all paper materials and not to retain, copy, or photograph them privately.
• Where an examination involving privacy is concerned (such as gynaecology, psychiatry, or infectious disease), or where you ask for privacy, Escort Staff will wait outside the consultation room and will provide only process assistance.
• If you find that an escort has breached the foregoing requirements, you may complain immediately (Article 18), and the Company will suspend his or her eligibility to accept orders and will investigate and handle the matter; in serious cases, the co-operation will be terminated and the matter will be referred to the authorities under law.

Article 10 Cross-Border Transfers

• The servers and the principal processing activities of this Platform are located within the territory of the People's Republic of China. Where a resident of Mongolia uses this Platform's Services, or where arrangements are made for treatment in China, your personal information (including contact details, itinerary, medical records, and document materials) will be transferred to servers within China for processing.
• That cross-border transfer is necessary for the performance of the care-assistance contract and is limited to the purposes and scope stated in this Policy. Other than the recipients listed in Article 8 and in this article, we will not forward the information further to other third parties; if any further forwarding is required, your separate consent will additionally be obtained.
• Where personal information is provided further to other countries or regions, the Company shall perform its duties of notification and of obtaining separate consent under applicable law and shall adopt protective measures such as encrypted transmission and access restriction. This Policy also describes the rights and remedies you enjoy, in cases of cross-border provision, under the Personal Information Protection Law of Mongolia and the Personal Information Protection Law of the People's Republic of China.
• You may, through the means set out in Article 13, request information about the specific circumstances of cross-border transfers (categories of recipients, purposes, and protective measures).

Article 11 Retention Periods and Deletion

• General principle: the Company retains personal information only for the period necessary to achieve the processing purposes, and deletes or anonymises it after that period expires.
• Account and contact details: retained for 12 months from the date on which your relevant Services end, for follow-up communication, settlement reconciliation, and dispute handling; upon expiry they are deleted automatically or anonymised (except where laws and regulations require a longer period). If you deregister your account earlier, the data will be deleted at your request, subject to the statutory retentions described below.
• Order, payment, and refund records: retained for the periods required by the E-Commerce Law of the People's Republic of China and other laws (in general not less than three years), for tax, audit, and consumer-dispute purposes; the purpose of retention is limited to compliance and dispute resolution.
• Medical records and examination materials (sensitive): the Company does not proactively retain medical-record originals for the long term. Where the materials you upload are used to compile Care Plans and to perform the Services, we will, after the relevant Services end and the follow-up period expires, delete them at your request, or delete them in accordance with the 12-month period under the item on account and contact details. Paper materials are returned on the spot by Escort Staff when the Services end, and escorts may not retain copies.
• On-site photographs and service records: only those necessary to verify service quality and to handle disputes are retained, and anything beyond that necessity shall be deleted; for content photographed with your consent, you may also request deletion at any time.
• Customer-service sessions and feedback: retained for 12 months from the end of the session or the completion of feedback handling; where complaints, dispute coordination, or regulatory requirements are involved, the period may be extended until 6 months after the matter is concluded.
• Logs and login auditing: general access logs and slow-request records are retained for approximately 30 days; login audit records are used for security traceability and are retained for no more than 12 months.
• Where deletion cannot be completed immediately as a matter of law or technology (for example on backup media), the Company will cease all processing other than storage and security measures and will complete deletion or anonymisation within the backup cycle.

Article 12 Security Measures We Adopt

• Transmission security: HTTPS is enabled across the entire site, so that public access and submissions occur within encrypted channels.
• Passwords and credentials: account passwords are stored as irreversible hashes, so that neither Company employees nor customer-service personnel can view your password in plain text, and form submissions use CSRF protection tokens.
• Access control: the back office divides permissions by role (administration, customer service, finance, hospital, and escort) and applies the minimum-necessary principle; repeated failed logins lock the account, and the login IP and device information are recorded for security review.
• Storage security: medical-record attachments, service photographs, and user content are stored in object-storage buckets with private read-and-write policies and time-limited temporary access links; servers and databases are backed up periodically, and access to backups is likewise subject to permission controls.
• Data classification and internal policies: tiered protection policies are established according to the sensitivity of the information; employees and co-operating service personnel bear confidentiality obligations and receive privacy and compliance training, and violators are dealt with under internal policies and bear corresponding liability.
• Processing restrictions: access by customer-service and back-office personnel to complete medical records is constrained by permissions and auditing, and statistics and analysis preferentially use anonymised or aggregated data.
• Shortcomings, which we also state truthfully: transmission and services in the internet environment cannot achieve absolute security, this Platform has not obtained third-party personal information protection certification, and no independent data protection committee has been established. If a security incident occurs, the Company will perform its notification and remediation duties in accordance with Article 16 and shall bear corresponding liability under law.

Article 13 Your Rights and How to Exercise Them

• You have the right to access the personal information about you held by the Company; to copy and to obtain a copy of your personal information free of charge; to rectify and supplement inaccurate or incomplete information; to delete unnecessary information; to restrict processing or to withdraw consent (including withdrawal of the authorisation for processing of your mobile number and of your medical materials); to deregister your account; to object to automated decision-making and to differential treatment; and to lodge complaints.
• Means of exercise: (i) view and modify your account information yourself in the "User Centre"; (ii) send an e-mail to [email protected], marking the subject line "Personal Information Rights Request" and stating the type of request; (iii) call the service hotline (Article 18) or contact the customer-service session to submit your request.
• To protect your security, the Company may verify your identity when accepting a request (for example by requiring a reply from your registered e-mail address or by asking for an order number). Where a request is unclear or exceeds what is necessary, we will ask you to provide further explanation or will act only on the parts that are clear.
• The Company will respond within 15 business days after receiving a request; where an extension is needed, it will state the reasons and the expected period. Where deletion is requested, the Company will simultaneously notify third parties entrusted with processing to cease use and to delete, except where this is technically infeasible, in which case the corresponding processing will cease.
• The Company may refuse a request and state its reasons in the following circumstances: the request is one that must be refused under law; deletion or rectification would prevent the Company from performing its legal obligations or from completing a contract already formed; the request concerns another person's information without that person's consent; or the request is manifestly repetitive, excessive, or without a legitimate basis.
• If you consider that the Company's processing of personal information infringes your lawful rights and interests, you may, in addition to complaining to the Company, complain under applicable law to a competent supervisory authority (such as the cyberspace administration or the market supervision and administration authorities in China, or the personal information protection authority of Mongolia), or bring an action before a competent court under law. You also have the right to claim compensation where damage is caused by the unlawful processing of personal information.
• In respect of the personal information of a deceased Patient, his or her close relatives may, within the scope of their own lawful interests or for the lawful interests of the survivors themselves, exercise under law the rights of access, copying, rectification, and deletion in respect of the relevant personal information (unless the deceased made other arrangements during his or her lifetime).

Article 14 Minors and Other Cases Requiring a Guardian's Consent

• This Platform does not offer standalone registration to children. Where the Patient is a minor, a person without capacity for civil conduct, or a person with limited capacity for civil conduct, his or her legal guardian or an accompanying adult shall register the account, give the consent, and submit the personal information.
• Where surgery, anaesthesia, invasive examinations, or similar matters require a statutory representative to sign medical documents, those documents must be signed personally by the guardian or by a person entitled to do so under law, and this Platform and Escort Staff shall not sign on anyone's behalf (see Article 3 of the Terms of Service).
• Guardians shall ensure that the information submitted is true, complete, and consistent with the interests of the person under guardianship. Where a guardian finds that the Platform processes a minor's information inappropriately, the guardian may request rectification or deletion under Article 13.

Article 15 Information You Publish and Publicly Visible Information

• When you publish patient stories, reviews, or feedback, the relevant content may be displayed publicly on the website or on official social-media accounts after review by the Company. Please do not include in published content another person's medical records, diagnostic reports, document information, or other personal information of a third party.
• You may choose to publish anonymously; the Company will hide identity-revealing information in accordance with your choice and may redact medical records, faces, and similar elements in images.
• Once shared, published content may be indexed by search engines. You may at any time request the modification or removal of content published by you; the Company will act within a reasonable period and will cease new displays, but cannot guarantee the complete elimination of parts already archived, backed up, or scraped by third parties.
• In reviewing and displaying content you publish, the Company observes the principles of lawfulness, legitimacy, and necessity, and does not treat such review and display as a basis for commercially using your health information.

Article 16 Notification of Personal Information Security Incidents

• The Company maintains an incident-response procedure: upon discovering or becoming aware of a leak of, tampering with, or loss of personal information, or any other personal information security incident, it will immediately commence handling, take measures such as stopping the leak, restricting access, repairing vulnerabilities, and preserving evidence, and assess the scope affected and the harm that may result.
• In accordance with applicable law, the Company will promptly report to the departments performing personal information protection duties and will notify affected users of the basic facts of the incident, the possible impact, the measures already taken or to be taken, recommendations for preventing and reducing harm, and the Company's contact details, by e-mail, SMS, on-site announcement, and telephone.
• Where the measures taken by the Company can effectively prevent harm (including unlawful acquisition or malicious use of the information), the obligation to notify each person individually may be dispensed with under law; provided that where the competent authority considers that harm may nevertheless result, notification will still be made as required.
• Notification may fail to reach you because the contact details you provided are no longer valid, so please keep your e-mail address and mobile number valid (see Article 17 of the Terms of Service).

Article 17 Updates to This Policy

• The Company may revise this Policy according to changes in law, business development, and technology. The revised Policy will be published on this page with the "last updated date" indicated at the top of the page, and material revisions will apply to Services formed from 7 days after publication onwards.
• For material changes concerning the manner of handling Sensitive Personal Information, the recipients of cross-border transfers, or the way in which you exercise your rights, the Company will notify you by on-site announcement or by the e-mail address you have provided; if you continue to use the Services or to place orders after such notice, you shall be deemed to have accepted the change.
• If you do not accept the change, you may cease use and request deletion of the corresponding personal information under Article 13; for orders formed before the change and not yet fully performed, you may still require the relevant data to be handled under the rules of the prior version of this Policy, except where processing is necessary to comply with new legal obligations.
• The Company retains historical versions for verification purposes, and you may request a historical version of this Policy in order to compare the differences.

Article 18 Contacting Us and Personal Information Protection Matters

• Person responsible for personal information protection matters (who may receive data-rights requests and complaints): the Company's operations department, e-mail [email protected]; please mark the subject line "Personal Information Request" or "Complaint".
• Service hotline (within China): +86 15764815555; service hotline (within Mongolia): +976 80482609
• Company name: Inner Mongolia Mingyan Health Management Service Co., Ltd.; place of business: Xincheng District, Hohhot, Inner Mongolia Autonomous Region, China
• Website and filing: https://iveelvita.com , ICP Filing No. Meng ICP Bei 2025026867; Facebook page: https://www.facebook.com/iveelvita
• We will respond within 15 business days after receiving your request; for urgent matters involving personal safety or medical risk, please call the service hotline first and simultaneously contact local emergency services and Medical Institutions.