1. Introduction

Institute for Functional Nutrition Limited (“we”, “us”, or “our”), the operator of hracpro.com (the “Website”), is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our Website, register for events, enquire about our services, or otherwise interact with us.

This Website is operated for marketing purposes and is affiliated with Health Risk Assessment Centre (hracentre.com) and Nu Life International (Asia) Limited (nulife.com). By using this Website, you acknowledge that you have read and understood this Privacy Policy.

We are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and any other applicable data protection legislation.

 

2. Who We Are

Data Controller:

• Company Name: Institute for Functional Nutrition Limited
• Address: Room 1533, Star House, No. 3 Salisbury Road, Tsim Sha Tsui, Kowloon, Hong Kong
• Company Registration No.: 1901698 (Hong Kong)
• Email: support@hracentre.com
• Phone: +852 3462 6633
• Website: https://hracpro.com/

 

3. What Personal Data We Collect

We may collect the following categories of personal data:

 

3.1 Data You Provide Directly

• Full name
• Email address
• Phone number
• Event attendance preference (Zoom or In Person)
• Nu Life membership status (whether you are or know a Nu Life member)
• Referral name (if you know a Nu Life member)

This data is collected through forms on the Website, including the Event Sign Up form and the Contact form on the homepage and Membership page.

 

3.2 Data Collected Automatically

When you visit our Website, we and our third-party service providers may automatically collect:

• IP address and approximate geographic location
• Browser type and version
• Device type and operating system
• Pages visited and time spent on each page
• Referral source (how you arrived at our Website)
• Clicks, scrolling behaviour, and interaction patterns
• Cookie identifiers and tracking pixel data

 

3.3 Data from Third-Party Platforms

If you interact with our advertising on Facebook or Instagram (Meta platforms), we may receive data about your interaction with those ads through the Meta Pixel installed on this Website, subject to Meta’s own privacy policies.

 

4. How We Collect Your Data — Technical Systems

The following tools and systems are used to collect, process, and manage your data:

 

4.1 Website Forms (Elementor Pro)

Our Website forms are built using Elementor Pro. When you submit a form, your data is transmitted via a secure Webhook to Zoho Flow, which then routes it into our CRM system (Zoho CRM). This replaces any manual data handling and ensures your data is captured accurately and immediately.

 

4.2 Zoho CRM & Zoho Flow

All personal data submitted through our Website forms is stored and managed in Zoho CRM, operated by Zoho Corporation. Zoho Flow is used as an automated integration layer to route data from our Website forms into Zoho CRM. Data held in Zoho CRM may be used by our team to follow up on your enquiry, confirm your event registration, or manage your membership journey.

 

4.3 Meta Pixel (Facebook Pixel)

We use the Meta Pixel on our Website. This is a piece of code that allows us to measure the effectiveness of our advertising campaigns on Facebook and Instagram, understand user behaviour on our Website, and build custom audiences for retargeting purposes. The Meta Pixel may collect data about your activity on our Website and associate it with your Facebook profile if you are logged in. You can manage your Facebook ad preferences at: https://www.facebook.com/ads/preferences/

 

4.4 Google Services (Google Site Kit)

We use Google Site Kit, which integrates the following Google services on our Website:

• Google Analytics: Collects anonymised data about Website traffic and user behaviour to help us understand how visitors use the site.
• Google Tag Manager: Manages tracking tags and scripts deployed on the Website, including the Meta Pixel and other measurement tools.
• Google Ads: Enables conversion tracking for any Google advertising campaigns we may run.

Data collected through Google services may be processed by Google LLC in the United States and other countries. For more information, see Google’s Privacy Policy at: https://policies.google.com/privacy

 

4.5 Zoho PageSense

We use Zoho PageSense for website analytics, heatmaps, A/B testing, and conversion optimisation. PageSense may record anonymised data about how users interact with pages on our Website, including click patterns, scroll depth, and session recordings. No personally identifiable information is used in this process.

 

4.6 Newsletter Subscription

If you subscribe to our newsletter via the sign-up form in the Website footer, your email address will be collected and used to send you blog updates and health-related communications. You may unsubscribe at any time using the link included in every email.

 

5. How We Use Your Personal Data

We use the personal data we collect for the following purposes:

• To process and confirm your event registration
• To send you event reminders and follow-up communications via email and/or WhatsApp
• To respond to your enquiries and provide information about our services and membership
• To send you marketing communications about upcoming events, health talks, and relevant services (where you have consented or where we have a legitimate interest)
• To measure and optimise the performance of our Website and advertising campaigns
• To build retargeting audiences on Meta platforms (Facebook and Instagram) to show you relevant advertising
• To conduct A/B testing and continuous improvement of our Website pages
• To comply with our legal obligations
• To manage our internal records and CRM database

 

6. Legal Basis for Processing

Under the PDPO and applicable data protection principles, we process your personal data on the following bases:

• Your consent, where you have expressly agreed to the processing (e.g. by submitting a form or subscribing to our newsletter)
• Legitimate interests, where processing is necessary for our legitimate business interests and does not override your rights (e.g. website analytics, marketing performance measurement)
• Contractual necessity, where processing is required to fulfil a request you have made (e.g. event registration)
• Legal obligation, where we are required to process your data to comply with applicable law

 

7. How We Share Your Data

We do not sell your personal data. We may share your data with the following categories of third parties, strictly for the purposes described in this Policy:

 

• Zoho Corporation: CRM and workflow automation (Zoho CRM, Zoho Flow, Zoho Campaigns, Zoho PageSense)
• Meta Platforms, Inc.: Advertising performance measurement and audience retargeting via Meta Pixel
• Google LLC: Analytics, tag management, and advertising via Google Site Kit
• Health Risk Assessment Centre (hracentre.com): Our affiliated health centre, whose professional team delivers the services and events promoted on this Website
• Nu Life International (Asia) Limited: Our affiliated partner organisation, whose products and membership programme are promoted on this Website
• Authorised service providers: Third-party vendors who assist us in operating our Website and delivering our services, bound by confidentiality obligations

All third-party service providers are required to handle your data securely and in accordance with applicable data protection law.

 

8. International Data Transfers

Some of our third-party service providers (including Zoho, Google, and Meta) may process your data outside Hong Kong, including in the United States, India, and the European Union. Where such transfers occur, we take steps to ensure appropriate safeguards are in place in accordance with the PDPO.

 

9. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. In general:

• Event registration data: retained for up to 24 months following the event
• Contact and enquiry data: retained for up to 24 months from the date of last contact
• Newsletter subscriber data: retained until you unsubscribe
• Analytics data: retained in accordance with the policies of the relevant platform (Google, Zoho)

When data is no longer required, it is securely deleted or anonymised.

 

10. Your Rights

Under the PDPO and applicable data protection law, you have the following rights in respect of your personal data:

• Right of access: You may request a copy of the personal data we hold about you
• Right of correction: You may request that we correct any inaccurate personal data
• Right to opt out of direct marketing: You may, at any time, request that we cease using your data for direct marketing purposes
• Right to withdraw consent: Where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal

To exercise any of these rights, please contact us at:

• Email: support@hracentre.com
• Post: Room 1533, Star House, No. 3 Salisbury Road, Tsim Sha Tsui, Kowloon, Hong Kong

We will respond to your request within 40 days, in accordance with the PDPO.

 

11. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These include the use of secure data transmission (HTTPS), access controls, and reputable third-party platforms with industry-standard security certifications.

However, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security and encourage you to be mindful of the information you share online.

 

12. Children’s Privacy

Our Website and services are not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe we have inadvertently collected data from a child, please contact us immediately and we will take steps to delete it.

 

13. Links to Third-Party Websites

Our Website may contain links to third-party websites, including hracentre.com and nulife.com. We are not responsible for the privacy practices of those websites and encourage you to review their respective privacy policies.

 

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised effective date. We encourage you to review this Policy periodically. Continued use of the Website following any changes constitutes your acceptance of the updated Policy.

 

15. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or how we handle your personal data, please contact us:

 

Institute for Functional Nutrition Limited

• Address: Room 1533, Star House, No. 3 Salisbury Road, Tsim Sha Tsui, Kowloon, Hong Kong
• Email: support@hracentre.com
• Phone: +852 3462 6633
• Website: https://hracpro.com/

 

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong:

• Website: https://www.pcpd.org.hk/
• Phone: +852 2827 2827