Privacy Policy


Privacy Policy

The Fivelements Habitat is operated by Evolution Wellness (Hong Kong) Limited., with a business address at Unit 916, 9/F, Lippo Sun Plaza, 28 Canton Road, Tsim Sha Tsui, Hong Kong ("The Company"). The principal objective is to provide health and leisure facilities for Centre Members and their Guests. The Fivelements Habitat is where a member joins or visits most frequently. The Company has appointed a Management tea m ("The Management"), who are responsible for the operation of The Habitat.
Provision of Personal Data

a) The Company recognises the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

b) You understand, acknowledge and consent to the Company processing, collecting and using your personal data for the following purposes:

(1) processing, administering and managing your Friend of Fivelements Contract;

(2) processing any transactions or payments made by you and to maintain payment records;

(3) contacting you or communicating with you via telephone call, text message, fax message, email and/or postal mail for the purposes of processing, administering and managing your Friend of Fivelements Contract ;

(4) for publicity purposes and conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance the services we provide to you, where you have consented for the Company to do so;

(5) record-keeping purposes;

(6) responding to legal process, pursuing legal rights and remedies, defending litigation and managing any complaints or claims;

(7) complying with any applicable law, regulation, legal process or government request; and

(8) storing, hosting and/or backing up (whether for disaster recovery or otherwise) your personal data, whether within or outside Hong Kong

c) Your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Hong Kong or outside of Hong Kong, for one or more of the purposes set out above:

(1) the Company's head office, affiliates and subsidiaries;

(2) any of the Company's agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those third party service providers which have been engaged by the Company to : (I) to provide and maintain any IT equipment used to store and access your personal information; (II) to operate the; or (III) otherwise in connection with the provision of Fivelements services to you;

(3) the Company's auditors and legal advisors;

(4) financial institutions, credit card companies and payment processors; and

(5) public and governmental / regulatory authorities, courts and other alternative dispute forums.

d) Further details on how the Company collects, uses and/or discloses your personal data can be found in our Privacy Policy available at

e) Data relating to Friend of Fivelements Cardholders or guests may be used for processing services, collection of Dues, locker fees, service fees and other payments required under the Rules or used in connection with the operation of the Fivelements Habitat and any ancillary or related purpose thereto.

f) The Fivelements Habitat may provide and transfer such data to any other Centre of the Company, the Company or any member of the Company's Group, any agent, collection agency, contractor or person who provides administrative, telecommunications, computer and other services to the Fivelements Habitat in connection with the operation of the Fivelements Habitat business. As a Friend of Fivelements Cardholder, you have the right to request access to and correct your personal data held by the Fivelements

g) The Fivelements Habitat in relation to you, upon payment of a reasonable processing fee, and you can make such requests to your Fivelements Habitat of enrolment.

h) If you have once accept to give us and use of your personal data, you may receive from us from time to time administrative news, direct marketing telephone calls, emails, SMS, direct mailings or other means, the same of which contain promotional materials. You may opt-out from receiving marketing communications at any time, free of charge, by:
Sending us a written request by:
I) Email to:
II) Updating your communication preferences at our front counter

The Company's officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company. The Company shall endeavor to ensure all collection and/or storage and/or transmission and/or usage of personal data by the Company shall be done in an appropriate manner for membership applications, and internal purposes. Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in an appropriate time and manner.

Types of Personal Data Collected:

For the purpose of carrying on the Company's business, including registration and administration of the Company's related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:

  • Your name;
  • Correspondence address, and/or billing address;
  • Payment details, including credit card and banking information;
  • Contact details, including contact name and telephone number or email address;
  • Your image taken at our premises with a web cam (or like equipment) for visual identification

Fivelements may employ other companies or individuals to assist us in providing our services, or to provide certain services such as analysing customer lists, providing marketing assistance or consulting services. These third parties may have access to information needed to perform their function but cannot use that information for other purposes.

In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:

  • Your age;
  • Gender;
  • Salary range and employment details;
  • Education and Profession;
  • Hobbies and leisure activities;
  • Other related products and services subscribed to; and
  • Family and household demographics.

Some of the Company's Websites may place a "cookie" on your machine; for example to provide personalised services and/or maintain your identity across multiple pages within or across one or more sessions. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across our Websites.

Under certain circumstances, telephone calls made to our order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. Unless expressly indicated at the time of calling, such recordings are NOT personal data of the caller and therefore, in respect of the caller, are not subject to the various provisions of the Ordinance and the caller has no rights and/or claims; either statutory, contractual or tortuous, over or to such data. At all times, every care is taken to protect such recordings from inadvertent and/or unauthorized access.

Where possible, we will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use the personal data such as with Personal Identifiers and/or proof of address.

Fivelements will endeavour to take all reasonable steps to keep secure any personal information recorded, and to keep this information accurate and up to date. The information is stored on secure servers if in digital format, or in locked areas if in hard copy format: these repositories are protected in controlled facilities. In some cases these facilities may be overseas.

Fivelements employees and data processors are obliged to respect the confidentiality of any personal information held by Fivelements. However, security of communications over the Internet cannot be guaranteed, and therefore absolute assurance that information will be secure at all times cannot be given. Fivelements will not be held responsible for events arising from unauthorized access to personal information.

The Company will destroy any personal data it may hold in accordance with our internal retention policy. The policy states that:

Personal data will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and

Personal data are purged from the Company's electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company's internal procedures.

All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:

Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;

Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided;

Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information; and

Any financial institutions, charge or credit card issuing companies, credit information or reference bureau, or collection agencies necessary to establish and support the payment of any services being requested. Personal data may also be disclosed to any person or persons that have a right under Hong Kong law to gain access to such information provided they are able to prove their authority to access such information. For example, if the Company were served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.

At times it may be necessary and/or prudent for the Company to transfer certain personal data to places outside of Hong Kong in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done so in accordance with local legislation such as the Personal Data Protection Act 2010.

Physical records containing personal data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a "need to know" basis that is commensurate with an individual's Company responsibilities and their training. Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate. Audit records may be produced to validate data modifications in order to verify the data's integrity. There may be violations logging processes for investigation of any unauthorized attempt to access information. Encryption technology, such as SSL, may be employed for the transmission of data collected online.

Individuals have the right to:

1. Check whether the Company holds any personal data relating to them and, if so, obtain copies of such data;

2. Require the Company to correct any personal data relating to them which is inaccurate for the purpose for which it is being used.

The Company will honor an individual's request not to use his or her personal data for the purposes of direct marketing. Any such request should clearly state details of the personal data in respect of which the request is being made. Specifically, we request that you include the corresponding Company assigned account numbers which are printed on the Company's statements/invoices. Please also state clearly the authority under which you are authorized to make such a request. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for marketing purposes.

Fivelements provides links to web sites outside of the Fivelements site. These linked sites are not under the control of Fivelements, and Fivelements is not responsible for the conduct of companies linked to the Fivelements web site, nor for the performance or otherwise of any content and/or software contained in such external websites.

Fivelements reserve the right to alter any of the clauses contained herein in compliance with local legislation, to meet its global policy requirements, and for any other purpose deemed necessary by the Company.