Personal Data Privacy Policy

Last updated April 1, 2020.

Introduction: Purpose, scope, and users

Intuitive Fosun, with locations including Intuitive Surgical-Fosun (Hongkong) Co., Limited, Unit 3301B-03, 33/F, AIA Tower, No. 183 Electric Road, North Point, Hong Kong (hereinafter also referred as: “Intuitive Fosun”, or “we” or “us”) conducting business within Hong Kong or processing the personal data of data subjects within Hong Kong understands the importance of privacy to our customers, visitors and suppliers, business partners, employees and other individuals (hereinafter also referred as: “you” or the “user” or the “data subject”). We are committed to safeguarding your privacy. We collect and store information (non-personal information and personal information or personal data) so that we can efficiently provide our products and services and support your interest in our products.

This Privacy Policy describes what kind of data we collect and how we handle the information that you provide to us and the basic personal data processing principles we adhere to.

Please contact us at with any questions.

We are committed to conduct our business in accordance with all applicable data protection legislation/regulations of all relevant jurisdictions, including The Personal Data (Privacy) Ordinance (the "PDPO").

Legal mention

Please ensure You read this Privacy Policy before using the Intuitive Fosun websites or submitting information to us.

This Privacy Policy is subject to change from time to time, so please review this Policy each time you visit the website. Your use of this website is subject not only to this Privacy Policy, but also to this site's Terms of Use, medical advice disclaimer, training disclaimer, and the other documents linked from our Legal page. Please read the above mentioned terms and documents. By accessing and using this website or any of our other websites through this website, and by providing us with your information, you agree to the practices described in this Privacy Policy.

The information we collect and how we handle it depends on the data type and what you do when you use our services and products. We only use the information required to successfully provide the products and services requested and only for the purposes you agreed with. Therefore, to protect your safety, you should not provide Intuitive Fosun with any personal information that is not specifically requested.


We do not sell or rent your personal identifying information or medical information to any third party. We may contract with reputable vendors to assist us in processing information or delivering the items that our customers order. These vendors are restricted from using or selling the information for any purpose, other than helping us to provide the products and services.

Information (non-personal and personal data)

Non-personal information

Non-personal data is information that does not identify you directly or indirectly as an individual person that we collect to help us understand how you use our services and products, as well as to protect and enhance them. It includes essentially the following:

  • Browser type and browser name and language used
  • Computer type
  • Access time and date of our website
  • The web page from which you came directly to our website
  • The web page(s) you access during your visit
  • Other web server log files (links clicked, terms searched, and anonymized or disconnected information that no longer allows to identify directly or indirectly the user

Personal information or personal data

Personal data is any information that identifies you directly or indirectly as an individual. It includes, but is not limited to: name, address, email address, phone number, identification number, location data, online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Definition of “personal data” may differ across jurisdictions and applicable laws and regulations.

We collect certain personal information, such as:

  • Personally identifying information (such as your name, street or email address, phone number, or similar information)
  • Unique identifiers and preference information
  • Professional activity linked to utilization of Intuitive Fosun products, including utilization of da Vinci surgical systems or training history

Intuitive Fosun products and services may also collect certain personal information. You may find out more information about that collection in their associated privacy policies, notices, and terms of service, or by looking for the associated notice at

Automated data collection


We use different types of “cookies” as part of data collection.

Essential cookies are required for the proper functioning of the site and may be used to:

  • Remember previous actions when navigating back to a page in the same session
  • Manage and pass security tokens to different services within the website to identify a visitor’s status
  • Maintain tokens for the implementation of secure areas of the website.
  • Route customers to specific versions/applications of a service, such as what might be used during a technical migration

Non-essential cookies are not required for the proper functioning of the site, and may be used to:

  • Track and store data about visits
  • Track and store visitor information
  • Record session details and page traffic
  • Customize and retarget contacts based on behavioral and demographic data

We use Google Analytics and Lucky Orange tracking codes to help analyze how visitors interact on our websites. If you would like more information about this practice and your choices about how this information is used, please visit Google Analytics and Lucky Orange.

Social networks

Links to our LinkedIn page are provided on some web pages.

Purpose for information collection

Processing of personal information is lawful and where applicable is based on at least one of the following grounds:

  • Consent
  • Fulfilling a contractual obligation
  • Complying with a legal obligation
  • Protecting any data subject’s vital interests
  • Legitimate interests of Intuitive Surgical when balanced against the rights and interests of the data subject
  • Other regionally appropriate basis

Conditions for consent

Where there is a need to request and receive your consent prior to collection, processing and transfer, Intuitive Fosun is committed to seeking such consent and obtaining it in line with the conditions set by the applicable data protection legislation/regulations.

Your (control) rights

Under the applicable data protection legislation/regulations, you have various rights in connection with the processing of your personal information.

Intuitive Fosun shall strictly uphold your rights and is responsible for implementing adequate procedures and policies to effectively protect your rights and monitoring compliance with applicable data protection laws and regulations. We will respond and provide information upon request without undue delay and in any event within the legally required timeline for your jurisdiction. That period may be extended where possible by local law.

As data subjects, your rights may include the following, depending on your jurisdiction and applicable laws:

Right to be informed

Where personal information is collected from you directly, Intuitive Fosun will ensure that you will receive all the information required at or before the time your personal information is obtained.

Right of access

We ensure that upon request, as available in your jurisdiction, access to your personal information will be granted and the regionally appropriate information will be provided, such as:

  • The specific pieces of personal information that are being held;
  • The purposes of processing;
  • The categories of personal information concerned;
  • The recipients or categories of recipients to whom the personal information has been or will be disclosed, in particular, recipients in third countries or international organizations;
  • Where possible, the envisaged period for which the personal information will be stored or, if not possible, the criteria used to determine that period;
  • The existence of the right to request from Intuitive Fosun rectification or erasure of personal data or restriction of processing of personal information concerning the data subject or to object to such processing;
  • The right to lodge a complaint with a Data Protection Authority;
  • Where the personal information is not collected from you, any available information as to their source; and
  • The existence of automated decision, if any – making, including profiling and meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing.

Right to rectification

You have the right to ask for rectification of any inaccurate personal data that concerns you and as appropriate, we will ensure that any inaccurate or incomplete information is erased, amended or rectified.

Right to erasure

In some jurisdictions, you may have the right to have your personal data erased, e.g. if any of the following apply in your region:

  • The data is no longer needed for its original purpose and no new lawful purpose exists;
  • The lawful basis for the processing is consent, your withdraw that consent, and no other lawful ground exists;
  • You exercise the right to object, and we have no overriding grounds for continuing the processing;
  • The data has been processed unlawfully; or
  • Erasure is necessary for compliance with European Union law or national law.

We will communicate any erasure of personal data to each recipient to whom the data has been disclosed, unless this proves impossible or involves a disproportionate effort.

Right to restriction of processing

As a data subject, you have the right to request the restriction of processing of your personal data if:

  • The accuracy of the personal data is contested (and only for as long as it takes to verify that accuracy);
  • The processing is unlawful (and you request the restriction of processing instead of the erasure of your personal information);
  • We no longer need the personal data for the original purposes of the processing, but still need it for the establishment, exercise or defense of legal claims; or
  • There is a verification of overriding grounds pending in the context of an erasure request.

Right to data portability

When available, the right to data portability allows you to receive the personal data you have provided to us, in a structured, commonly used and machine-readable format, and to transmit those data to another controller.

Right to object

When available, where processing is justified on the basis of legitimate interests, you may object to such processing, including profiling, unless Intuitive Fosun is in a position to demonstrate that compelling legitimate grounds, which override your interests, rights and freedoms, exist for the processing or for the establishment, exercise or defense of legal claims.

Profiling and automated decision-making

When available, where decision-making, including profiling, is based solely on automated processing and produces legal effects that concern you or similarly you are significantly affected by it, you have the right to object not to be subject to such a decision.

We do not base decision making or profiling solely on automated processing; human involvement ensures that the collaborators have the authority and competence to change the decision that concerns your personal information.

Data sharing and transfers

Intragroup transfers of personal data

Intuitive Surgical may transfer personal information to other entities.

Personal data transfers to third countries

Any transfer of personal information which is undergoing processing or is intended for processing after it is transferred to a third country or international organization requires special consideration and shall be carried out in compliance with local data protection legislation/regulations.

For example, as a general rule, in accordance with the GDPR, personal information shall be transferred outside the EU only if adequate safeguards are in place ensuring the same level of data protection as guaranteed under the GDPR. In addition, member states are, unless the transfer is based on an adequacy decision (see below), entitled to restrict the transfer of specific categories of personal data under their national laws.

Pursuant to the GDPR, each Intuitive Surgical entity which is subject to the GDPR shall, amongst other things, ensure that one of the following safeguards are in place when transferring data to a recipient in a third country (i.e. Non-EU country):

  1. Adequacy decision. Personal data may be transferred if the European Commission has decided that the relevant third country or international organization ensures an adequate level of protection. The list of adequate countries can be found below:
    • Andorra
    • Argentina
    • Canada
    • Switzerland
    • Faroe Islands
    • Guernsey
    • Israel
    • Isle of Man
    • Jersey
    • New Zealand
    • Uruguay
  2. Appropriate safeguards. Personal data may be transferred if one of the following appropriate safeguards are in place:
    1. Binding corporate rules for intra-group transfers;
    2. Standard data protection clauses adopted by the European Commission or adopted by a Data Protection Authority and then approved by the European Commission;
    3. Approved code of conduct together with binding and enforceable commitments by the third country entity to apply appropriate safeguards;
    4. Accredited GDPR certification mechanism together with binding and enforceable commitments by the third country entity to apply appropriate safeguards; or
    5. Contractual clauses between the relevant Intuitive Surgical entities and the third country entity authorized by the Data Protection Authority.

Currently, Intuitive Surgical entities perform intragroup transfers of personal data on the basis of an adequacy decision or on the basis of standard contractual clauses (SCCs) and certifies to the Privacy Shield. You may find more information about our Privacy Shield certification in our Privacy Shield Policy.


Intuitive Fosun has implemented technical and organizational security measures to protect your personal data from loss, misuse or unauthorized access, disclosure, deletion or modification. It includes, among other mechanisms, secured back-up and archiving servers, access control, firewalls or encryption.

Unfortunately, however, no data transmission over the Internet is certain to be 100% secure. As a result, while we strive to protect this information, we cannot guarantee its security.


We understand the need to protect children's privacy online (we define "children" as minors younger than 13 years of age). We do not knowingly collect or use any personal information from children. We do not knowingly allow children to register with us, order our products, communicate with us, or to use any of our online services. If you are a parent or guardian of a child and you become aware that he or she has provided us with personally identifying information without your consent, you should contact us at If we become aware that a child has provided us with personally identifying information, we will delete this information from our records.


If you have any questions about this Privacy Policy and your rights, please contact Intuitive Fosun using the below details. As mentioned above, we will address your request without undue delay and in any event within the legally required timeline for your jurisdiction. That period may be extended where possible by local law.

Hong Kong Office

Intuitive Surgical-Fosun (Hongkong) Co., Limited
Unit 3301B-03, 33/F,
AIA Tower, No. 183 Electric Road,
North Point, Hong Kong

Data retention and destruction

In principle, we will retain your personal data for as long as reasonably necessary for our legitimate business purposes. Personal information must be kept to be available for legal or regulatory compliance. Retention deadlines vary depending on the type of data and the need to delete obsolete data is assessed on a case-by-case basis.

We are responsible for the secure destruction of personal information once the necessary period that was required to achieve the processing purpose ends. Such destruction must be done through a specific procedure and in order to be secure and avoid potential unlawful data processing, for instance any disclosure to Third Parties, appropriate control mechanisms to monitor the data destruction procedure are in place

Privacy Policy revision

This Privacy Policy is subject to change at any time, so please check back periodically. If significant changes are made in how your personal data is collected, processed or shared, this Privacy Policy will be updated and an alert will be displayed on our website. If required by law, we will seek your consent prior to any significant change.

Our Data Privacy Officer is responsible for the maintenance and accuracy of the present Privacy Policy. This policy shall be reviewed at least annually or more frequently, as appropriate, by the Data Privacy Officer.

Any inquiry regarding the present Privacy Policy can be addressed to

The policy effective date is at the top of this page.