English
Mesura Health — Personal Data Protection Notice (PDPA 2010)
Data user: Vast Dynamic Ltd, trading as Mesura Health — a Hong Kong company, registration number 77131343, registered address Level 9, Amtel Building, 144-148 Des Voeux Road Central, Hong Kong ("Vast Dynamic Ltd", "Mesura") Data protection contact: the Data Protection Officer, support@mesura.health, or by post to the registered address above
This notice is issued under the Personal Data Protection Act 2010. It applies from the moment you first contact the programme, and before any personal data is collected.
Mesura is a Hong Kong company, so your data is controlled from outside Malaysia. We apply the PDPA to your data and give you the rights in §5 regardless, and you may complain to the Malaysian Commissioner at any time. See §3 on transfers.
1. What we collect
Your name, WhatsApp number and language preference; your answers to health assessment questions (height, weight, screening questions); your messages on the programme channel; your self-reported measurements during care; care events from our partner clinic; and payment records (never card numbers). Your health information is sensitive personal data and is processed only with your explicit consent. We do not collect your NRIC, ID documents or photos. Data is collected directly from you, and from the partner clinic for your care.
2. Why
To assess your suitability and run your care programme; to keep you safe (message screening and escalation to your care team); to coordinate with the partner clinic and pharmacy; to bill you; to improve the service (de-identified); and to meet legal obligations. Optional, separate consents — never required for care: direct marketing (s.43); inclusion of your de-identified data in published research.
3. Who it is disclosed to
The partner clinic providing your care, and its pharmacy; our service providers — WhatsApp business messaging (respond.io; Meta/WhatsApp), our payment provider (Airwallex), cloud hosting, and WellTech Health as our platform operator/processor; and authorities where the law permits or requires. The full list and safeguards are in the Privacy Policy. We never sell your personal data.
On AI: the programme uses AI to draft routine replies, route messages and prepare summaries for your doctor. It runs on a model operated by the partner clinic, on the clinic's own infrastructure in Malaysia — your messages are not sent to any external AI company and are not used to train anyone's models.
Transfer outside Malaysia — please read. Because Mesura is a Hong Kong company, your personal data is transferred out of Malaysia to Hong Kong as a normal part of running your programme, and our service providers process it in other countries too. By consenting you agree to that transfer. Your clinical record held by the partner clinic remains in Malaysia.
4. Whether you must provide it
Providing the data in §1 (other than the optional consents) is obligatory to receive the service — without it we cannot assess you, your doctor cannot treat you safely, and the pharmacy cannot dispense. If you choose not to provide it, we will not collect any health information and the programme cannot proceed.
5. Your rights, and how to use them
Write to the data protection contact above, message us on the programme channel, or use the contact page at mesura.health — you do not need to write a formal letter to exercise a right. We will verify your identity before acting.
- Access (s.30): request a copy of your personal data. We respond within 21 days, and we do not charge a fee — the PDPA allows one, and we have chosen to waive it.
- Correction (s.34): have inaccurate, incomplete, misleading or out-of-date data corrected. Corrections supersede the record; originals are preserved in the audit trail.
- Withdraw consent (s.38): at any time, without reason. We then stop processing and cease the data exchange with the clinic. We retain only what the law requires: the clinic's statutory medical record, our consent and audit records, and records held per the retention schedule; the rest is quarantined. Withdrawal during treatment is handled safely — see the Medical Consent §7.
- Prevent processing likely to cause damage or distress (s.42).
- Stop direct marketing (s.43): immediate effect; never affects your care.
Timelines: access and correction within the statutory 21 days; every other request acknowledged within 2 working days and answered within 14 days.
6. Complaints
Complain to the data protection contact above first if you wish — but you may complain at any time to the Personal Data Protection Commissioner (Jabatan Perlindungan Data Peribadi, JPDP). Clinical-conduct complaints go to the Malaysian Medical Council.
7. Retention and security
Data is kept per our retention schedule (clinical/programme records per medical-record retention rules — 7 years; payment records 7 years per tax law; marketing data until you withdraw).
What happens at the end of that period, stated plainly. Our records are held in an append-only system: entries can be added but not altered or erased. That is deliberate — it is what makes your care record and our audit trail trustworthy, and it is why we can show you exactly what was done and when. The consequence is that we quarantine rather than delete: at the end of retention, and immediately if you withdraw consent, the record is closed to all operational use. Nothing is served, messaged, analysed, exported or acted on from it. It can only be reopened through a restricted route that itself records who opened it and when. Marketing contact data is deleted from our marketing systems when you withdraw.
We would rather tell you this than claim a deletion we cannot perform.
Your data is protected by access controls, encryption in transit, append-only audit logging, and consent-gated data flows; breaches are notified to the Commissioner and to you as the PDPA (as amended) requires.
This notice is issued in English and Bahasa Malaysia. The Bahasa Malaysia text follows below in this same document. The notice is drafted in English and the Bahasa Malaysia text is a translation of it; if there is any inconsistency between the two, the English version prevails.**

