Privacy Policy

1. Purpose and Scope

This Privacy Policy (“Policy”) sets out the principles and practices adopted by the mobile application (“App”) in relation to the collection, use, processing, storage, transfer, and deletion of personal data of elderly subscribers (“Subscribers”). The App is committed to complying with the requirements of the  Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong  (“PDPO”) and to safeguarding the privacy and personal data of all Subscribers.

This Policy applies to all services provided within the App, including but not limited to:

• Collection and monitoring of health metric data;
• Medical consultation services via external practitioners;
• Medical analysis services via external institutions;
• Entertainment, gaming, and social networking features;
• Payment gateway and Octopus card integration; and
• Communication and data sharing with relatives or designated persons.

2. Consent to Collection and Processing

• 2.1
  Express consent: By registering, accessing, or using the App, Subscribers expressly consent to the collection, processing, and use of their personal data for the purposes of operating and maintaining the App and providing the services described herein.
• 2.2
  Implied consent: Consent shall be deemed to be granted upon the Subscribers’ election to use any of the App’s services, including medical consultation, medical analysis, entertainment, payment gateway integration, or social networking.
• 2.3
  The Subscribers acknowledge that the provision of personal data is voluntary but necessary for the proper functioning of the App. Failure to provide accurate and complete data may result in limited or restricted access to certain services

3. Categories of Data Collected

The App may collect and process the following categories of personal

• Health metric data: Including but not limited to blood pressure, heart rate, glucose levels, and other health-related information voluntarily provided by Subscribers.
• Personal identification information: Including name, age, gender, contact details, and account credentials.
• Payment information: Including electronic payment gateway details and Octopus card information linked to the App.
• Usage data: Including records of participation in entertainment, gaming, purchases, and social activities within the App.

4. Purpose Limitation

• 4.1
  Personal data shall be collected and processed solely for the purpose of operating, maintaining and providing services within the App.
• 4.2
  Personal data shall not be used for any purpose unrelated to the App’s functions and services, unless required by law or with the Subscribers’ explicit consent.
• 4.3
  The App shall ensure compliance with the Data Protection Principles (“DPPs”) under the PDPO, including but not limited to:
• DPP1: Purpose and manner of collection;
• DPP2: Accuracy and duration of retention;
• DPP3: Use of personal data;
• DPP4: Security of personal data;
• DPP5: Information to be generally available;
• DPP6: Access and correction rights.

5. Data Amendment and Deletion

• 5.1
  Subscribers may amend or delete their personal data at any time by using the in-App functions provided for such purposes.
• 5.2
  Amendments and deletions shall take effect instantly upon execution by the Subscribers.
• 5.3
  The App shall not retain any deleted data beyond the Subscribers’ instruction.
• 5.4
  Upon termination of use or removal of the App, all personal data of the Subscribers shall be deleted in entirety and shall not be recoverable.

6. Data Retention

• 6.1
  Personal data shall be retained only for so long as the Subscribers continue to use the App.
• 6.2
  Upon termination of use or removal of the App, all personal data of the Subscribers shall be permanently erased from the App’s systems.
• 6.3
  The App shall not retain personal data beyond the period necessary to fulfill the purposes for which it was collected, in compliance with DPP2 of the PDPO.

7. Sharing and Transfer of Data

• 7.1
  Personal data may be shared with relatives or designated persons only upon the explicit consent of the Subscribers.
• 7.2
  Health metric data may be transferred to external medical institutions and medical analysis companies solely upon the Subscribers’ consent.
• 7.3
  Payment gateway and Octopus card information shall be transferred into the App system for transaction processing.
• 7.4
  By electing to use optional services (medical consultation, medical analysis, entertainment, or communication with other Subscribers), Subscribers shall be deemed to have provided consent to the transfer of their personal data to the relevant parties necessary for the provision of such services.
• 7.5
  The App shall maintain records of consent obtained from Subscribers for any transfer or sharing of personal data, in compliance with DPP3 of the PDPO.

8. Data Security

• 8.1
  The App shall implement reasonable technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction, in compliance with DPP4 of the PDPO
• 8.2
  Security measures may include encryption, access controls, and secure storage protocols.
• 8.3
  Subscribers shall remain solely responsible for safeguarding their login credentials, payment information, and any other authentication details associated with their account.

9. Subscribers’ Rights

• 9.1
  Subscribers have the following rights under the PDPO:
• The right to access their personal data;
• The right to request correction of inaccurate personal data;
• The right to request deletion of personal data; and
• The right to withdraw consent for data transfer at any time.
• 9.2
  The Subscribers may exercise these rights through the in-App functions or by submitting a written request to the App’s designated Data Protection Officer.
• 9.3
  The Subscribers acknowledge that withdrawal of consent may limit or prevent access to certain services within the App.

10. Compliance with PDPO

• 10.1
  The App undertakes to comply fully with the PDPO and the six Data Protection Principles contained therein.
• 10.2
  The App shall appoint a Data Protection Officer responsible for overseeing compliance with the PDPO and this Policy.
• 10.3
  The App shall ensure transparency by making this Policy available to all Subscribers and by responding to data access and correction requests in accordance with the statutory timeframes prescribed under the PDPO.

11. Governing Law

12. Amendments

We may amend this Policy from time to time. Any amendments will be posted within the App and shall take effect upon posting. Subscribers are encouraged to review this Policy periodically for any changes. Continued use of the App following any amendment shall constitute acceptance of the amended Policy.