Legal
Privacy Policy
Last Updated: 15 May 2025 | Effective Date: 15 May 2025
Tin Lok ("we", "us", "our") is a senior living residence located at 9 Severn Road, The Peak, Hong Kong. We take our responsibility to protect personal data seriously. This policy explains what information we collect, how we use it, and what choices you have in relation to your data.
This policy applies to personal data collected through our website, enquiry forms, telephone communications and in the course of providing our residential services. We operate in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") of Hong Kong.
If you have questions about this policy or wish to exercise your rights, please contact us at [email protected] or by post at the address above.
1. What Data We Collect
We may collect the following categories of personal data:
- Contact information: Name, email address, telephone number, postal address.
- Resident and family information: Details about prospective or current residents shared during enquiry or admission, including dietary needs, preferences and emergency contact details.
- Website usage data: IP address, browser type, pages visited and time spent on our website, collected via cookies and analytics tools.
- Communication records: Emails, telephone notes and correspondence related to enquiries or ongoing service.
Data is collected through our website contact form, telephone calls, in-person visits and correspondence. We collect only what is reasonably necessary for the purpose.
2. How We Use Personal Data
We use personal data for the following purposes:
- Responding to enquiries and providing information about our arrangements.
- Managing admission processes and providing residential services to residents.
- Communicating with families about a resident's wellbeing and day-to-day life.
- Maintaining internal records for service quality and safety purposes.
- Improving the performance and content of our website through analytics.
- Complying with legal obligations under Hong Kong law.
We do not sell personal data to third parties. We do not use personal data for unsolicited marketing without prior consent.
3. Legal Basis for Processing
Under the PDPO, we process personal data on the following bases:
- Consent: Where you have provided data voluntarily via our website form or correspondence.
- Contractual necessity: Where data is required to fulfil or manage a residential arrangement.
- Legitimate interests: For website analytics and service improvement, balanced against your rights.
- Legal obligation: Where required by applicable Hong Kong law or regulation.
Data retention: Enquiry data is retained for up to 24 months. Resident and family data is retained for the duration of the arrangement and for up to 7 years thereafter, as required for legal and administrative purposes.
4. Data Protection Measures
We take reasonable steps to protect personal data from unauthorised access, disclosure or loss:
- Website data is transmitted using SSL/TLS encryption.
- Internal records are held on access-controlled systems with restricted staff access.
- Staff are trained on data handling obligations under the PDPO.
- In the event of a data breach likely to cause harm, we will notify affected individuals and, where required, the Office of the Privacy Commissioner for Personal Data (PCPD) in accordance with applicable guidance.
5. Cookies
Our website uses cookies to support basic functionality and to understand how visitors use the site. We use essential cookies (which cannot be declined), and optional analytics and preference cookies (which require your consent). For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.
6. Your Rights
Under the Personal Data (Privacy) Ordinance (Cap. 486) and applicable Hong Kong privacy law, you have the following rights in relation to your personal data:
- Right of access: Request a copy of the personal data we hold about you.
- Right to correction: Request that inaccurate or incomplete data be corrected.
- Right to object: Object to the use of your data for direct marketing at any time.
- Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time.
- Right to complain: Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) — www.pcpd.org.hk.
To exercise any of these rights, please contact us at [email protected]. We will respond within 40 days as required by the PDPO.
7. Third-Party Links
Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We encourage you to read their privacy policies before providing any personal data.
8. Children's Privacy
Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18 through our website. If you believe we have inadvertently received data from a minor, please contact us and we will arrange for its deletion.
9. Changes to This Policy
We may update this policy from time to time. Where changes are material, we will post the revised policy on this page with a new effective date. Continued use of our website or services after that date constitutes acceptance of the updated policy.
10. Contact
For any data-related questions or requests: