Privacy Policy

1. Introduction

Tung Lok ("we", "us", "our"), located at 12 Shouson Hill Road, Shouson Hill, Hong Kong, is committed to handling the personal data of residents, prospective residents, their families and website visitors with care and in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO").

This policy explains what personal data we collect, how we use it, how long we retain it and the rights you hold. If you have questions, please contact us at [email protected].

2. Personal Data We Collect

We collect personal data through the contact form on our website, telephone calls, in-person meetings and written correspondence. The data collected may include:

• Full name
• Email address
• Phone number
• Home address (where relevant to service arrangements)
• Dietary preferences or health notes provided voluntarily for kitchen purposes
• Technical data: IP address, browser type, pages visited (via analytics cookies, with consent)

Legal basis: We process data on the basis of consent (where given), the performance of a service arrangement, and legitimate interest in communicating with prospective residents and their families. Retention period: Enquiry data is held for 12 months from last contact; active service data is held for the duration of the arrangement plus 3 years thereafter.

3. How We Use Personal Data

• To respond to enquiries and arrange residence visits
• To administer and deliver the programme or residence services
• To communicate service updates, changes to arrangements or relevant information
• To personalise kitchen preferences and daily care arrangements (with resident consent)
• To improve our website using anonymised analytics

We do not sell personal data to third parties. We do not send marketing communications without your express consent. We may share limited data with service providers (such as our website hosting provider) under confidentiality obligations. We will not transfer data outside Hong Kong without legal safeguards in place.

4. Data Protection Measures

We take reasonable technical and organisational steps to protect personal data from unauthorised access, alteration, disclosure or destruction. These include:

• Secure storage of records with restricted staff access
• Password-protected systems with regular access review
• SSL encryption on our website
• Breach notification procedures: we will notify affected individuals and the Office of the Privacy Commissioner for Personal Data (PCPD) without undue delay where a data breach is likely to result in risk to individuals

5. Cookies

Our website uses essential cookies required for basic functionality, and optional analytics and preference cookies which are only set with your consent. For full details, please see our Cookie Policy.

6. Your Rights Under Hong Kong Law

Under the PDPO, you have the right to:

• Access personal data we hold about you
• Correct inaccurate personal data
• Withdraw consent at any time where processing is based on consent
• Object to direct marketing use of your data
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk

To exercise any of these rights, please write to us at [email protected]. We aim to respond within 40 days in line with PDPO requirements.

7. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their policies individually.

8. Children's Privacy

Our services are intended for adults aged 18 and over. We do not knowingly collect personal data from persons under 18. If you believe a minor has provided us with personal data, please contact us so we can take appropriate action.

9. Policy Updates

We may update this policy from time to time. The revised version will be posted on this page with an updated date at the top. Continued use of our website or services after changes are posted constitutes acceptance of the revised policy.

10. Contact for Data Enquiries

Data Controller: Tung Lok Residence
Address: 12 Shouson Hill Road, Shouson Hill, Hong Kong
Email: [email protected]
Phone: +852 2917 4068

We are happy to discuss any aspect of this policy with you directly.