Privacy Policy

1. Introduction

Wing Lok (referred to as "we", "us" or "our") is committed to handling personal data with care and in a way that respects the people who share it with us. This policy explains what data we collect, why we collect it, how we use it and the rights available to individuals under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

This policy applies to personal data collected through our website at https://wing-lok.live, through our contact form, and in connection with enquiries about our senior living residence at 9 Pok Fu Lam Road, Pok Fu Lam, Hong Kong.

If you have questions about this policy, please contact us at [email protected].

2. What personal data we collect

We collect personal data in the following circumstances:

• Contact form enquiries: name, email address, telephone number and any message content you choose to provide.
• Telephone or in-person enquiries: name and contact details given voluntarily.
• Website analytics: anonymised data about how visitors use the site, including pages visited, time spent and browser type. This data does not directly identify individuals.
• Cookies: small files stored on your device. See our Cookie Policy for details.

Legal basis for processing

• Consent — when you submit a contact form or accept optional cookies.
• Legitimate interest — to respond to enquiries and improve our website.
• Contractual necessity — for residents whose data is processed in connection with a living arrangement.

Retention

Enquiry data is retained for up to 12 months unless it leads to a resident arrangement, in which case data is retained for the duration of the arrangement and for 7 years thereafter in line with Hong Kong record-keeping requirements.

3. How we use personal data

• To respond to enquiries submitted through the website or by phone.
• To arrange and conduct visits to Wing Lok.
• To provide and manage residence services where a living arrangement has been agreed.
• To send information about Wing Lok that may be relevant to your enquiry — you may opt out at any time by contacting [email protected].
• To analyse how the website is used, so we can improve it for future visitors.
• To comply with legal obligations under Hong Kong law.

We do not sell personal data to third parties. We do not use personal data for automated decision-making.

4. How we protect personal data

• Data submitted through the website is transmitted over HTTPS (SSL encryption).
• Access to personal data within Wing Lok is restricted to staff with a legitimate need to handle it.
• Electronic records are stored on password-protected systems. Paper records are kept in locked storage.
• In the event of a data breach that affects individuals' rights and interests, we will notify the Office of the Privacy Commissioner for Personal Data (PCPD) and affected individuals as required by the PDPO.

5. Cookies

Our website uses essential cookies to function, and optional analytics cookies to help us understand how visitors use the site. You can review and manage your cookie preferences at any time on our Cookie Policy page.

6. Your rights under the PDPO

Under Hong Kong's Personal Data (Privacy) Ordinance, you have the right to:

• Access: request a copy of the personal data we hold about you.
• Correction: ask us to correct data that is inaccurate or incomplete.
• Erasure: request deletion of your data where there is no lawful reason for us to continue holding it.
• Objection: object to our processing of your data where we rely on legitimate interest.
• Withdraw consent: where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days as required by the PDPO.

If you are not satisfied with our handling of a complaint, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.

7. Third-party links

Our website may contain links to external sites. 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

Wing Lok's services are directed at adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18 through our website. If you believe a minor has submitted data through our site, please contact us and we will remove it promptly.

9. Changes to this policy

We may update this policy from time to time. When we do, we will revise the "Last Updated" date above. Material changes will be communicated via a notice on our website. Continued use of our website after any change constitutes acceptance of the updated policy.

10. Contact

Data Controller: Wing Lok Senior Living Residence

9 Pok Fu Lam Road, Pok Fu Lam, Hong Kong

[email protected]