Effective Date: [•] July 2026

Version: 4

BNET-TECH COMPANY LIMITED (hereinafter referred to as “BNET“, “our“, “us“, or “we“) (Company Registration Number: 2355254) is fully committed to protecting your privacy. We ensure that all personal data received by us is handled strictly in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “PDPO”), the Data Protection Principles, and the relevant terms of this Privacy Policy (the “Policy”). We are equally committed to ensuring that all our staff and third-party service providers processing personal data on behalf of BNET comply with these obligations.

Please read this Policy carefully before providing any data about yourself or any other individual to us.

This Policy describes the personal data that will be collected or processed during your use of our official website (the “Website”) and our mobile applications (the “Applications”, including the STICKu Application and the ElderlyGo Application). This Policy explains how we collect, use, process, store, share, and protect your personal data, what choices you have regarding your personal data, and how you can contact us. In this Policy, depending on the context, “you” and “your” may refer to a visitor of the Website, an individual user of the Applications, a designated caregiver, or all of the above.

The Website and Applications may contain links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. This Policy does not apply to, and we are not responsible for, the privacy, data, or other practices of any third parties. We encourage you to read the privacy notice of every website you visit.

Definitions

In this Policy:

“Personal Data” means any data relating directly or indirectly to you, from which it is practicable to directly or indirectly ascertain your identity.

“Processing” or “Process” means any operation or set of operations performed on personal data (whether or not by automated means), including but not limited to collecting, recording, organizing, amending, augmenting, deleting, adapting, retrieving, using, disclosing, or disseminating such personal data.

“Services” means the features and functions provided on and through the Applications and the Website, including but not limited to the “Emergency SOS”, “Find Missing Elderly”, “Fall Detection Notification”, and “Left-Behind Reminder” features in the STICKu Application; and the “Contact Tracing” feature in the ElderlyGo Application.

“STICKu” means the multi-functional walking stick developed by BNET.

1. Who is Responsible for Processing Your Personal Data?

BNET is responsible for processing your personal data.

2. What Personal Data Do We Collect and When?

When you use our Website and Applications, the personal data we collect includes, but is not limited to, the following categories:

A. Data Actively Provided by You or Generated Through the Applications

Your contact information, including name, email address, phone number, and physical address;

Login and account details, including screen name, password, and unique username;

Profile details, including gender and date of birth;

Detailed contact information of your designated emergency contacts or caregivers;

Fitness and activity data provided by you or generated through the STICKu Application (e.g., time, duration, distance, location, step count);

Personal preferences;

Physiological data measured by vital sign devices synced with the Application (e.g., blood pressure, blood oxygen level).

B. Device and Technical Sensor Data

Sensor data and movement data from your device’s accelerometer;

Data automatically collected from your device during interactions between the Applications and your device, including device name, network connectivity status, storage usage, and battery status.

C. Website and Web Browsing Data

Cookies and IP addresses automatically collected when you browse our official Website;

Anonymous web browsing behavior collected through Google Analytics 4 (GA4) (e.g., clickstream data, page dwell time, and navigation paths).

We may collect additional personal data from you to enable specific features within the Applications or on the Website. For example, if you use the STICKu Application, we may access the location data of your mobile device to track your movements. We may access your designated contacts’ information to allow your mobile device to automatically send alerts in an emergency. We may also access your mobile device’s location data and use it to assist in locating a missing elderly individual.

3. Why and How Do We Use Your Personal Data?

We use your personal data for the following purposes:

Account Creation and Management: To accept you as a new registered user of the Applications or to upgrade services, we need your identity and contact information. You can only use the services provided by the Applications after we receive such data and successfully complete all verification procedures. If you are unable or unwilling to provide such data, you may still use STICKu (subject to the Terms of Use) but may not be able to receive all or part of the services available only through the Applications.

Provision of Services and Application Features: During your use of the Applications, we will use your personal data to provide our Services. For example, if your STICKu walking stick falls and is not picked up after a certain period, the Application will automatically send a “Fall Detection Notification” to your designated caregiver.

Precise and Background Location Services: Certain features and functions of the Applications record your location and activity. In an emergency, the STICKu Application will send a notification containing your name and location to your emergency contacts.

Continuous Background Location: If you enable the continuous background location feature, we will still obtain your device’s location even when you are not actively using the Application under the following circumstances: (1) The ElderlyGo Application will detect nearby STICKu devices; when your device is close to them, your location data will be collected for contact tracing; (2) When we receive a missing elderly report sent by an authenticated emergency contact of a STICKu user, your location will be collected if you are near the missing STICKu user. We use multiple technologies to determine your location, including but not limited to Bluetooth scanning. You can turn off background sharing at any time in your device settings.

Responding to Queries and Information Notices: To respond to your inquiries and fulfill your requests; we will also share any latest feature updates and service progress with you through the Applications or the Website.

Operating, Improving, and Maintaining Our Services: To process personal data to elevate our service standards and perfect the functionalities of STICKu, the Applications, and the Website. We may publish user counts and demographic statistics in our marketing materials in an anonymous or aggregated form. These materials may be provided to sponsors or funders to understand our business model and consider financial support. We also use it to help diagnose technical and service difficulties and manage the platforms.

Protecting Our Rights, Property, or Safety and Those of Others: To prevent, detect, or investigate fraud, abuse, illegal use, or violations of our Terms of Use, and to comply with court orders, government requests, or applicable laws, regulations, or guidelines.

General Research and Analytical Purposes (Social Enterprise Mission): As a social enterprise aimed at enhancing the safety and mobility of the elderly, we may use your personal data to understand the details of Hong Kong’s aging population (including but not limited to their activities, habits, preferences, and behaviors) to conduct further research, publish reports, innovate new products/services, and work with other stakeholders (such as the government, NGOs, charities, hospitals, clinics, and elderly homes) to provide a better life for the elderly.

4. Tools to Manage Our Collection of Personal Data

Mobile Device Tools: During your use of the Applications, we may issue notifications or seek your consent for specific scenarios (e.g., push notifications, standard device permission requests). Your mobile device platform will provide additional tools allowing you to control specific categories of personal data, such as location sharing. You can turn off background sharing at any time via your device settings.

Website Cookie Management and Google Consent Mode v2: For visitors to our official Website, we provide a clear Cookie Consent Banner. You can freely choose to accept or reject non-essential statistical and analytical cookies (including GA4). The Website has been configured with Google Consent Mode v2. When you reject analytical cookies, the GA4 script will switch to a cookie-less mode, sending only basic, anonymous network signals (pings) without personal identifiers or tracking tags to Google, fully respecting your privacy choices. You can also change your browser settings to reject all cookies.

5. Sharing and Cross-Border Transfer of Your Personal Data

We may disclose or transfer personal data necessary to satisfy the purposes described above. We may share your personal data with the following parties:

The emergency contacts and caregivers in your designated emergency contact list (applicable only to users of the STICKu Application);

Our staff and volunteers who need access to the data to perform their duties;

Our data storage providers and data analytics providers (including but not limited to external medical teams that may participate in analyzing your personal data to improve our services), and other third-party service providers rendering ancillary services to us;

Medical service providers and professional healthcare personnel, including ambulance service providers, emergency medical technicians, and paramedics;

Any person or entity to whom BNET is under an obligation to make disclosure under the requirements of any applicable laws, regulations, or guidelines issued by governmental, regulatory, or other authorities; and

Any person acting on your behalf with authorization to interact with us.

Your personal data may be stored and processed outside of Hong Kong (including but not limited to Singapore), where our affiliates, facilities, or service providers engaged by us are located. By using the Website and Applications, you acknowledge that your data may be transferred to countries outside your country of residence.

We will never sell your personal data to any third party.

6. Protection and Management of Your Personal Data

Retention of Personal Data: We will retain your data only for as long as necessary or permitted to achieve the purposes of collection, use, and/or disclosure, or to fulfill any legal or business purposes. We will retain your personal data during your use of our services and for a reasonable period thereafter. Please note: Uninstalling the Applications does not automatically delete any data already uploaded to our central repository.

Storage and Security Safeguards: Personal data collected by us is generally held by third-party data storage providers (on our behalf). Occasionally, we may also maintain paper records of personal data in physical storage facilities. We utilize a range of physical and technical processes and procedures to safeguard the confidentiality and security of the data we hold, and we update these measures periodically to address emerging security threats.

7. Access, Correction, and Deletion of Personal Data

You provide personal data to us on a voluntary basis. Under the provisions of the PDPO, you have the right to request access to the personal data we hold about you. We may charge a reasonable fee to offset the administrative costs incurred in preparing electronic copies of your personal data.

You also have the right to correct parts of your personal data held by us, and to request at any time that we cease using or completely delete your personal data, without any charge. You may submit an access, correction, or deletion request (including deletion from the central repository) by submitting the Feedback Form on our website, enclosing your full name and contact details. Our data protection officer will handle your request via mail, email, or telephone.

In certain circumstances, we may not be able to provide the requested data, such as where doing so would violate any laws, infringe upon the privacy of others, or breach confidentiality obligations. In such cases, we will inform you of the reasons for our inability to comply.

8. Direct Marketing

We may from time to time use your contact details to send you our marketing materials (including but not limited to marketing materials regarding our events, projects, research, volunteer opportunities, news updates, and impact reports on our products). We shall not use your personal data for direct marketing unless we have obtained your express consent.

You can opt-out of receiving marketing communications at any time, free of charge, by submitting the Feedback Form on our website (along with your full name and contact details). We will then cease sending any relevant marketing communications. Please note that you might still receive communications for a brief period after changing your preferences while our systems update. You also have the right to request the source of the personal data used in direct marketing communications, which we will provide free of charge unless providing the source is impracticable or unreasonable.

9. Changes to Our Policy

We reserve the right to make updates, modifications, alterations, or amendments to this Policy from time to time as we deem necessary. Therefore, we request that you review this Policy frequently. Any changes or clarifications will take effect immediately upon their publication on the Website or Applications. If we make any material changes to this Policy, we will notify you within the updated Applications or Website.

10. Questions, Complaints, and Feedback

We are committed to maintaining high standards to protect your privacy. However, if you have any concerns regarding how we handle your personal data, or believe that we may have breached any applicable privacy laws or other relevant obligations, please contact us using the Feedback Form on our website. We will record your complaint and conduct further investigations where necessary. We will handle your complaint as quickly as possible and keep you informed of the latest progress of our investigation.

The Chinese translation is for reference only. In the event of any discrepancy or conflict between the Chinese and English versions, the English version shall prevail.

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