PRIVACY POLICY OF BNET-TECH COMPANY LIMITED

Effective Date: [•] 2019

Version: 1

BNET-TECH COMPANY LIMITED (“BNET”, “our”, “we” or “us”) (CR No. 2355254) is committed to protecting your privacy and ensuring that all personal data provided to us is handled in accordance with the relevant provisions of the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”), the Data Protection Principles and this privacy policy (“Policy”).

***Please read this Policy carefully before furnishing us any information about you or any other person***

This Policy describes the personal data which will be collected or processed when you use our mobile application (“App”). It explains how your personal data is used, shared and protected, what choices you have relating to your personal data, and how you can reach us.

In this Policy:

personal data” means any information relating to you directly or indirectly, from which it is practicable for your identity to be directly or indirectly ascertained;

process” or “processing” means any operation performed on personal data, whether by automated means or not, including without limitation collecting, recording, structuring, amending, augmenting, deleting, rearranging, retrieving, using, disclosing or disseminating such personal data;

services” means the functions relating to STICKu provided in the App, including without limitation the “emergency alert”, “fall down alert” and “anti-loss alert” features;

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

subscription” means the arrangement to receive the services; and

subscription period” means the period in which you, the subscriber, subscribe to receive the services.

Navigating this Policy

You can click on the links below to jump to the relevant section:

WHO is responsible for processing your personal data?

BNET is responsible for processing your personal data.

WHY and HOW do we use your personal data?

We use your personal data in the following ways:

To commence your subscription

We require your personal data, such as your identity and contact information to admit you as a new registered user of the App. Your subscription of any services of the App will only commence after we receive such information and all verification processes are successfully completed. If you are unable or unwilling to provide such information to us, you may still be able to use the STICKu (subject to the Terms of Use) but you may not be able to receive all or part of the services which can only be rendered with the use of the App.

To provide the features of the App

When you use the App, we will use your personal data for rendering the services. For example, if your STICKu drops and is not picked up over a certain period of time, the App will automatically give a “fall down alert” to caretakers. If emergency situation arises, the App will send notifications to your emergency contacts containing your name and location. The App also records your location and movement. We will collect such data and store it so that you can review it in the App.

In some cases, to use certain features in the App, you may need to provide us with additional data or additional consent. For example, to activate the “emergency alert” and “fall down alert” features, you will need to provide us the contact details of your caretakers and emergency contacts respectively.

We may also use data about you to help you resolve a problem or question.

To communicate information about us and our services

We plan to enhance our services from time to time by adding innovative features and strengthening existing functions. We will share with you any updates through the App.

To operate, improve and maintain our services

We process the personal data you provide to us to improve our services, enhance the functionality of STICKu and perform various internal functions. For example, we may publish in our marketing materials the number of users of the App and their demographics. We may also furnish to sponsors or funders your personal data as a condition to receive their sponsorship or funding.

We may use personal data about how you use our services to enhance the user experience of the App, help us diagnose technical and service problems and administer the App.

To protect our or others’ rights, property or safety

We may also use personal data about how you use the App to prevent, detect, or investigate fraud, abuse, illegal use, violations of our Terms of Use, and to comply with court orders, governmental requests or applicable laws, regulations and guidelines.

For general research and analysis purposes

As a social enterprise with the objective to enhance the safety and mobility of the elderly, we may use your personal data to understand the elderly population in Hong Kong, including without limitation their activities, habits, preferences and behaviours, so that we can conduct further research, publish reports, innovate new products and services and work with other stakeholders (e.g. government, non-governmental organisations, charitable organisations, hospitals, clinics and elderly homes) to better the lives of elderly people.

WHAT personal data do we collect and WHEN?

This personal data we collect includes without limitation:

  • contact details including name, email, telephone number and address;
  • login and account information, including screen name, password and unique user ID;
  • personal details including gender and date of birth;
  • fitness activity data provided by you or generated through the App (e.g. time, duration, distance, location, walking steps); and
  • personal preferences.

We collect additional personal data from you to enable particular features within the App.  For example, we request access to your mobile’s location data to keep track of your whereabouts and your contacts to enable your mobile device to automatically send notifications when there is an emergency situation. Such personal data includes without limitation:

  • movement data from your device’s accelerometer;
  • contacts and calendar information; and
  • sensor data, including location data.

When interacting with the App, certain data is automatically collected from your device.  Such data includes without limitation:

  • device IDs, network access, storage information and battery information; and
  • cookies and IP addresses.

TOOLS to manage what personal data we collect

When using the App, we may provide notice or obtain consent for certain scenarios. For example, we may send push notifications. Such consent may be obtained through the App or using the standard permissions available on your device.

In many cases, your mobile device platform will provide additional tools to allow you to control when your device collects or shares particular categories of personal data.  For example, your mobile device may offer tools to allow you to manage location sharing.  We encourage you to familiarise yourself with and use the tools available on your devices.

SHARING your personal data

We may disclose or transfer such personal data where such disclosure is necessary to satisfy the purposes for which the data is collected as set out above. We may share personal data about you with:

  • your emergency contacts in your emergency contact list;
  • your caretakers;
  • our staff who need the information to discharge their duties;
  • sponsors and funders who have untaken to keep such data confidential;
  • any person or entity to whom BNET is under an obligation to make disclosure under applicable laws, regulations or guidelines issued by government, regulatory or other authorities; and
  • any person you have authorised to interact with us on your behalf.

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

PROTECTION and MANAGEMENT of your personal data

Retention of your personal data

Your personal data will only be kept as long as required for the purposes for which such personal data is collected, used and/or disclosed, or for any legal or business purposes. For the avoidance of doubt, we will retain your personal data during the subscription period and for a reasonable period thereafter.

Storage and security of your personal data

The personal data that we collect will generally be held on our behalf by third party data storage provider(s). Sometimes we also keep hard copy records of personal data in physical storage facilities. We use a range of physical and technical processes and procedures to protect the confidentiality and security of the information that we hold, and we update these from time to time to address new and emerging security threats that we become aware of.

Access, correction and deletion personal data

You provide your personal data to us on a voluntary basis, except where we specify that it is mandatory to access or activate certain of the services. In accordance with the PDPO, you may request access to your personal data held by us. A reasonable charge may be imposed to cover the administrative cost of preparing an electronic copy of your personal data. You are also entitled to correct some aspects of your personal data held by us, and request us to cease to use your personal data at any time without charge.

There may be instances where we are unable to provide the information you request, for example, where it would otherwise infringe any laws, interfere with the privacy of others, or result in a breach of confidentiality. In these cases we will let you know why we cannot comply with your requests.

DIRECT MARKETING

We may from time to time use your personal data in order to send you marketing materials about, without limitation, our events, programmes, research, volunteer opportunities, news update, and impact reports. We may not use your personal data unless we have received your consent.

You may opt out of receiving marketing communications at any time by submitting the feedback form on our website with your full name and contact details. We will then stop any further marketing related emails from ourselves. Please note that you may continue to receive communications for a short period after changing your preferences while we are updating our systems.

If we use your personal data in any direct marketing communications, you have the right to request that we provide you with the source of that personal data. There is no fee for requesting this information. We will provide you with the source of personal data unless it is impracticable or unreasonable to do so.

CHANGES to our Policy

We reserve the right to update, revise, modify or amend this Policy from time to time as we deem necessary. We therefore ask you to review this Policy frequently. Changes and clarifications will take effect immediately upon their posting on the App. If we make material changes to this Policy, we will notify you in the App that it has been updated.

QUESTIONS, complaints and feedback

We aim to implement high standards in order to protect your privacy. However, if you are concerned about the way in which we are processing your personal data or think we may have violated any applicable privacy laws, or any other relevant obligation, please contact us using the feedback form on our website. We will make a record of your complaint and conduct further investigation if necessary. We will handle your complaints as soon as we can and keep you informed of the progress of our investigation.

Should you have any enquiries or feedback about this Policy, feel free contact us using the feedback form on our website.

***