Privacy Policy

1. Introduction

Ngon Lok ("we", "our", "us") is committed to handling personal data with care and transparency. This policy explains what information we collect, how we use it, and the choices you have. It applies to our website and to the enquiry, membership and residency processes through which you may share information with us.

If you have any questions about this policy or how your data is handled, please contact us at [email protected].

2. Data We Collect

Information You Provide

• Name, email address and phone number submitted through the contact form
• Details about a prospective resident provided by a family member or representative
• Any additional information you choose to include in enquiry messages

Information Collected Automatically

• Basic website usage data (pages visited, time on site) via analytics tools
• Browser type and device category for technical purposes
• Cookie preferences as recorded through the consent tool on our homepage

Legal Basis for Processing

We process data on the basis of your consent (when you submit a form or accept cookies), legitimate interest (to respond to your enquiry and improve our services), and contractual necessity (to manage resident and member arrangements).

Retention

Enquiry data is retained for up to 12 months from the date of last contact. Resident and member records are retained for seven years for administrative and legal purposes, then securely deleted unless a longer period is required by applicable law.

3. How We Use Your Data

• To respond to enquiries about our plans and arrange visits
• To manage membership and residency arrangements
• To communicate relevant updates about programmes and services
• To improve the website and understand how it is used
• To comply with applicable regulatory and reporting obligations

We do not sell personal data to third parties. We do not send unsolicited marketing without your consent.

4. Data Sharing

We may share data with:

• Service providers who support our website and communications (e.g. email hosting, analytics tools), who are bound by confidentiality obligations
• Regulatory bodies in Hong Kong as required by law
• Family members or designated contacts, only with the resident's knowledge and agreement

5. Data Protection Measures

Personal data is stored on secure servers with access restricted to authorised staff. We apply reasonable technical and organisational measures to protect data from unauthorised access, loss or disclosure. In the event of a data breach that may affect your rights, we will notify you and the relevant authority within a reasonable period.

6. Cookies

Our website uses cookies to support basic functionality and, with your consent, to track anonymous usage statistics. You can manage your cookie preferences at any time through our Cookie Policy page. Refusing optional cookies will not affect your ability to use the site.

7. Your Rights

Under Hong Kong's Personal Data (Privacy) Ordinance (PDPO) and, where applicable, international data protection standards, you have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate data
• Request deletion of data we no longer have a lawful basis to retain
• Object to processing based on legitimate interest
• Withdraw consent at any time (this does not affect processing carried out before withdrawal)
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong

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

8. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and recommend you read their policies independently.

9. Children's Privacy

Our services are directed at adults. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.

10. Governing Jurisdiction

This policy is governed by the laws of Hong Kong Special Administrative Region. Data protection matters are overseen by the Office of the Privacy Commissioner for Personal Data (PCPD), which can be reached at www.pcpd.org.hk.

11. Policy Updates

We may update this policy from time to time. The date at the top of this page indicates when it was last revised. Significant changes will be communicated to active members and residents directly.

12. Contact

Data Controller: Ngon Lok
Address: 15 Tai Tam Road, Stanley, Hong Kong
Email: [email protected]
Phone: +852 3158 4072