Privacy Policy

1. Introduction

Harbor Willow, registered at 14 Sai Wan Ho Street, Shau Kei Wan, Hong Kong, is committed to protecting the privacy of residents, families, and all individuals who interact with our services. This Privacy Policy explains what personal data we collect, how we use it, and what rights you hold under Hong Kong law.

This policy applies to personal data collected through our website, enquiry forms, telephone communications, and in the course of providing residential care services. If you have questions, please contact us at [email protected].

2. Data We Collect

We collect personal data in the following situations:

• Enquiry and contact forms: Name, email address, telephone number, and the content of your message.
• Residency intake: Full name, date of birth, emergency contact details, and relevant background information provided by the family of a prospective or current resident.
• Website usage: Anonymised analytics data, including pages visited and approximate geographic location, collected through cookies (see our Cookie Policy for details).

We collect only what is necessary for the purposes described in this policy. We do not collect sensitive personal data such as health records or financial information through this website.

3. How We Use Your Data

• To respond to enquiries and provide information about our services
• To manage residential care arrangements and support family communication
• To improve our website and services based on aggregated usage data
• To fulfil any legal obligations we hold as a registered care home
• To send occasional updates where you have consented to receive them

The legal basis for processing your data is consent (for web enquiries), contractual necessity (for residential care arrangements), and legitimate interests (for website analytics). We do not sell your data to third parties, and we do not use it for automated profiling or decision-making.

4. Data Retention

Enquiry data is retained for up to 12 months. Resident and family records are retained for the duration of the residency and for 7 years thereafter, in accordance with applicable regulatory requirements. Website analytics data is anonymised and retained for up to 26 months before deletion.

5. Data Protection Measures

We take reasonable steps to protect personal data from unauthorised access, loss, or misuse. These include:

• Secure storage of physical records with restricted access
• Password-protected digital systems used only by authorised staff
• HTTPS encryption for all data transmitted through our website
• Regular staff reminders on data handling responsibilities

In the event of a data breach that poses a risk to affected individuals, we will notify those individuals and the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD) without undue delay.

6. Cookies

Our website uses cookies for basic functionality and anonymised analytics. Please refer to our Cookie Policy for full details of the cookies we use and how to manage your preferences.

7. Third Parties

We may share limited data with trusted third-party service providers who assist us in operating the website and administering our services. These providers are contractually required to handle data in accordance with Hong Kong privacy law.

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

8. Your Rights

Under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate personal data
• Withdraw consent where processing is based on consent
• Object to the use of your data for direct marketing
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong

To exercise any of these rights, please contact us at [email protected]. We will respond within 40 days in accordance with the Ordinance.

9. Children's Privacy

Our services are intended for adults. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently received data from a minor, please contact us and we will delete it promptly.