Last Updated: June 16, 2025
SmartAge Care (“we,” “us,” or “our”) is committed to protecting your privacy and ensuring that your personal data is handled in strict compliance with the Personal Data (Privacy) Ordinance (Cap 486) (“PD(P)O”) of Hong Kong. This Privacy Policy explains how we collect, use, store, disclose, and protect your personal data when you use the SmartAge Care mobile application (“App”). By using the App, you agree to the terms of this Privacy Policy. If you do not agree, please refrain from using the App.
1. Personal Data We Collect
We collect the following types of personal data to provide and improve our services:
a. Data Collected via mmWave Sensor
Activity Data: Information about elderly activities, including time spent in marked areas, entering and exiting marked areas, and sleep patterns, collected through our mmWave sensor.
Calibration Data: Data transmitted via Bluetooth to calibrate the mmWave sensor for area marking.
b. Data Collected via the App
Questionnaire Responses: Answers provided to in-app questionnaires designed to identify symptoms or health-related information.
Account Information: Email address and other identifiers provided during account creation or for account deletion requests.
c. Data from Integrated Devices
Vital Signs: Health data, such as heart rate, blood pressure, or other vital signs, collected from third-party devices integrated with the App (with your explicit consent).
d. Usage Data
Non-personal data, such as App usage statistics, device type, operating system, and interaction logs, collected to improve App performance and user experience. This data is anonymized and does not identify you personally.
2. How We Collect Your Personal Data
Directly from You: Through your input in the App (e.g., questionnaire responses, account details).
Automatically via Sensors: Activity data collected by the mmWave sensor and transmitted to the App via Bluetooth.
From Third-Party Devices: Vital signs data from integrated devices, subject to your consent.
Cookies and Analytics: We use cookies to collect anonymized usage data. You may disable cookies in your device settings, but some App features may not function optimally.
3. Purposes of Collecting and Using Personal Data
We use your personal data for the following purposes:
To process and display elderly activity data (e.g., time in marked areas, sleep patterns) on the App.
To analyze questionnaire responses to identify potential symptoms and provide personalized insights.
To enable integration with third-party devices for collecting and displaying vital signs.
To calibrate the mmWave sensor via Bluetooth for accurate area marking.
To process account deletion requests submitted via email.
To improve the App’s functionality, performance, and user experience through anonymized analytics.
To comply with legal obligations, such as responding to regulatory or law enforcement requests.
To conduct research or analysis to enhance our services, provided data is anonymized or aggregated.
4. Disclosure of Personal Data
We do not sell or share your personal data with third parties except in the following circumstances:
Service Providers: We may engage trusted third-party service providers (e.g., cloud storage, analytics providers) to process data on our behalf. These providers are contractually obligated to comply with the PD(P)O and protect your data.
Third-Party Device Integration: With your explicit consent, we may share data with third-party devices or services for vital signs integration.
Legal Requirements: We may disclose data to regulatory authorities, courts, or government agencies to comply with legal obligations or protect our rights.
Anonymized Data: Aggregated or anonymized data that does not identify you may be shared for research, analytics, or industry benchmarking.
5. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. Upon account deletion or when data is no longer needed, we will securely delete or anonymize it. If you request account deletion via email, we will process the request within 30 days and delete your personal data, except where retention is required by law.
6. Your Rights Under the PD(P)O
You have the following rights regarding your personal data:
Access: Request a copy of the personal data we hold about you.
Correction: Request correction of inaccurate or incomplete data.
Deletion: Request deletion of your account and personal data by emailing us at smartage@smart-age.net.
Objection: Object to certain uses of your data, such as direct marketing.
Withdrawal of Consent: Withdraw consent for data processing where consent is the legal basis (e.g., third-party device integration).
To exercise these rights, please contact our Data Protection Officer at jason.or@smart-age.net. We may require identity verification to process your request. A reasonable fee may be charged for data access requests, as permitted by the PD(P)O.
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse, including:
Encryption of data transmitted between the mmWave sensor, App, and our servers.
Secure storage of data in compliance with industry standards.
Regular security assessments and updates to address potential vulnerabilities.
Contractual safeguards with third-party service providers to ensure data protection.
Despite these measures, no system is completely secure. If you suspect a data breach, please contact us immediately.
8. Third-Party Services
The App may integrate with third-party devices or services (e.g., for vital signs collection). These services are governed by their own privacy policies, and we are not responsible for their practices. Please review their policies before enabling integration.
9. Account Deletion
To delete your account and associated personal data, please send an email to smartage@smart-age.net with the subject “Account Deletion Request.” Include your registered email address and any additional verification information we may request. We will process your request within 30 days, subject to legal retention requirements.
10. Cookies and Usage Data
We use cookies and similar technologies to collect anonymized usage data for analytics and App improvement. Cookies are not used to collect personal data. You can disable cookies in your device settings, but this may affect App functionality.
11. Children’s Privacy
The App is not intended for use by individuals under 13 years of age. We do not knowingly collect personal data from minors. If you believe we have collected such data, please contact us to have it deleted.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. Updates will be posted on our website or within the App, and we will notify you of significant changes via email or in-app notifications. Please review this policy periodically.
13. Governing Law
This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region. Any disputes arising from this policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact our Data Protection Officer:
Email: smartage@smart-age.net
Address: Unit 2A, PI Centre, Inter-University Hall, The Chinese University of Hong Kong, Shatin, New Territories, Hong Kong
Phone: +852 60815199
We are committed to addressing your inquiries promptly and in accordance with the PD(P)O.
