Privacy Notice

Agewhale Privacy Policy

Agewhale Limited is a company incorporated in Hong Kong (“Agewhale”, "us", "we" or "our"). We are committed to protecting and respecting your privacy. In order to provide you with the best experience, we need to collect various types of information about you in order to help us serve you.  

This Privacy Policy describes how and why we may collect, store, use, and/or share personal data when you use our services (“Services”), such as when you:

  • Visit our website at (“Site”);
  • Download and use our mobile application ("App"), or any other application of ours that links to this Privacy Policy; or
  • Engage with us in other related ways, including by phone/video call consultations (“E-Consultations”), or when you make enquiries with us.

Sometimes, we may provide additional privacy notices to explain how we may use your personal data in specific situations and you may have the choice to opt out of such uses.

By using our Services, you acknowledge and agree to the collection, use and transfer of your personal data in accordance with this Privacy Policy. If you provide us with personal data on behalf of another person, you represent that you have obtained consent from them to provide their personal data to us, in accordance with this Privacy Policy.

  1. Collection of Information 

When you use our Services, personal data will either be provided by you or collected automatically from you. We will indicate if the collection and provision of certain categories of personal data is mandatory. If you fail to provide to us any mandatory categories of data, we may not be able to provide you with our Services if you do not provide us with the required personal data. All other personal data can be provided by you on a voluntary basis.

The personal data we may collect from you includes:

  • name;
  • contact information;
  • address;
  • employment status;
  • background information related to the caregiving relationship (e.g. caregiving experience, caregiving details, relationship with care recipients etc.);
  • household income range; 
  • gender of the care recipient;
  • nationality of the care recipient;
  • age range of the care recipient;
  • health condition of the care recipient; and
  • other information that is not otherwise publicly available.

We may also use online tracking technologies such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:

  • your visits to our Site and/or App, such as your browsing history, how long you stay on our Site and/or App, and how often you visit; and
  • your location information as provided by your mobile or other device when you use our Site and/or App, including your IP address and general geographic location; and the device on which the App is installed (e.g. your device ID, operating system, type of device, device version, mobile application crashes or other system activity).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online Tracking Technologies.

2. Purpose of Collection

We will only use your personal data for the purposes set out below:

(a) Profile administration 

To help administer and maintain your profile, including:

  • Creating and updating your profile;
  • Verifying your identity; 
  • Maintaining, updating, administering and processing a record of your use of our Services; and 
  • Completing transactions, including processing or facilitating payments;

(b) Service Provision

To provide you with our Services, including:

  • Conducting an internal assessment of your care situation;
  • Creating a care plan;
  • Identifying potential third-party service providers; and
  • Coordinating services from potential third-party service providers;

(c) Customer support

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

(d) Optimization and improvements

We may use your personal data to understand and improve our Site, App, or our operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us to enhance Services, develop new offerings and benefits, and assess and amend business, marketing and strategic operations and plans.

(e) To organize activities and events in connection with our Services

(f) To obtain funding from organizations to subsidise the provision of our Services

(g) To enable third party consultants to evaluate the effectiveness of our Services

(h) For direct marketing purposes

To provide you with marketing and promotional materials (“Marketing Communications”), if you choose to receive them.  Please see the section on Direct marketing below for more information.

(i) Legal and administrative purposes

We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.

(j) Mergers and Acquisitions

To enable an actual or proposed assignee or transferee of our rights or business (or portions thereof) to evaluate or carry out the transaction intended to be the subject of the assignment or transfer or to enable us to evaluate or carry out a proposed or actual assignment or transfer of a third party’s rights or business (or portions thereof) to us.

3. Use of Personal Data in Direct Marketing

Subject to your consent, we may use your personal data to send you Marketing Communications via email, telephone or SMS, in connection with the latest news, events, updates, offers relating to our Services.

Before providing you with Marketing Communications, we will ask for your consent.  You can choose at any time not to receive any Marketing Communications from us. See the section on Your Rights below.

4. Disclosure and Transfer 

To the extent necessary, Agewhale may disclose your personal data to the following parties in or outside Hong Kong solely for the purposes set out in this Privacy Policy:

(a) Our Service Providers

Your personal data may be disclosed or transferred to our service providers (including agents and contractors) who process personal data on our behalf to help us administer, maintain and operate the Site, App, provide back-end, storage, administrative or IT services to us, provide any services to you, conduct data analytics, or carry out any of the purposes set out above. For example, IT vendors, back-office and front-end service providers, call centre operators and marketing agencies.

(b) Potential third-party service providers

Your personal data may be disclosed or transferred to third-party service providers for the purposes of providing you with our Services. For example, for the purposes of assisting you with your care planning arrangements, this may include providers of medical services, home care services, legal services (for wills and POAs), counselling services and rehabilitation training services.  

(c) Government authorities, regulatory bodies etc.

Any person or entity to whom we are under an obligation or otherwise required to make disclosure under the requirements of any law or rules, regulations, codes of practice, guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, binding on or applying to us, or with which we expected to comply with.

(d) We may also transfer your personal data in connection with a corporate transaction such as a merger, acquisition or asset sale.

In any case, where personal data is provided to third parties, your personal data will only be transferred to third parties that are under an obligation to treat your personal data in the same manner required by this Privacy Policy. Other than the parties set out in this policy, we will not disclose your personal data to any third party without your prior consent.

5. Retention

We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required under law. We will either irreversibly anonymise or securely destroy your personal data once we no longer need it.

6. Your Rights

(a) Access and Correction

You are entitled to request access to any personal data that we hold about you, and you can do this by contacting our Data Protection Officer at the address specified below. You may request that we correct the personal data that is inaccurate or out of date. We may charge a reasonable fee for the processing of any personal data access request. If you have any concerns, requests, questions, or complaints about your personal data, or if you have any questions about this Privacy Policy, please contact our Data Protection Officer at [email protected]. We will look into your inquiry and will respond within the time frame provided by any applicable law after receiving your request.

(b) Opt-out of direct marketing

If you no longer wish to receive any promotional materials from us, please let us know at: [email protected].  

7. Data Security

We use appropriate administrative, technical and physical security measures to help protect your personal data against unauthorized or accidental disclosure, access, misuse, loss, or alteration. While we have taken reasonable steps to secure the personal data you provide to us, we cannot ensure or warrant the security of such information.

8. Online Tracking Technologies

When you visit our Site or use our App, we may collect information about your computer or device automatically through cookies or similar technologies. Cookies are text files sent from a website and placed on your computer or device to collect standard Internet log information and visitor behaviour information. 

We use cookies and other tracking mechanisms for system administration, to track information about your use of our website, to improve your browsing and user experience and to deliver relevant content and advertisements based on your preferences, location and usage patterns. 

Most browsers are set to accept cookies by default. You can set your browser not to accept cookies. However, some of our Site features may not function as a result. 

9. External Links 

Our Site and App may contain links to other third party websites and applications. We are not responsible for their content or their privacy policies or how they treat information about their users. We encourage you to review the policies of these third party sites before revealing any personal data.

10. Language

The English version shall prevail in case of any discrepancy or inconsistency between the English version and its Chinese translation.

11. Changes to this Privacy Policy 

We may amend this Privacy Policy from time to time and post the amended Privacy Policy on our Site. An amended version of this Privacy Policy will be effective immediately upon the posting of the amended Privacy Policy unless otherwise specified. While we may notify you of changes in our discretion, we encourage you to check this Privacy Policy for updates regularly. Your continued access or use of our Services after the effective date of the amended Privacy Policy will constitute your consent to the amendments. However, we will not use your personal data in a manner materially different than what was stated at the time your personal data was collected without notifying you and obtaining your consent. 

12. Our communication channels

If you have any questions or comments concerning this Privacy Policy, you can contact our DPO at [email protected].

Alternatively, our communication channels at listed below. Please double-check with us if you get contacted by a different number or account.

Agewhale Personal Information Collection Statement ("PICS")

Agewhale Limited (“Agewhale”, “we”, “us” or “our”) is a company incorporated under the laws of Hong Kong. This personal information collection statement ("PICS") sets out the purposes for which your Personal Data may be collected, used, processed, disclosed, transferred and retained by us in relation to our Services.

  1. Collection of Personal Data

In order for us to provide you with our Services, you will need to provide us with the following categories of Personal Data that we have indicated as being mandatory for you to provide:

  • Name;
  • Phone Number; 
  • Email address;
  • Caregiving details (e.g. your role, your employment status, relationship with care recipients, amount of time spent caregiving on a daily basis, stress levels etc.);  and
  • Care recipient details (e.g. age group, relationship with caregiver, gender, health condition etc.).

If you do not provide such mandatory information, or if any information you provide is untrue, inaccurate or incomplete, we may not be able to provide our Services to you.  All other information you provide is voluntary.

If you provide us with the Personal Data of another individual in connection with the Services, you confirm that you have obtained the consent of the relevant individual to provide their Personal Data to us, and for their Personal Data to be used, processed, disclosed, transferred and retained by us in accordance with this PICS. 

2. Use of Personal Data

We may use the Personal Data you provide for the following purposes: 

(a) to administer, provide, maintain and operate our Services;

(b) to process, handle or communicate with you in respect of any enquiry, complaint or service support request relating to our Services;

(c) to improve our operations through various means, such as the use of analytics tools, research, surveys and feedback forms; 

(d) to investigate or handle any incidents, claims or disputes, defend or bring any claims or actions, or comply with any applicable laws or any requests from any regulatory authority, court or government authority; and

(e) subject to your consent, to provide you with marketing and promotional materials in connection with the latest news, events, updates, offers, contests and promotions relating to our Services.

(f) subject to your consent, to allow our affiliates and business partners to provide you with marketing and promotional materials in connection with the latest news, events, updates, offers, contests and promotions relating to their services and goods.

3. Disclosure and transfer of Personal Data

To fulfil any of the above purposes, we may transfer your Personal Data to the following parties, whether inside or outside of Hong Kong: 

  • funding organisations;
  • service providers; 
  • consultants;
  • legal and professional advisors; and
  • any government or regulatory authorities or third parties in accordance with any legal or regulatory requirements or any court order applicable to us.

We may also share your Personal Data with any third party in connection with a merger, acquisition, consolidation, restructuring, sale of assets, financing or any similar scenarios.  

4. Access to and correction of your Personal Data  

You have the right to request access to and correction of your Personal Data held by us, by submitting a written request to our Data Privacy Officer who will be in-charge of receiving and processing such requests at [email protected].

5. Cookies and Automatic Data Collection

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website. We may use cookies and other similar identification technologies such as web beacons and pixel tags for various purposes, including to provide, monitor, analyze, promote and improve the Services. For example, a cookie may be used to remember your user preferences and settings to enhance your experience when you return to using our Services, and to improve our understanding of how you interact with the Services. If we use choose to use cookies, you can exercise your right to choose whether or not to accept cookies by adjusting your application settings to modify your cookie preferences. However, if you turn off your cookies, some of our Services may not function properly and you will not be able to receive the most efficient and personalised experience.

6. Language

The English version shall prevail in case of any discrepancy or inconsistency between the English version and its Chinese translation.

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