Effective Date: [•] July 2023

Version: 1

BNET-TECH COMPANY LIMITED 必靈科技有限公司 (“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”). We are equally committed to ensuring that all our employees and service providers who process personal data on behalf of BNET uphold these obligations.

***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 human fall detection LiDAR system branded under the name of “FADELISY” (the “System”, which are targeted for our organizational and institutional customers, such as retirement homes and nursing homes). It explains how your personal data is collected, used, processed, stored, shared and protected, what choices you have relating to your personal data, and how you can reach us. In this Policy, as the context may be, “you” and “your” may refer to our organizational and institutional customers, or the individual users of the System, or both.
The System is a non-visual and non-audio system that is not capable of recording or reproducing surrounding audio and visual signals. The System does not take any photo or video, nor does it record any sound. The System does not have a camera or a sound recorder. The System only detects human falls within its ranges using eye-safe pulsed laser beams, which measure distances and thus provide computers with an accurate three-dimensional representation of the environment monitored by the System.

The System may not successfully or precisely detect each and every human fall, and may not successfully or precisely alert any individual to any such fall. While we strive to improve the System’s functionality, the System is not error-free. To the extent permitted by applicable laws, we are in any event not responsible or liable for any of the failure of the System to successfully or precisely detect a human fall or alert any individual to any such fall. By purchasing or using the System, you agree to our terms and conditions as stated in our website and in this Policy, including the disclaimers, limitations of our products and services, and limitation of liability.
In this Policy:

“FADELISY” means the human fall detection LiDAR system developed by BNET;
“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; and
“services” means the functions provided in and through the System, including without limitation the functions relating or ancillary to the provision of fall alert services and the notification of a human fall.

Navigating this Policy

You can click on the links below to jump to the relevant section:
1. WHO is responsible for processing your personal data?
2. WHY and HOW do we use your personal data?
3. WHAT personal data do we collect and WHEN?
4. SHARING your personal data
5. PROTECTION and MANAGEMENT of your personal data
6. DIRECT MARKETING
7. CHANGES to our Policy
8. QUESTIONS, complaints and feedback

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 create your user account
We require your personal data, such as your identity and contact information, to admit you as a new registered user of the System or to otherwise facilitate our provision of the services and functionalities of the System. You will only be able to enjoy the services after we receive the necessary information and, if relevant, all verification processes are successfully completed. If you wish to purchase the System but are unable or unwilling to provide such information to us, you will not be able to use the System.

To provide the features of the System
When you use the System, we will use your personal data for rendering the services. For example, if an individual under your care trips or stumbles within the detectable ranges of the System, the System will automatically give a “fall down alert” to you, warning you of the occurrence of a human fall within the ranges of the System. If an individual under your care gets out of his or her bed located within the detectable ranges of the System, the System will also automatically give a “warning” notification to you as well.
We may also use data about you to respond to your inquiries and fulfill your requests.

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 System.

To operate, improve and maintain our services
We process the personal data you provide to us to improve our services, enhance the functionality of FADELISY (if applicable) and the System, and perform various internal functions. For example, we may publish in our marketing materials the number of purchasers of the System and their demographics in an anonymised or aggregated way. These marketing materials may be furnished to sponsors or funders to allow them to understand our model and consider whether to financially support us.

We may collect and use information about how you use our services to enhance the user experience of the System, help us diagnose technical and service problems and administer the System. Information collected by means of cookies on the System will be used only for compiling aggregate statistics on how the System is being used. Such statistics are collected for the purpose of managing and improving the design of the System.

To protect our or others’ rights, property or safety
We may also collect and use information about how you use the System 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 social objectives such as enhancing the safety and mobility of the elderly and the disabled, we may use your personal data to understand users’ 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 our users.

WHAT data (most of which are not personal data) do we collect and WHEN?
When using the System, the personal data we may collect includes without limitation:
1. contact details of our organizational and institutional customers;
2. sensor data;
3. location data;
4. login and account information, including screen name, password and unique user ID;
5. names of users of the System and certain statistical information (e.g. fall frequency and particulars, occupancy of the System, response time, location, walking steps) relating to such users; and
6. Data relating to the customised settings of every System.
When interacting with the System, certain data is automatically collected. Such data includes without limitation:
1. device IDs, network access, storage information and battery information; and
2. cookies and IP addresses.

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 your personal data with:

1. our employees who need the information to discharge their duties;
2. our data storage provider(s) and other third-party service providers for services ancillary to ours, including but not limited to external manned security service providers;
3. medical service providers and healthcare professionals including ambulance service providers, emergency medical technicians and paramedics;
4. 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
5. any person you have authorised to interact with us on your behalf.
Your personal data may be stored and processed in place outside of Hong Kong (including but not limited to Singapore), where we have affiliates, facilities, or in which we engage service providers. By using the Apps, you understand that your information may be transferred to countries outside of your country of residence.
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 or permitted 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 period you use our services 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 of which we become aware.

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. You may submit a data access request, and/or subsequently a data correction request, by submitting the feedback form on our website with your full name and contact details. These requests will be handled by our representatives, who may be contacted by mail, e-mail or phone. You may visit our website for our contact details.

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.

Uninstalling the System will not automatically delete any information already uploaded to our central storage. If you wish any of your personal data uploaded to our central storage to be deleted, you can expressly ask us to delete your information using the feedback form on our website.

DIRECT MARKETING
We may from time to time use your contact details in order to send you marketing materials about, without limitation, our events, programmes, research, volunteer opportunities, news update, and impact reports relating to our products. We may not use your personal data in direct marketing unless we have received your consent.
You may opt out of receiving marketing communications at any time, with no charge, by submitting the feedback form on our website with your full name and contact details. We will then stop sending you any further marketing related emails. 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 System. If we make material changes to this Policy, we will notify you in the System 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.
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