Privacy Policy

1. Introduction

Dragonwell ("we", "us", "our") is committed to handling personal information with care and discretion. This Privacy Policy explains what information we collect, how we use it, and the rights available to individuals in relation to their data.

This policy applies to our website at dragonwell.pro and to personal information collected in connection with our residential home services in Hong Kong. If you have questions, contact us at [email protected].

2. Information We Collect

We collect personal information in the following ways:

• Contact forms: When you submit an enquiry, we collect your name, email address, and phone number if provided.
• Telephone enquiries: We may note your name and contact details when you call us.
• Resident and family information: If you enter into an arrangement with us, we collect information necessary to provide appropriate care and communication — including names, contact details, and relevant personal preferences.
• Website usage data: We may collect anonymised data about how visitors use our website, through analytics cookies with your consent.

We do not collect sensitive personal data (such as health records) through our website. Any health-related information shared as part of a care arrangement is handled separately under additional safeguards.

3. How We Use Your Information

• To respond to enquiries about our arrangements
• To communicate with families about a resident's wellbeing
• To manage the relationship between Dragonwell and resident families
• To improve our website and understand how it is used (with consent)
• To comply with applicable legal obligations in Hong Kong

We do not use personal information for unsolicited marketing. We do not sell, rent, or share personal data with third parties for commercial purposes.

4. Legal Basis for Processing

We process personal information on the following grounds:

• Consent: Where you have given us permission, such as when submitting a contact form or accepting analytics cookies.
• Legitimate interest: Where processing is necessary to respond to reasonable enquiries or to maintain the operation of our home.
• Legal obligation: Where we are required to process or retain data under Hong Kong law, including the Personal Data (Privacy) Ordinance (Cap. 486).

5. Data Retention

Enquiry data is retained for up to 12 months. Resident and family records are kept for the duration of the arrangement and for seven years afterwards, in accordance with standard record-keeping practices. You may request deletion of your data subject to any overriding legal retention requirements.

6. Data Protection Measures

We take reasonable steps to protect personal information against loss, misuse, and unauthorised access. These measures include:

• Access to personal data restricted to relevant staff members
• Secure storage of physical and digital records
• Training for all team members on data handling and confidentiality
• HTTPS encryption for our website

In the event of a data breach that is likely to affect your rights, we will notify you and, where applicable, the Privacy Commissioner for Personal Data in Hong Kong.

7. Cookies

Our website uses cookies to understand how visitors use the site. Essential cookies are used to support basic site functions. Optional analytics and preference cookies are only activated with your consent. Please see our Cookie Policy for full details.

8. Third-Party Services

Our website may use the following third-party services:

• Google Analytics (with consent) — anonymised website usage data
• Google Maps — embedded map for our location. Subject to Google's own privacy terms.

We are not responsible for the privacy practices of third-party services. We encourage you to review their policies separately.

9. Your Rights

Under the Personal Data (Privacy) Ordinance (Hong Kong), you have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate information
• Request deletion of your data (subject to legal retention requirements)
• Withdraw consent at any time, where processing is based on consent
• Lodge a complaint with the Privacy Commissioner for Personal Data at pcpd.org.hk

To exercise any of these rights, please contact us at [email protected]. We will respond within 40 days as required by law.

10. Children's Privacy

Our services are directed towards adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe we have done so inadvertently, please contact us and we will delete the information promptly.

11. Links to Other Websites

Our website may contain links to external sites. We are not responsible for the content or privacy practices of those sites and recommend reviewing their own policies before sharing personal information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of this page. Continued use of the website following any changes constitutes acceptance of the updated policy.

13. Contact

For questions about this policy or to exercise your data rights: