1. Who we are

MARKABLE is a general wellness self-awareness and self-tracking companion for women in midlife, operated by MARKABLE Ltd. ("MARKABLE", "we", "us", "our"). The MARKABLE website is served at markable.life and the application at app.markable.life.

MARKABLE is a general wellness product. It is not a medical device, and it does not diagnose, treat, prevent or manage any condition, including any hormonal or menopause-related condition. This policy explains how we handle personal data of users in Hong Kong, and how we meet our obligations under the Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO") and its six Data Protection Principles. MARKABLE Ltd. is the data user (controller) responsible for your personal data.

2. Your rights under the PDPO

The PDPO sets out six Data Protection Principles (DPPs) that govern how we handle your personal data, and we have built this policy around them:

3. What we collect

Information you provide

Information collected automatically

4. Your selfie and facial geometry

This section matters most, and we want to be completely clear about it.

5. How we use your data

We use health and wellness information only to provide MARKABLE's wellness features, including generating your results, establishing your personal baseline, tracking changes over time, and creating your wellness summary. We do not sell health and wellness information or use it for advertising.

We use your information to:

In keeping with DPP3, we will not use your personal data for any new purpose that is not directly related to the above without first obtaining your fresh, voluntary consent. We do not sell your data, build advertising profiles, perform facial recognition or make any medical diagnosis.

6. Who we share data with

We do not sell health and wellness information or use it for advertising. Where service providers process information on our behalf in order to operate the service, they may use it only for the purposes described in this policy and subject to our contractual requirements.

We share data only with:

We do not sell, trade or rent your personal data to anyone.

Key commitment: MARKABLE will never share your individual facial images, scores or symptom answers with your employer, your insurer, or any other third party without your explicit, informed consent, other than service providers acting on our instructions, a business transfer described above, or where required by law.

7. Visitor counting and analytics

Analytics run only after you accept them in our cookie banner; until then no analytics cookies are set. We use:

Web fonts: Our pages currently load fonts from Google Fonts, so your browser connects to Google and your IP address is processed by Google to deliver the fonts. We are moving to self-hosted fonts to remove this dependency.

We do not use advertising cookies, retargeting pixels, or social media tracking pixels.

8. Access and correction

Under DPP6 and sections 18 to 22 of the PDPO, you have the right to:

To make a data access or correction request, email us at privacy@markable.life. We will respond within the timeframe required by the PDPO (generally 40 days). We may charge a reasonable fee for a data access request, as permitted by the Ordinance.

9. Cross-border transfers

MARKABLE Ltd. operates from Israel, and our service providers may process data in other locations. Where your personal data is transferred outside Hong Kong, we take practicable steps to ensure it is given a level of protection comparable to that required under the PDPO, including through contractual safeguards with our processors.

10. Data retention

11. Security

We apply practicable security measures, in line with DPP4, including:

No method of transmission over the Internet is completely secure. While we work hard to protect your data, we cannot guarantee absolute security.

12. Children's privacy

MARKABLE is intended for adult women and is not for use by anyone under 18. We do not knowingly collect personal data from children. If you believe a child has given us personal data, please contact us and we will delete it.

13. Changes to this policy

We may update this Privacy Policy from time to time. We will post any material change on this page and update the "Last updated" date above.

14. Contact and complaints

For privacy questions, or to exercise your data access and correction rights:

Data user: MARKABLE Ltd.

If you are not satisfied with how we have handled your personal data, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD) at pcpd.org.hk.