1. Who we are
Peritale is a general wellness self-awareness and self-tracking companion for women in midlife, operated by MARKABLE Ltd. ("Peritale", "we", "us", "our"). The Peritale website is served at peritale.online and the application at app.peritale.online.
Peritale 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:
- DPP1 – Purpose and collection. We collect personal data only for purposes directly related to the Peritale wellness service, by lawful and fair means, and we tell you what we collect and why.
- DPP2 – Accuracy and retention. We take practicable steps to keep your data accurate and to retain it no longer than is necessary.
- DPP3 – Use limitation. We use your personal data only for the purposes set out in this policy, or a directly related purpose. We will seek your fresh, voluntary consent before using your data for any new purpose.
- DPP4 – Security. We apply practicable safeguards to protect your data against unauthorised access, loss or misuse.
- DPP5 – Openness. We make our data practices, policies and the types of data we hold available to you, as in this policy.
- DPP6 – Access and correction. You may request access to, and correction of, the personal data we hold about you (see Section 8).
3. What we collect
Information you provide
- Account information: email address, name (optional) and age range.
- Wellness data: your selections from our symptom questionnaire.
- THINK and SENSE data: results from the attention and memory (THINK) activities and the hearing and vision (SENSE) self-checks, such as response times and accuracy.
- Communications: messages you send us by email or contact forms.
Information collected automatically
- Device information: browser type, operating system and screen resolution.
- Usage data: pages visited, time on site and referral source.
- Cookies: essential and analytics cookies (see Section 7).
4. Your selfie and facial geometry
This section matters most, and we want to be completely clear about it.
- Consent first. Your selfie is biometric personal data. We capture it only with your separate, explicit consent, and you may decline or withdraw that consent at any time.
- What we derive: our software analyses your selfie to extract numerical facial-geometry wellness data points (such as texture, tone and volume values). This reflects general wellness patterns. We do not measure your hormones.
- Storage: your facial image is stored in encrypted form, with your consent, so that we can generate your wellness picture and track how it moves over time across multiple reads.
- No facial recognition: we do not use your image for facial recognition, identity verification or any purpose other than wellness pattern analysis.
- Never sold: your facial data is never sold, and never shared with or made available to any third party.
- Deletable: you may request deletion of your stored image and derived data at any time, and we will action it.
5. How we use your data
We use your information to:
- generate your personal wellness picture;
- track your wellness patterns over time when you complete more than one read;
- create the summary you can choose to bring to your doctor;
- improve our wellness models using anonymised, aggregated data only;
- send you results and, if you opt in, wellness updates;
- respond to your questions and support requests; and
- comply with legal obligations.
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 share data only with:
- Service providers who process data on our behalf under strict contractual obligations: hosting (Cloudflare Pages), analytics (Google Analytics 4 and Microsoft Clarity, which load only after you consent), web fonts (currently served by Google Fonts), payment processing, and a privacy-friendly visitor-count beacon (see Section 7).
- At your direction: when you choose to share your wellness summary with a healthcare professional.
- Legal requirements: when required by law, court order or a lawful request from a Hong Kong authority.
We do not sell, trade or rent your personal data to anyone.
7. Visitor counting and analytics
To understand how many people visit the site, each page load sends a lightweight signal to a privacy-friendly visitor beacon (a Cloudflare Worker). This signal contains only the page path you visited. It carries no name, email, account identifier or other personal data, and it is not used to build a profile of you.
We also use a small number of cookies, and analytics run only after you accept them in our cookie banner. Until you choose to accept, no analytics cookies are set: our consent mechanism (Google Consent Mode) defaults to denied, and a "Cookie settings" control on every page lets you change or withdraw your choice at any time. Essential cookies remember your cookie-consent choice and your login state, and set no analytics. When you consent, we load Google Analytics 4 (measurement ID G-9GKG02ZL9Z) to understand, in aggregate, how the site is used, and Microsoft Clarity for aggregated, anonymised session insights and heatmaps. Our pages currently load web 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. 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:
- Ask whether we hold personal data about you;
- Access a copy of the personal data we hold about you;
- Correct any data that is inaccurate;
- Delete your account and associated data, including your stored selfie; and
- Withdraw consent at any time where we rely on your consent.
To make a data access or correction request, email us at privacy@peritale.online. 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
- Wellness data: retained while your account is active, or until you request deletion.
- Facial images: stored in encrypted form while your account is active, and deleted on account closure or on your request.
- Analytics data: anonymised, aggregated data may be retained for product improvement.
- Account data: deleted within 30 days of an account deletion request, except where retention is required by law.
11. Security
We apply practicable security measures, in line with DPP4, including:
- encryption in transit (TLS/SSL) and at rest;
- access controls and authentication;
- regular security review; and
- secure data-processing practices.
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
Peritale 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.
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.
Peritale is a general wellness product for personal self-awareness and self-tracking. It is not a medical device and does not diagnose, treat, cure, prevent or manage any disease or condition, including any hormonal or menopause-related condition. The scores and summaries it provides are wellness reflections only and are not medical advice. Always consult a qualified healthcare professional for any health concern. This page is general wellness information and is not an advertisement for the prevention, treatment or management of any disease or bodily condition.