1
THE FAMILY PLANNING ASSOCIATION OF HONG KONG
Privacy Policy Statement
Hong Kong Jockey Club “Making Smart Choices” v.2
1. General
1.1 At The Family Planning Association of Hong Kong (“FPAHK), we care
about your personal data, so we have prepared this Privacy Policy
statement to explain how we collect, use and share it. This Hong Kong
Jockey Club Making Smart Choices v.2 (MSCv2), is owned and
operated by FPAHK. We respect personal data and are committed to full
implementation and compliance with the data protection principles and all
relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486
("the Ordinance") of Hong Kong. This Statement is important and should
be read thoroughly in order to understand the privacy policies of MSCv2 in
respect of any personal data it collects from you, as a data subject (as
defined below).
1.2 This statement is applicable to all users of the system, including but not
limited to all Students, Parents, and Teachers/Tutors, as well as any other
persons that their personal data is collected, by whatever means, used and
held by us. We may update our Privacy Policy to reflect changes of our
information practices. By accessing and using MSCv2 and any of its pages,
you are agreeing to the terms and conditions set out herein.
2. Types of Personal Data
2.1 The term Personal Data, wherever mentioned in this Statement, includes
the following kind of information:
2.2 All the data which may be collected or held by FPAHK from time to time
in connection with the registration and establishment of users account or
the use or continuation of provision of educational services, products and
facilities, the following data relating to a data subject (including any
updated data of any of the following data):
2
a. full name;
b. date of birth;
c. correspondence address and/or residential address;
d. e-mail address;
e. telephone number;
f. fax number;
g. Hong Kong Identity Card Number or travel document number;
h. school name;
i. class code; and
j. information as referred to in the paragraphs below under ‘Cookies,
Domain Names and IP Addresses’.
2.3 Information collected through computer technologies by third parties
whom FPAHK works with to find out more about users of FPAHKs
MSCv2, including number of the visitors, behaviour and usage patterns, for
more accurate reporting.
2.4 Other data collected from data subjects in the ordinary course of the
continuation of the relationship between FPAHK and data subjects such as
the followings:
a. When a data subject uses MSCv2;
b. When a data subject submits any work or statement through MSCv2;
c. The term data subject(s), wherever mentioned in this Statement,
includes the following categories of individuals:
i. Students;
ii. Parents;
iii. Guardians;
iv. Teachers;
v. Users of MSCv2; and
vi. Users of education related services and products so forth provided by
FPAHK or its partners.
2.5 For the avoidance of doubt, data subjects shall not include any
incorporated bodies. The contents of this Statement shall apply to all data
subjects and form part of any contracts for services that the data subjects
have or may enter into with MSCv2 from time to time. If there is any
3
inconsistency or discrepancy between this Statement and the relevant
contract, this Statement shall prevail insofar as it relates to the protection of
the data subjects' personal data. Nothing in this Statement shall limit the
rights of the data subjects under the Ordinance.
3. Cookies, Domain Names and IP Addresses
3.1 When you browse MSCv2, your visit to MSCv2 may be recorded for
analysis on visitor flow and general usage patterns analysis. Some of this
information will be collected through the use of cookies (as defined below).
3.2 Cookies are small bits of information that are automatically stored in
your computer hard drive which can be retrieved by this mobile app game.
3.3 Cookies can make the site more useful by storing information about your
preferences on particular websites and thus enabling FPAHK as the mobile
app game owner to provide more useful features for its users. The
information collected by cookies is anonymous aggregated research data,
and contain no name or address information or any information that will
enable anyone to contact you through telephone, e-mail or any other means.
Most web browsers are initially set to accept cookies and if you would
prefer, you can disable the functionality of cookies. However, by disabling
cookies, you may not be able to take full advantage of MSCv2.
3.4 Every time you log on to this MSCv2, FPAHK will, through its network
servers, automatically collect your domain name and IP address for the
purpose of verification and MSCv2 will use such data for visitor flow
statistical and data analysis.
4. Collection of Personal Data
4.1 From time to time, it is necessary for the data subjects to supply FPAHK
with personal data in connection with the registration and establishment of
user's account or the use or continuation of provision of educational
services, products and facilities.
4.2 FPAHK may work with third parties that use applications or computer
technologies to find out more about users of MSCv2.
4
4.3 Failure to supply such personal data may result in FPAHK being unable to
register and establish a user account or use or continue the provision of
educational services and products and facilities.
5. Protection of Children under the age of 18
5.1 Data subjects who are under the age of 18 must obtain permission from
their parents or legal guardians before providing any personal data to
FPAHK.
6. Purposes of Use of Personal Data Collected
6.1 The purposes for which the personal data relating to the data subjects may
be used will vary depending on the nature of the data subjects' relationship
with FPAHK, they may include the following:
a. Assessing the merits and suitability of the data subjects as actual or
potential applicants for educational research;
b. Conducting statistical and data analysis;
c. Communicating with data subjects or its authorized;
d. Researching and/or designing and/or implementing education related
services and facilities;
e. Conducting, or allowing to be conducted, research on usage and activities
on parts of Hall-Mission including number of visitors, behaviour and usage
patterns, for more accurate reporting;
f. Complying with obligations, requirements, arrangements or procedures that
apply to MSCv2 or that it is expected to comply according to:
i) Any law binding or applying to it within the Hong Kong Special
Administrative Region (Hong Kong) existing currently and in the future;
ii) Any guidelines or guidance given or issued by any legal, regulatory,
governmental, tax, law enforcement or other authorities, or self-regulatory
or industry bodies within Hong Kong existing currently and in the future;
and
iii) Any contractual obligations or other commitment applying to it under any
contractual arrangement FPAHK has with its agent, representative,
5
contractor, business partner or other third party which FPAHK has entered
into a contractual relationship with;
iv) Purposes incidental, associated or relating to any of the above items a. to f.
7. Transfer of Personal Data Collected
7.1 Personal data held by FPAHK relating to data subjects will be kept
confidential but FPAHK may provide and disclose (as defined in the
Ordinance) such personal data to the following parties for the purposes set
out in the previous paragraph:
a. Any agent, contractor, business partner or other third party which FPAHK
works together with in its provision of such service, product or facility,
wherever situated;
b. Any party to whom FPAHK is under an obligation or otherwise required to
make disclosure under the requirements of any law binding or applying to it
within or outside Hong Kong, or any disclosure under and for the purposes
of any guidelines or guidance given or issued by any legal, regulatory,
governmental, tax, law enforcement or other authorities, or self-regulatory
or industry bodies with which FPAHK is expected to comply, or any
disclosure pursuant to any contractual or other commitment of FPAHK, all
of which are within Hong Kong and may be existing currently and in the
future;
c. Such party as authorized to receive a response from FPAHK in accordance
with Part V of the Ordinance.
8. Storage of Personal Data and Security
8.1 All personal data collected from data subjects will be stored in secure
servers of FPAHK in order to prevent any unauthorized or accidental
access, processing or erasure.
8.2 FPAHK maintains this commitment to data security by implementing
appropriate physical, electronic and managerial measures to safeguard and
secure personal data.
8.3 FPAHK will take all practical steps to ensure that personal data will not be
kept longer than necessary and FPAHK will comply with all statutory and
6
regulatory requirements of Hong Kong concerning the retention of personal
data.
8.4 While FPAHK does everything it can to protect personal data from
unauthorized use, processing and disclosure, data subjects should take
precaution not to share, provide or facilitate unauthorized use of an unique
username and/or password assigned by FPAHK or allow access or use of it
by others. If, in the unlikely event, unauthorized transactions have been
discovered through no fraud, fault or negligence on the part of data subjects,
the data subjects should inform FPAHK immediately.
9. Others
9.1 For any queries regarding the issue of Personal Data, please write to
FPAHK by email sent to sexedu@famplan.org.hk or by mail sent to 10/F,
Southorn Centre, 130 Hennessy Road, Wan Chai, Hong Kong.
Last update: 15 October 2020