The Hong Kong Jockey Club Charities Trust (the "Trust") and The Hong Kong Jockey Club (the "Club") are committed to ensuring the privacy and security of the Personal Data (as defined below) they hold.  The Trust and the Club aim to meet this commitment by implementing the principles and requirements of the Personal Data (Privacy) Ordinance (“the Ordinance”) of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).  This Privacy Policy Statement is intended to explain the Trust and/or the Club's privacy practices.

For the purpose of this Privacy Policy Statement, an "HKJC Entity" refers to the subsidiaries or entities which the Club or the Trust is related to as set out in the annual report of the Club.

Collection of Personal Data

From time to time and for the purpose of carrying on any operation or business of the Trust and/or the Club, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data").  The scope of Personal Data required from you may vary depending on the circumstances but in general may include, but not limited to, the following:

1. Information about you such as your full name, date of birth, gender, nationality, place of residence, marital status, educational background, professional qualifications, employment history, public appointments, awards and recognitions and community services;
2. Photographs and other images of yours and biometric data, such as your voice, voice ID, thumb ID and facial recognition data;
3. Information for verification of identity or citizenship, including identification type and identification number (such as your Hong Kong Identity Card or passport details, visa information, residence or work permit) and other related information;
4. Contact details such as office and/or home address, telephone number, mobile phone number, fax number and email address;
5. Unique identifiers or personal identifiers for any programme, initiative and activities managed and/or operated by the Trust and/or the Club and the relevant login credentials;
6. Your usage, transactional and activity records of the programmes, initiatives and activities managed and/or operated by the Trust and/or the Club;
7. Educational and professional background including details of examination results, references, past scholarships, awards, employment, community services or extra-curricular activities;
8. Financial and billing information including income, expenses, financial statements, identity of other funders and details of funding, identity and contact details of beneficiaries, employees or contractors, bank account information and details etc.;
9. Your image and voice, including photograph, video or audio recordings;
10. Your interests, preferences and opinions and your responses to market surveys and contests conducted by the Trust and/or the Club or on their behalf;
11. Information the Trust and/or the Club collect about you when you use the Trust and/or the Club’s websites (“Websites”), mobile applications (“Apps”), web pages (including social media pages) (“Web Pages”) and systems , e.g. general diagnostic and usage data, geographic location of your device, details about your device, technical information (e.g. IP address, your log-in information, browser type and version, any unique device identifiers etc.), information about your visit (e.g. the full URL, clickstream to, through and from the Trust and/or the Club’s Websites, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and browsing history, etc.); and/or
12. Any other Personal Data and/or information provided by you, acquired and/or came into existence during the establishment or maintenance of business relationship for the performance of contracts or for compliance with laws, regulations, regulatory requirements and/or any of the Trust and/or the Club’s rules and bye-laws.

Supply of Personal Data to the Trust and/or the Club is non-obligatory, but failure to do so may result in the Trust and/or the Club being unable to process your application(s) or to provide you with the relevant facilities or services.

Occasionally, you may need to provide Personal Data about other individuals to the Trust and/or the Club (such as spouse, children, funders, beneficiaries, members, employees, suppliers or contractors). In that event, to comply with the Ordinance and any other applicable laws, regulations and requirements, you are required to have first obtained the authorisation of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to the Trust and/or the Club's possible use, disclosure and transfer of their Personal Data. You agree to, upon the Trust and/or the Club’s request, provide any supporting documents which may be necessary to prove such authorisation. You also agree to procure and ensure that they have made access to this Privacy Policy Statement and advise them that the Trust and/or the Club can be contacted for further information.

Use of Personal Data

Your Personal Data may be used for the following purposes:

1. The Trust and/or the Club's management and administration of their funding programmes and/or activities, including but not limited to grants, loans, scholarships, sponsorship, events, membership or fellowship of any association established by the Trust and/or the Club in connection with such funding programmes and/or activities and/or other related charitable matters;
2. Operating and managing any funding programmes and/or activities, including but not limited to:
1. the enrolment and management of the funding programmes and/or activities;
2. the identification, verification and determination of eligibility for the funding programmes and/or activities;
3. the processing of the funding programmes and/or activities (whether through the Trust, the Club, any HKJC Entities and/or any other third party partners under the relevant funding programme);
4. the handling of the associated transfer, migration and synchronisation of data (including Personal Data) across the funding programmes and/or activities and the like operated by the Trust, the Club, HKJC Entities and/or business partners; and/or
5. the operation, maintenance, administration, customer data analysis thereof and all incidental matters.
3. Processing of applications in relation to the funding programmes and/or activities of the Trust and/or the Club as set out in paragraph 1, including verifying your identity and assessing your suitability and verifying your eligibility for the same (regardless of whether you are a new applicant or an applicant who re-applies for such funding programmes and/or activities);
4. Contacting you for the purpose of and/or in relation to the funding programmes and/or activities of the Trust and/or the Club as set out in paragraph 1, and addressing any enquiries and complaints related thereto;
5. Collating statistical information relating to the applicants, to assist the Trust and/or the Club in the management and administration of its funding programmes and/or activities;
6. Matching (as defined in the Ordinance) your Personal Data with other data collected (by the Trust, the Club or any third party) for other purposes and automated decision processing (including profiling), in relation to the processing, assessment, administration and/or management of the Trust and/or the Club's funding programmes and/or activities and/or the performance of any service or administration work in connection with the Trust and/or the Club's operations;
7. Handling matters relating to the administration of awarding scholarships or related matters, including making arrangement for placement with or admission to educational institutions or related associations or organisations;
8. Promoting the grants, loans, scholarship or other funding programmes and/or activities of the Trust, the Club or an HKJC Entity, such as sending you annual reports, newsletters, information or promotional materials regarding charitable or community causes, activities and events organised or sponsored by the Trust, the Club or an HKJC Entity (please see further details in "Direct Marketing");
9. Facilitating and maintaining communication with recipients of grants, loans, scholarships and other award recipients during the grant or award period and upon expiry of such period;
10. Maintaining and developing the Trust and/or the Club's business systems and infrastructure, including testing and upgrading of these systems;
11. Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, or establishing, exercising or defending any legal rights of the Trust and/or the Club, in connection with:
• any law, regulation, judgment, court order, sanctions regime, within or outside Hong Kong existing currently and in the future;
• any guidelines, guidance, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside Hong Kong;
• any of the rules or bye-laws of the Trust and/or the Club relating to the Trust and/or the Club's core operations; and/or
• any other agreements between you and the Trust and/or the Club.


12. Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the Trust, the Club and/or any other use of data and information in accordance with any programmes for compliance with client due diligence, sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
13. Prevention, detection or investigation of anomalies and preventing and/or remediating fraud or other potentially criminal, prohibited or illegal activities or otherwise protecting the integrity of the Trust, the Club and/or HKJC Entity;
14. Responding or taking part in legal proceedings, including seeking professional advice; and/or
15. All other legitimate business purposes and purposes directly related to or incidental to the above.

The Trust and/or the Club may also use from time to time aggregate non-identifying information about you to better design and improve the Trust and/or the Club's facilities and services that they offer. This information will not identify any individual in particular.

Direct Marketing

Subject to the Trust, the Club and/or an HKJC Entity having obtained the relevant consent from you, occasionally, the Trust, the Club and/or an HKJC Entity may use your Personal Data to send you marketing or promotional communications containing news, offers and/or promotions about charitable, community or other non-profit making events, causes or activities organised, sponsored or arranged by the Trust, the Club, or an HKJC Entity. 

For such purposes, your Personal Data held by an HKJC Entity may be provided to other HKJC Entities and/or their respective business partners for use for direct marketing subject to your consent.  The Trust, the Club and/or the HKJC Entities or their respective business partners may also conduct such direct marketing via or jointly with third party services providers including social media platforms, which may involve sharing your Personal Data that the Trust, the Club and/or the HKJC Entities or their respective business partners hold about you with them.  However, the Trust, the Club and/or the HKJC Entities will first obtain your consent before doing so.

You can always opt-out free-of-charge by following the opt-out instructions contained in the relevant communications or contacting the Trust and/or the Club's Data Privacy Compliance Officer if you no longer wish any of your Personal Data to be used in and/or be transferred for any of the described direct marketing purposes.

Please note that if you choose to opt-out of direct marketing, the Trust and/or the Club may still send you communications which are of administrative nature.

The Trust and/or the Club may create indirect group profiling by way of analysing your preference characteristics manifested in the information the Trust and/or the Club have about you (e.g. your preferences, details of transactions conducted using your account, etc.).

Disclosure of Personal Data

Personal Data supplied to the Trust and/or the Club will be kept confidential. However, the Trust and/or the Club may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, provide such Personal Data to the following parties:

1. Any HKJC Entity for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above) and to the Trust and/or the Club’s business partners for direct marketing use as described in “Direct Marketing” above;
2. External personnel or organisations (including but not limited to educational or other institutions, associations or organisations, your referees, governmental authorities, assessment or examination boards and awarding bodies) for the purposes or a directly-related purpose for which the personal data was collected or where it is permitted under the Ordinance;
3. Any other person or company who is under a duty of confidentiality to the Trust and/or the Club and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
4. Consultants, agents, contractors, suppliers and any third party service provider of the Trust and/or the Club which provide administrative, marketing and research, distribution, data processing and analytics, telecommunications, computer, financial, payment or other services to the Trust and/or the Club in connection with their operations;
5. The Trust and/or the Club’s insurers and their reinsurers, brokers and agents;
6. Government and regulatory authorities, investigative bodies, courts, law enforcement agencies and other organisations, as required or authorised by law, orders or requests;
7. Any financial institutions or payment services providers necessary to and solely for the purposes of establishing and supporting payment in connection with the funding programmes and/or activities; and/or
8. Your authorised representatives or your legal advisers when requested by you to do so.

The Trust and/or the Club may also disclose your Personal Data to third parties: (i) when required by law, by court order, or in response to a search warrant or other legally valid inquiry; (ii) pursuant to the Trust and/or the Club's good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defences, to obtain legal advice, to exercise and defend the Trust and/or the Club's legal rights or to protect the life, body or property of an individual; or (iii) for enforcement of the Trust and/or the Club’s rules and bye-laws or prevent unauthorised access to the Trust and/or the Club’s premises.  This also applies when the Trust and/or the Club have reason to believe that disclosing the Personal Data is necessary to identify, contact or bring legal action against someone who may be causing interference with the Trust and/or the Club's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by activities causing such interference.

Where applicable, the Trust and/or the Club may also transfer any information it holds about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Trust and/or the Club or as part of a corporate reorganisation or other change in corporate control.

The Personal Data that the Trust and/or the Club collect or obtain may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction.  By submitting Personal Data to the Trust and/or the Club or applying for any of the funding programmes and/or activities of the Trust and/or the Club, you understand and consent to such transfer. 

Links to Third Party Websites

The Trust and/or the Club's Websites, Apps and Web Pages may contain links to other sites and pages which are operated by third parties.  You understand and acknowledge that the Trust and/or the Club have no control over and does not endorse the content of the linked websites or the way in which the operators of those websites deal with your Personal Data.  You should review the privacy policy for those third party websites to understand the ways in which your Personal Data may be used by those third parties.

Use of Cookies

By using any of the Trust and/or the Club's Websites, Apps and/or Web Pages, you agree that the Trust and/or the Club can store and access cookies, IP addresses, domain names, URLs and use other methods in order to collect your usage data on the Websites, Apps and/or Web Pages and improve your on-line experience.

Cookies are small files that are placed on your computer, mobile phones or other devices by websites or mobile applications that you visit/use or certain emails you open.  They are widely used in order to make functions on the websites, mobile applications and/or emails properly, as well as to provide business and marketing information to the owners of the websites, mobile applications and/or emails.

The Trust and/or the Club use cookies on its Websites, Apps and/or Web Pages to track visitor preferences. These cookies allow the Websites, Apps and/or Web Pages to remember information that changes the way the Websites, Apps and/or Web Pages behave or look, such as your preferred language. These cookies can also assist you in changing text size, font and other parts of the Websites, Apps and/or Web Pages that you can personalise. You may refuse to accept cookies by altering the settings on your internet browser, mobile phone or device but it should be noted that if you choose not to permit cookies, some areas of the Websites, Apps and/or Web Pages may not function properly.

Data Retention

All Personal Data that has been collected from you will only be stored for a duration that is reasonably necessary to fulfil the purposes for which it was collected as outlined under this Privacy Policy Statement.  In some circumstances, the Trust and/or the Club may retain your Personal Data for longer periods of time, for instance, where the Trust and/or the Club are required to do so to meet legal, statutory, regulatory, tax or accounting requirements.

Commitment to Data Security

The Trust and/or the Club are committed to protecting the security of your Personal Data.  They use a variety of physical, technological and organisational measures to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.

The transmission of information via the Internet or mobile network is not completely secure. The security measures described above do not preclude the Trust and/or the Club from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and the Trust and/or the Club do not warrant that their servers or network will be immune from such attacks.

Although the Trust and/or the Club will implement security measures to protect your data, the Trust and/or the Club cannot guarantee the security of the data transmitted via Internet or mobile network.  You agree that the Trust and/or the Club shall not be liable for any loss or damage arising from risks relating to any transmission.

Changes to this Privacy Policy Statement

The Trust and/or the Club may update this Privacy Policy Statement from time to time which will be posted on their Website at http://www.hkjc.com/english/corporate/corp_privacy.asp, so as to inform you what information the Trust and/or the Club gather, how they might use that information and whether they disclose such information to anyone.  You are also advised to check the latest Privacy Policy Statement posted on the Trust and/or the Club’s Websites at http://www.hkjc.com/english/corporate/corp_privacy.asp on a regular basis. Where there are significant changes, we will notify you and obtain your acceptance and/or consents (as necessary or applicable). If you do not agree with this Privacy Policy Statement (as revised), please do not use or cease to use the facilities or services of the Trust and/or the Club and do not give us any of your information.  By continuing to use the facilities or services of the Trust and/or the Club after the changes come into effect, you agree to the revised Privacy Policy Statement.

Access to and Correction of Personal Data

You are entitled to request access to Personal Data held by the Trust and/or the Club about you and to correct such data. The Trust and/or the Club may charge a reasonable fee for the processing of such data access request.

You may direct your request in writing to:

Data Privacy Compliance Officer
Jockey Club Headquarters
1 Sports Road
Happy Valley, Hong Kong.

Interpretation

This notice is written in English language and may be translated into Chinese and other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.