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:
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:
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:
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.