Collection of your personal data
1. From time to time, it is necessary for you to supply Enrich Personal Development Limited (“us”, “our” or “we”) with personal information and particulars to enable us to carry out the activities described in paragraph 3 below. We may be unable to carry out such activities if you do not provide the necessary information and particulars.
2. We may also generate and compile information and collect information from publicly available sources about you. Personal information and particulars provided by you and all information collected, generated and compiled by us about you from time to time is collectively referred to as “Personal Data”.
Purposes for which your Personal Data are used
3. We may use your Personal Data for one or more of the following purposes:
a. for the supply of any educational. training, counseling or other services (together, the “Services”) which we may offer from time to time;
b. for use of any online services available at our website, the Enrich Planner app (“App”) or through other telecommunication channels;
c. in order to inform you and others about what we do, including providing the Services and our fundraising activities;
d. with your consent, for promoting and soliciting donations or contributions and direct marketing;
e. for processing and administration of donations;
f. for human resources management purposes (including recruitment, provision of compensation and benefits and keeping records of performance and disciplinary matters);
g. for identification and verification purposes (including in connection with any of the Services that may be supplied to you);
h. in order to prepare statistics, carry out research and evaluate our work (including the Services);
i. for communicating with you by email, mail, fax, phone or other means, including contacting you regarding your enquiries;
j. for making disclosures when required by law, regulation, or court order of any jurisdiction or as requested by any government, regulatory or law Enforcement authority or administrative organisation, which may be within or outside The Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”);
k. for establishing legal claims or defences, obtaining legal advice, exercising, defending or protecting our rights or properties (including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or the property of any other person could be damaged by such interfering activities);
l. for any incidental or associated purposes relating to the above or any other purposes which you may from time to time agree.
Transfer of your Personal Data
4. To facilitate the purposes set out in paragraph 3 above, we may transfer, disclose, grant access to or share your Personal Data with third parties (whether within or outside Hong Kong), and your Personal Data may be transferred within or outside Hong Kong. These third parties may include the following:
a. any agent, contractor or third party service provider who provides administrative, distribution, data processing, telemarketing, telecommunications, computer or other services to or support the operations of Enrich (including its fundraising and direct marketing activities);
b. medical professionals, clinics, hospitals, insurers or loss adjustors;
c. any person, government or law enforcement authority or administrative organization and any person under a duty of confidentiality to us (including accountants, legal advisers or other advisers);
d. any charitable or non-profit making organisations.
5. The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above. We may also share information or statistics with third parties in an aggregated or anonymised form that does not directly identify you.
Use and transfer of your Personal Data for fundraising and direct marketing
6. We are allowed to use and/or transfer your Personal Data for fundraising or direct marketing only if you consent or do not object in writing.
7. If we intend to use your Personal Data (including your name and contact details) collected from you for soliciting donations from you or for direct marketing purposes, we will first obtain your consent (or an indication of no objection) before doing so.
8. If we intend to provide your Personal Data (including your name and contact details) collected from you to third parties for their use in soliciting donations or direct marketing, we will first obtain your consent (or an indication of no objection) before doing so.
9. You may opt-out from receiving communications soliciting donations and direct marketing communications from us at any time, free of charge by following the opt-out instructions contained in the communications or writing to us at the address below.
12. Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.
13. We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your Personal Data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.
14. If you use the WiFi available where we operate, we may collect your location data (if you have consented to this on your device). We may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information we receive from third parties to provide you with better service and, where you have consented to receive requests for donations or direct marketing, we may provide you with targeted advertisements, content, features, deals and offers in relation to fundraising or direct marketing.
15. If you interact with us on social media platforms (for example if you “Like” our Facebook Page or post on our timeline), we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your Personal Data. We are not responsible for what third parties post on our social media accounts.
16. Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above after which it will be destroyed.
17. Without limiting or reducing any of our rights in law or under any other provisions in this statement:
a. we will take all practical steps to erase all the Personal Data you provide to us where the Personal Data is no longer required for the purposes described above.
b. you are entitled to request that any Personal Data relating to you that we hold is erased. To make such a request, please write to us at the address below at para 22. We reserve the right to decline to erase Personal Data which we consider is still required to be retained for legitimate purposes in accordance with the law and this Policy, or where it is not reasonably practicable to access the Personal Data in order to completely erase or destroy it. We may also opt to anonymise data rather than erasing it.
18. We do our best to safeguard and secure the Personal Data we collect. However, complete confidentiality and security is not possible over the internet, and privacy cannot be assured in your communications to us.
19. In order to anticipate your needs, our website or the App may contain links to third party sites that are operated under different privacy practices.
20. All such websites are independent from our website or the App. We have no control over the contents of such other websites or their privacy policies or compliance with the law. You should therefore be fully aware that the provision of such links does not constitute an endorsement, approval or any form of association by or with Enrich. We have no control over Personal Data that is submitted to these other websites. You should remain alert when you leave our website or the App, and read the privacy statements of other websites.
How to access or correct your Personal Data or contact us
21. You are entitled to access or correct any Personal Data relating to you held by us. If you wish to obtain a copy of any of your Personal Data or if you believe that the Personal Data relating to you which we collect and maintain is inaccurate, please write to us at the address below.
22. A request for access to Personal Data, correction or erasure of Personal Data, or for information regarding policies and practices and kinds of Personal Data held by ENRICH may be sent to us at the following address:
1102 Enterprise Building
228-238 Queen’s Road Central, Hong Kong
23. In accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong), we have the right to charge a reasonable fee for the processing of any data access request.
24. This statement is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this statement, the English version shall prevail.