Privacy Policy
The Institute of Philanthropy (“IoP”) is committed to ensuring the privacy and security of the Personal Data it holds. The IoP aims to meet this commitment by implementing the principles and requirements of the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (the “Ordinance”). This Privacy Policy Statement is intended to explain the IoP’s privacy practices.
Collection of Personal Data
From time to time and for the purpose of carrying on businesses and operation of the IoP, 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 is not limited to, the following:-
- Information about you such as your full name, gender, date and place of birth, nationality, marital status, educational background, professional qualifications, employment history, public appointments, awards and recognitions received and community services;
- Audio recordings, photographs and other images of yours and biometric data such as your voice ID, thumb ID and facial recognition data;
- Information for verification of identity or citizenship including identification type and identification number such as Hong Kong Identity Card or passport details, visa information, residence or work permit;
- Contact details such as office and/or home address, telephone number, mobile phone number, fax number and email address;
- Information provided in your application for IoP’s services and/or activities;
- 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.;
- Your responses to market surveys and contests conducted by the IoP or on its behalf; and
- Details of your visits to IoP’s websites, mobile applications and other information collected through cookies and other tracking technology as set out below.
Supply of Personal Data to the IoP is generally non-obligatory but failure to do so may result in the IoP being unable to process your applications or to provide you with the relevant facilities or services.
Occasionally, you may need to provide Personal Data about other individuals to the IoP (such as spouse or children, funders, beneficiaries, members, employees, suppliers or contractors). In that event, for the compliance with the Ordinance, 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 IoP’s possible use, disclosure and transfer of their Personal Data, for the purposes you would want to achieve from the IoP. If necessary, the IoP may require you to provide to the IoP any supporting documents which may be necessary to prove such authorisation. You should also advise them that the IoP can be contacted for further information.
Use of Personal Data
Your Personal Data may be used for the following purposes or any directly-related purposes:-
- The IoP’s management and administration of their funding programmes including grants, loans, scholarships, sponsorship, membership or fellowship of any association established by the IoP in connection with such funding programmes and/or other related charitable matters;
- Processing of applications in relation to the funding programmes of the IoP 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);
- Producing and/or publishing articles or other publications in relation to IoP’s funding programmes and/or other IoP activities and services;
- Conducting research and/or collating statistical information relating to the applicants, to assist the IoP in the management and administration of its funding programmes;
- For the purposes of improving IoP’s services, including to ensure that IoP’s websites, mobile applications and web pages (including social media pages) function correctly and in accordance with your preferences and circumstances;
- Matching (as defined in the Ordinance) your Personal Data with other data collected for other purposes (by the IoP or any third party), in relation to the processing, assessment, administration and/or management of the IoP’s funding programmes and/or the performance of any service or administration work in connection with the IoP’s operations and tailoring and personalising services and offers as set out below;
- 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;
- Promoting the grants, loans, scholarship or other funding programmes of the IoP, such as sending you annual reports, newsletters, information or promotional materials regarding charitable or community causes, activities and events organised or sponsored by the IoP (please see further details in "Direct Marketing");
- 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;
- Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, of the IoP, or in connection with:
- any law, regulation, judgment, court order, sanctions regime, within or outside the Hong Kong Special Administrative Region ("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; or
- any of the rules or bye-laws of the IoP relating to the IoP’s core operations.
- Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the IoP and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities; and/or
- Prevention, detection or investigation of crime.
Direct Marketing
Subject to IoP having obtained the relevant consent from you, IoP (or an agent on behalf of the IoP) may use your Personal Data for direct marketing carried out by IoP for marketing and promotion of the following classes of facilities, 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 IoP or the IoP’s programme partners.
For such purposes your Personal Data held by the IoP may be provided to The Hong Kong Jockey Club and/or its subsidiaries (together “the Club”) for their use for direct marketing. The IoP may also conduct such direct marketing via or jointly with third party services providers including social media platforms, which may involve the IoP sharing Personal Data it holds about you with them. You can always opt out from receiving such marketing or promotional communications free-of-charge by following the opt-out instructions contained in the relevant communications or contacting the Club’s Data Privacy Compliance Officer.
Please note that if you choose to opt out of direct marketing, the IoP may still send you communications on administrative matters such as annual reports or updates to its services.
Disclosure of Personal Data
Personal Data supplied to the IoP will be kept confidential. However, the IoP 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:
- 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;
- Any other person or company who is under a duty of confidentiality to the IoP and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
- Consultants, agents, contractors, suppliers and any third party service provider of the IoP which provide administrative, marketing and research, distribution, data processing and analytics, telecommunications, computer, financial, payment or other services to the IoP in connection with their operations;
- Government and regulatory authorities, investigative bodies and law enforcement agencies and other organisations, as required or authorised by law;
- Any financial institutions, including banks, necessary to and solely for the purposes of establishing and supporting payment in connection with the funding programmes; and
- Your authorised representatives or legal advisers when requested by you to do so.
The IoP 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; or (ii) pursuant to the IoP’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 IoP’s legal rights, or to protect the life, body or property of an individual. This also applies when the IoP has 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 IoP’s rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
Where applicable, the IoP 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 IoP or as part of a corporate reorganisation or other change in corporate control.
The Personal Data that the IoP collects or obtains may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. By submitting Personal Data to the IoP or applying for any of the funding programmes of the IoP, you understand and consent to such transfer.
Links to Third Party Websites
The IoP’s websites may contain links to other sites and pages which are operated by third parties. The IoP has no control over 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 the IoP’s websites ("Websites") and mobile apps, if any, you agree that the IoP can store and access cookies, IP addresses and use other methods in order to collect website usage data and improve your on-line experience.
Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the website owners.
The IoP uses cookies on its Website to track visitor preferences. These cookies allow the Website to remember information that changes the way the Website behaves or looks, such as your preferred language. These cookies can also assist you in changing text size, font and other parts of webpages that you can personalise. You may refuse to accept cookies by altering the settings on your internet browser but it should be noted that if you choose not to permit cookies, some areas of the Website may not function properly.
Data Retention
All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.
Commitment to Data Security
The IoP is committed to protecting the security of your Personal Data. A variety of physical, technological and organisational measures are used to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.
Changes to the Privacy Policy Statement
The IoP will post on its website at www.iop.org.hk any changes to its Privacy Policy Statement, so that you will always know what information the IoP gathers, how it might use that information and whether it discloses such information to anyone.
Access to and Correction of Personal Data
You are entitled to request access to Personal Data held by the IoP about you and to correct such data. The IoP 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
This notice is written in 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 notice, the English version shall prevail.