The Plan International Hong Kong Website, found at plan.org.hk, including all information and materials contained on it (“Website”), is managed by Plan International Hong Kong Limited, 21/F, 9 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong. (“PIHK” “We”, “Us” or “Our”).
This policy sets out the basis on which we collect, handle, process, store, transfer and destroy Personal Data.
PIHK is committed to protecting and safeguarding the privacy and security of the Personal Data which we collect and hold in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and, for users residing in the European Union, the General Data Protection Regulation (“GDPR”).
We require that all members of staff to comply fully with the terms of this privacy policy and any other standard operating procedures relating to data protection developed by us from time to time.
The Website
This privacy policy governs all pages on the Website but does not apply to pages hosted by other organisations, including the websites of our fundraising partners or third parties. The Website may contain links to websites of such other parties, and those sites may have their own privacy policies which apply to them. We suggest that you review their privacy policies before using their websites.
By using the Website or by opting to receive any information from us, you consent to the terms of this privacy policy and the Terms and Conditions of the Website. PIHK may change the terms of this privacy policy and the Terms and Conditions of the Website from time to time. We encourage you to check the Website from time to time to ensure that you are aware of the most recent version.
Collection of Personal Data
We may ask you to provide Personal Data when you engage with us as a donor, supporter, fundraiser, programme partner, event/programme participant or job applicant, etc.
You are not required to provide this information to us, but if you do not, we may not be able to contact you or process your donations, applications or requests, etc.
Personal Data that we may collect from you and held by us includes, but not limited to:
- Your name;
- Your gender;
- Your mailing address;
- Your email address;
- Your phone number;
- Your date of birth;
- Your education and past employment information;
- Your reference/background check information;
- Your health related information;
- Your emergency contact information;
- Your Hong Kong ID card number or passport number; and/or
- Your bank account or payment card information.
With respect to the Website, the type and amount of information we receive and store depends on how you use the Website. You can access most pages on the Website without telling us who you are and without providing any Personal Data. Our web servers generate anonymous logs during user visits to the Website. This information may be used to create aggregate statistics about how the Website is used.
We do not collect personal information (such as your name, e-mail address or country of residence) from use of the Website unless you choose to provide it to us. For example, if you express an interest in subscribing to our email updates, we may need your personal information such as your name and email address, etc.
Purpose of Collection
When Personal Data is collected from you, processing of Personal Data will only be for the specific purposes notified to you at the time of collection or for other purposes specifically permitted under the PDPO. If at any time it becomes necessary to change the purpose(s) for which the data is processed, you will be informed and your consent will be obtained before processing occurs.
We may collect your Personal Data for the following purposes:
- to process your donations and issue your receipts;
- to conduct donor surveys, fundraising activities or market research;
- to foster communications between you and PIHK;
- for donor and donation administration;
- for direct marketing purposes (see “Direct Marketing” below);
- for managing your participation in our programmes, fundraising events or other activities;
- for recruitment, employment and human resources management;
- to exercise any rights or to respond to any claims in connection with our fundraising or other activities;
- to comply with any court orders, laws, rules, regulations, codes of practice, guidelines or requests binding on us ; and/or
- for any purposes relating to the above or in accordance with this policy and other policies in relation to our programmes or fundraising activities.
Your Personal Data will be retained by PIHK in a secure environment, will be kept confidential and will only be used in connection with the purposes for which it is collected or as necessary for us to comply with our legal obligations, or as otherwise explained on the Website.
Direct Marketing
From time to time, we and our service providers or event partners may use your Personal Data (your name, donor ID, contact details and donation history) to send you emails, updates, or newsletters about our sponsorship and donation programmes, fundraising events, event recruitment and/or to invite you to make a donation, but we cannot do so unless with your consent.
Even if you have consented for us to use your Personal Data for direct marketing purposes, you may withdraw your consent at any time free of charge. Any e-mails we send you will enable you to opt-out of receiving further e-mails from us and you can also request that we remove you from our mailing lists by contacting us through one of the channels listed in the Website’s contact us page. The withdrawal of your consent will be processed and take effect as soon as possible.
Transfer of Your Personal Data
The Personal Data you provide will not be sold or rented. To the extent necessary to achieve the purposes specified under this policy, as notified at the time of collection and to the extent permissible by law, we will only transfer Personal Data to third-parties or other offices if they agree, contractually or otherwise, to comply with the procedures and policies in relation to the retention and security of Personal Data as outlined in this policy, or if they have adequate and appropriate retention and security measures in place.
We may provide your Personal Data to the following parties within or outside Hong Kong:
- our head office or other offices ;
- any agents, contractors, banks or third party service providers who provide administrative, telecommunications, printing, information technology, payment processing, data processing, storage or other related services to us;
- any of our auditors, legal and/or other professional advisors;
- any persons to whom we are under an obligation to make disclosure under the requirements of any laws, rules, regulations, codes of practice, guidelines or voluntary arrangements binding on us ; and/or
- subject to your consent, any agents, contractors or third party service providers who provide marketing, advertising or campaigning services to us or our event partners in connection with the development and promotion of our programmes, fundraising or education activities.
Addresses Submitted through ‘Contact us’
Please note that the addresses of those using the ‘Contact us’ facility are only retained for the purposes of reply or to be forwarded to the appropriate office for action. E-mail addresses are not otherwise retained. E-mail addresses used to contact us in this way will not be passed to any third parties.
CCTV
PIHK has adopted closed-circuit television surveillance for security purposes and to ensure a safe environment for all staff and event participants. CCTV images will only be used for the intended purposes. Security measures are in place to prevent unauthorised access to the CCTV system. We would take all practicable steps to ensure Personal Data held are protected against unauthorised or accidental access, processing, erasure or other use.
CCTV images will not be provided to third parties except for crime investigation where the CCTV images may be requested by the law enforcement departments, government agencies or regulators.
Use of Cookies
PIHK uses cookies and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or other network devices on the internet). We use analysis software to look at IP addresses and cookies for the purpose of enhancing your user experience. This information is not used to develop a personal profile of you and the log files are regularly purged.
Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. To prevent the creation of cookies, or otherwise control how cookies are used on your computer, please read the help information supplied with your Internet browser software or go to www.allaboutcookies.org.
Our Use of Cookies
The Website uses Google Analytics to help analyse how users use the site. This analytical tool uses ‘cookies’, which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form.
The information generated by the cookies about your use of the Website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on website activity for us.
PIHK will not use the statistical analytics tool to track or collect any personally identifiable information of visitors to our website. We will not associate any data gathered from this website with any personally identifying information from any source as part of our use of the Google statistical analytics tool.
Disabling and Enabling Cookies
You have the ability to accept or decline cookies by modifying the settings on your browser. Browsers are usually set to accept cookies. However, if you would prefer not to receive cookies, you may opt-out of being tracked by any websites using Google Analytics by visiting:
http://tools.google.com/dlpage/gaoptout.
Social Media Plugins
Our website also uses social plugins of social networking sites including:
www.facebook.com (Facebook), www.twitter.com (Twitter), www.youtube.com (YouTube), www.weibo.com (Weibo), www.instagram.com (Instagram) and www.linkedin.com (LinkedIn).
Because our website uses social plugins, your browser will connect to the servers of the relevant social media websites.
This results in certain data being transmitted to social media websites, in particular, your IP address, your Facebook ID if you are logged into Facebook, and information about which websites you are visiting. This information is collected by social media websites in order to personalise and socialise your browsing experience by communicating to other social media users information about the websites you are visiting. Your information, once transmitted, will be held by each social media website in accordance with its own privacy policy. If you do not wish these sites to be able to associate your browsing behaviour with your Facebook, Twitter or other user IDs, then please log out of these sites before using our website. You can deactivate social plugins at any time by changing your browser preferences.
Retention and Security of Your Personal Data
We will take all practicable steps to ensure that the Personal Data we hold is accurate and kept up-to-date. We will therefore take reasonable and appropriate steps to check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. Personal Data which is found to be inaccurate or out of date will be destroyed.
All practicable steps will be taken to ensure that your Personal Data is not kept longer than is necessary. We will therefore destroy or erase from our systems Personal Data when it is no longer required.
Once we receive your Personal Data, we will make our best efforts to ensure its security on our systems and we will take all practicable and reasonable steps to protect your Personal Data from unauthorised or accidental access, processing, erasure, loss or use.
Access to and Correction of Your Personal Data
You have the right of access to and correction of your Personal Data kept and used by PIHK in accordance with the provisions of the PDPO. For access and/or correction of Personal Data, please send your request to:
Data Protection Officer
Plan International Hong Kong Ltd, 21/F, 9 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong
Or e-mail us at [email protected]
Miscellaneous
Nothing in this policy shall limit your rights under the PDPO. This policy shall be deemed as an integral part of any forms or applications you may submit to PIHK.
Should there be any disputes or discrepancies between English and Chinese versions of this privacy policy, English language shall take precedence over Chinese language.
We may change this privacy policy from time to time. We encourage you to check this privacy policy from time to time to ensure that you are aware of the most recent version.
May 2023