Privacy Policy Statement

The Hong Kong Jockey Club Equine Welfare Research Foundation Limited (“the Foundation”), which is established by The Hong Kong Jockey Club (“the Club”), is committed to ensuring the privacy and security of the Personal Data (as defined below) it holds. The Foundation aims 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 Foundation’s privacy practices.

For the purpose of this Privacy Policy Statement, "subsidiaries" or “entities” of the Club refers to the "subsidiaries" or “entities” which the Club 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 businesses and operations of the Foundation, including the provision of facilities and services to you, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data") such as, but not limited to, the following:

Information about you such as your full name, educational background, professional qualifications, employment history, public appointments, awards and recognitions and community services;
Photographs and other images of yours;
Contact details such as email address, mailing and residential address, telephone/mobile number;
Your usage, transactional and activity records of the facilities and services provided and/or operated by the Foundation;
Information for verification of identity, including identification type and identification number (such as your Hong Kong Identity Card and passport number) and other related information;
Your interests, preferences and opinions and your responses to market surveys and contests conducted by the Foundation or on its behalf;
Information the Foundation collects about you when you use the Foundation’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 Foundation’s Websites, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and browsing history, etc.); and/or
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 Foundation’s rules and bye-laws.

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

Occasionally, you may need to provide Personal Data about other individuals to the Foundation (such as referee(s) from your institution, researcher(s) of your project(s), funders, suppliers or contractors). In that event, for the compliance 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 Foundation’s possible use, disclosure and transfer of their Personal Data. You agree to, upon the Foundation’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 Foundation can be contacted for further information.

Use of Personal Data

Your Personal Data may be used for the following purposes:

Providing facilities, services and support or performing administration work related to the following operations of the Foundation, including but not limited to, the Foundation’s management, administration and operations of its funding programmes such as grants, scholarships, sponsorship or fellowship of any association established by the Foundation in connection with such funding programmes and/or other related charitable matters ("Funding Programmes");
Processing your application, request and/or enquiries for, or in relation to the Funding Programmes;
Contacting you for the purpose of and/or in relation to the provision of the Foundation’s facilities and services as set out in paragraph 1, and addressing any enquiries related thereto;
Verifying your identity and assessing your suitability and eligibility for the Funding Programmes (regardless of whether you are a new applicant or an applicant who re-applies for such funding programmes);
Matching (as defined in the Ordinance) your Personal Data with other data collected (by the Foundation or third parties) for other purposes and automated decision processing (including profiling), in relation to the processing, assessment, administration, operations and/or management of the Funding Programmes;
Conducting data analysis (e.g. analysing trends, usages and other user behaviours) and commercial exploration of big data applications;
Promoting and advertising any Funding Programmes, such as sending you newsletters, information or promotional materials regarding charitable causes, activities and events organised or sponsored by the Foundation (please see further details in "Direct Marketing" below);
For the purposes of improving or designing new facilities and services, including to ensure that the Foundation’s Websites, Apps and Web Pages function correctly;
Maintaining and developing the Foundation's business systems and infrastructure, including testing and upgrading of these systems;
Facilitating and maintaining communication with recipients of grants, scholarships and other award recipients;
Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, or establishing, exercising or defending any legal rights of the Foundation 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 articles of the Foundation relating to the Foundation's core operations; or
any other agreements between you and the Foundation.

Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the Foundation 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;
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 Foundation;
Responding or taking part in legal proceedings, including seeking professional advice; and/or
All other legitimate business purposes and purposes directly related to or incidental to the above.

The Foundation may also use from time to time aggregate non-identifying information about applicants to better design and improve the Foundation's facilities and services that it offers. This information will not identify any individual in particular.

Direct Marketing

Subject to the Foundation having obtained the relevant consent from you, the Foundation 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 Foundation.

For such purposes, your Personal Data held by the Foundation may be provided to other Club entities and/or their respective business partners for use for direct marketing subject to your consent. The Foundation or a Club entity 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 the Foundation or a Club entity or their respective business partners hold about you with them.

You can always opt-out free-of-charge by following the opt-out instructions contained in the relevant communications or contacting the Foundation’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 Foundation may still send you communications which are of administrative nature.

The Foundation may create indirect group profiling by way of analysing your preference characteristics manifested in the information the Foundation has about you (e.g. your preferences).

Disclosure of Personal Data

Personal Data supplied to the Foundation will be kept confidential. However, the Foundation 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:

Any Club Entities for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above), and to their business partners for direct marketing use as described in “Direct Marketing” above;
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 Foundation and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
The Foundation’s consultants, agents, contractors, suppliers and any third party service provider of the Foundation which provides administrative, marketing and research, distribution, data processing and analytics, telemarketing, telecommunications, computer, financial, payment or other services to the Foundation in connection with the operations of its business;
The Foundation’s insurers and their reinsurers, brokers and agents;
Government and regulatory authorities, investigative bodies, courts, law enforcement agencies and other organisations, as required or authorised by law, orders or requests;
Any financial institutions or payment services providers necessary to establish and support the payment of any facilities and services provided to you; and/or
Your authorised representatives or legal advisers when requested by you to do so.

The Foundation 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 Foundation 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 Foundation and/or the Club's legal rights, or to protect the life, body or property of an individual; or (iii) for enforcement of the Foundation and/or the Club’s rules and bye-laws or prevent unauthorised access to their premises. This also applies when the Foundation and/or the Club 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 Foundation and/or the Club's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by activities causing such interference.

The Foundation 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 Foundation and/or the Club or as part of a corporate reorganisation or other change in corporate control.

The Personal Data that the Foundation and/or the Club 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 Foundation or using any of the Foundation’s facilities and services of the Funding Programmes, you understand and consent to such transfer.

Links to Third Party Websites

The Foundation’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 Foundation has 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 Foundation's Websites, Apps and/or Web Pages, you agree that the Foundation 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 Foundation uses 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 Foundation may retain your Personal Data for longer periods of time, for instance, where the Foundation is required to do so to meet legal, statutory, regulatory, tax or accounting requirements.

Commitment to Data Security

The Foundation is committed to protecting the security of your Personal Data. It uses 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 Foundation from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and the Foundation does not warrant that its servers or network will be immune from such attacks.

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

Changes to this Privacy Policy Statement

The Foundation may update this Privacy Policy Statement from time to time which will be posted on its Website at https://www.hkjcequinewelfare.org.hk/, so as to inform you what information the Foundation gathers, how it might use that information and whether it discloses such information to anyone. You are also advised to check the latest Privacy Policy Statement posted on the Foundation’s Website at https://www.hkjcequinewelfare.org.hk/ 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 Foundation and do not give us any of your information. By continuing to use the facilities or services of the Foundation 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 Foundation about you and to correct such data. The Foundation 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
The Hong Kong 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.