1. INTRODUCTION

1.1 Purpose of this Privacy Policy

Sham Shui Po District Health Centre (referred to in this Privacy Policy as “SSPDHC”, “we”, “us”or“our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you use our website or the Health is Core mobile application for iOS or Android (the “App”) and tell you about your privacy rights and how the law protects you.

This Privacy Policy aims to give you information on how we collect and process your personal data through your use of the Website/App, including any data you may provide through the Website/App when you sign up to our newsletter, or request services and/or take part in an event.

It is important that you read this Privacy Policy together with any other Privacy Policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them.

1.2 Data Controller

SSPDHC is a “data controller” of your personal data.

In simple terms, this means that we (i) “control” your personal data, including making sure that it is kept secure; and (ii) make certain decisions on how to use and protect your personal data, but only to the extent that we have informed you about the use or as otherwise permitted by law.

1.3 Contact Information and Complaints

If you have any questions about this Privacy Policy or any questions regarding our use of your personal data, please contact us at [email protected] or post to
Sham Shui Po District Health Centre
201A, 2/F Mei Hei House,
Sham Shui Po, Kowloon
Marked: Personal Data Privacy Enquire

1.4 Changes to this Privacy Policy

This Privacy Policy is regularly reviewed. Please note that this Policy may be amended from time to time without prior notice. You are advised to check for the latest version on a regular basis. If there is any inconsistency or conflict between the English and Chinese versions of this Statement, the English version shall prevail.

1.5 Third-Party Links

The Website/App may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website/App, we encourage you to read the privacy policy of every website you visit.

2. THE DATA WE COLLECT ABOUT YOU

The types of personal data we collect, use and store about you will depend on the services you have requested from us and/or the nature of your interaction with us. When using our Website/App, we collect and process the following types of personal data (include but not limited to):

  • your first name, last name, username or similar identifier, date of birth, health records and medical histories (“Identity Data”);
  • your address, email address and telephone numbers (“Contact Data”);
  • your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website/App (“Technical Data”);
  • your username and password, your application, your interests, preferences, feedback and survey responses (“Profile Data”);
  • information about how you use our Website/App and other services, for example, how often you come to our centres and events (“Usage Data”).

We do not collect any special categories of personal data about you (this includes details about your sex life, sexual orientation, political opinions and trade union membership). Nor do we collect any information about criminal convictions and offences.

3. HOW WE COLLECT DATA ABOUT YOU

3.1 Direct Interactions

We collect Identity Data and Contact Data about you that you provide to us by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • register on our Website/App;
  • apply for our services or programs;
  • subscribe to our newsletter;
  • enter an event or survey; or
  • give us feedback or contact us in any way or form.

Please notice that all data you entered in the Website/App cannot be deleted after submission.

3.2 Automated Technologies and Interactions (Cookies Policy)

As you interact with our Website/App, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using Cookies and other similar technologies.

Cookies are small files of letters and numbers stored by computer after being sent to your computer when you visit the Website or the App. Whenever you visit the same Website/App again, the information stored in the Cookies can be retrieved to notify the Website/App of your previous activity. We use Cookies to facilitate Website/App navigation, maintain quality of online service, provide additional security, allow the customization of your access to the Website/App and remember you when you return to the Website/App.

Cookies cannot give us access to your mobile phone or to information beyond what you provide us and we don't store personally identifiable information such as your name or address in Cookies we create, but we do use encrypted information gathered from them to help improve your experience on our Website/App. If you do not wish to enable Cookies, you'll still be able to browse the Website/App and use them for research purposes.

You can set your browser to refuse all or some browser Cookies, or to alert you when the Website/App sets or accesses Cookies. If you disable or refuse Cookies, please note that some parts of the Website/App may become inaccessible or not function properly.

When you visit our Website/App, you may notice some Cookies that are not related to OnTheList. If you go on to another website/app that contains embedded content, you may be sent Cookies from these websites/apps. We do not control the setting of these Cookies, so we suggest you check the third-party website/app for more information about their Cookies and how to manage them.

To find out more about Cookies, including how to see what Cookies have been set and how to manage and delete them, visit www.aboutcookies.org or www.allaboutcookies.org.

4. HOW WE USE YOUR PERSONAL DATA

4.1 Data Usage

We are committed to only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the service, we are about to enter into or have entered into with you (“Performance of Service”).
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (“Legitimate Interests”).
  • Where we need to comply with a legal obligation (“Legal Obligations”).

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please feel free to contact us any time.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4.2 Marketing and Promotional Purposes

As the Website/App is an information sharing platform, we may provide you with our updated news, services information, course invitation, gift redemption, fundraising appeal or volunteer service information.

Your photos taken in class/our centres may be shown on the Website/App and/or website, service newsletter and/or activities promotion or service report purpose after signing the member registration form with acceptance of statement on personal information collection.

If you want to stop receiving any of above information and usage of your photos, please contact us at [email protected] . Upon your request at any time and at no charge, we will cease to use your personal data for marketing and promotional purposes.

4.3 Opting Out

You can ask us or third parties to stop sending you marketing messages at any time by:

Where you opt-out of receiving these marketing messages or newsletters, this will not apply to personal data provided to us as a result of service provide (which we will continue to process in order to perform the service with you or as a result of our regulatory or legal obligations).

5. DISCLOSURES OF YOUR PERSONAL DATA

According to the Personal data (Privacy) Ordinance, the centre will only disclose personal information to relevant parties in the following circumstances:

  • Consent from the user /authorizer/guardian; or
  • required by law; or
  • Protect the interests of the users and be carried by the law

All personal data held by our Centre will be kept confidential and only can be used by services-related staff, authorized staff who are not allowed to store, download and transfer the personal data and for personal use.

However, the Centre may share your personal data with the following parties:

  • External Third Parties as set out in Clause 9 (Definitions) below; and

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

If the Centre needs to disclose your personal data to external parties, such as government departments, social service organization, etc., your written consent is needed before making data transfer.

6. DATA SECURITY

6.1 We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agent, contractors and other third parties who need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6.1.1 This Website/App uses the Secure Socket Layer (SSL) communication protocol to transmit the information registered online to ensure that your personal information is protected. The personal information you provide on this Website/App will be kept confidential, and only authorized persons can access it.

6.1.2 The search service on this Website/App is provided by an independent contractor of the Centre. The independent contractor informed us that the company will not collect personally identifiable information when providing search results on this Website/App. However, the independent contractor will provide some anonymous information obtained through the use of the search service to the Centre for the purpose of analyzing the traffic of the Centre's Website/App. The Centre will not match the data collected from any of the aforementioned search activities with any personally identifiable information that may be held by the Centre.

6.1.3 It may be necessary for the Centre to transfer certain personal data to places outside the HKSAR in order to carry out the purposes or directly related purposes, for which the personal data were collected. Where such a transfer is performed, your consent in accordance with the requirement of the Ordinance will be obtained.

7. DATA RETENTION

We will only retain your personal data for as long as reasonably (3 years) necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data: see Clause 10 (Your Legal Rights within Hong Kong) below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

8. DATA ACCESS, CORRECTION AND QUERIES

If you are currently staying in Hong Kong, you are entitled, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486, the laws of Hong Kong) (the “Ordinance”), to check whether we hold data about you and to have access to those data. If any of these data are incorrect or inaccurate, you have the right to correct or update them. When you request access to or to correct personal data, we may need to take measures to verify your identity. In accordance with the Ordinance, we reserve the right to charge a reasonable fee for complying with your data access request. You may contact us at:
Sham Shui Po District Health Centre
201A, 2/F Mei Hei House,
Sham Shui Po, Kowloon

9. DEFINITIONS

In this Privacy Policy, the following expressions shall have the following meanings except where the context otherwise required:

“External Third Parties”shall mean (a) service providers based in Hong Kong who provide IT and system administration services, and logistics support; and (b) the Inland Revenue Department, regulators and other authorities based in Hong Kong who require reporting of processing activities in certain circumstances.

“Legitimate Interests” shall mean the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Legal Obligations” shall mean processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

“Performance of Service” shall mean processing your data where it is necessary for the performance of the service to which you are a party or to take steps at your request.

10. THE CONSEQUENCE OF NOT ACCEPTING THIS POLICY

You can refuse the policy above. If you refuse the policy, please note that all the function of the Website/App would become inaccessible or not function, and your application will be canceled too.

  • I agree with this privacy policy
  • I agree to receive the notification and the sharing information

In the event of discrepancies between the English and any foreign language translation, the English version shall prevail.

Date of revision: 13 July 2022