THE AMERICAN CLUB FOUNDATION
PRIVACY POLICY STATEMENT 2023/24
The American Club Foundation (“ACF”) is committed to ensuring and protecting the privacy of personal data ACF collects from the American Club’s members and non-members. ACF aims to meet this commitment by implementing the principles and requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”). This Privacy Policy Statement is intended to outline ACF’s data privacy policy and practices in relation to the data we collect and use.
Collection of Personal Data
For the purpose of carrying on any operation or activities of ACF, such as making a donation or joining ACF’s volunteer activities, you may be requested to supply personal information from time to time 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 not be limited to:
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full name;
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date and place of birth;
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contact details such as e-mail address, mailing and residential address, telephone number, mobile phone number and fax number;
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American Club membership number, if any;
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information for verification of identity, including identification type and number (such as Hong Kong Identity Card or passport number) and other related information;
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billing information, including bank account and credit card information and details;
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demographic information, including age, gender, nationality, marital status, educational and professional background, community services or extra-curricular activities;
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areas of interest;
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image and voice, including photograph, video or audio recordings; and
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spouse and family information, including any of their above information.
ACF will provide a Personal Information Collection Statement on the form or webpage that collects Personal Data to inform you of the purposes of collecting the data, the classes of persons to whom the data may be transferred and other related information. Supply of Personal Data to ACF is non-obligatory but failure to do so may result in ACF being unable to process your registrations or applications and/or to provide you with the relevant services or information.
You may need to provide Personal Data about other individuals (such as your spouse or children) to ACF. In order to comply with the Ordinance, you are required to have first obtained the authorization of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to ACF’s use, disclosure and transfer of their Personal Data. If necessary, ACF may require you to provide to ACF any supporting documents in proving such authorization. You should also advise them that ACF can be contacted for further information.
Purposes of Collection of Personal Data
Your Personal Data may be used for the following purposes or any directly-related purposes:
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processing donations and donation-related administration, such as issue of acknowledgement, receipts, payment collection notices and donation records;
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performing services or administration work related to the operations of ACF, including the provision of volunteering or community services and other charitable or non-profit making causes;
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processing applications to participate in ACF’s activities or subscribe for ACF’s services, including verifying the identity of applicants, assessing their suitability and collecting statistical information relating to the applicants, in order to assist ACF in the planning and management of its activities;
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promoting activities, including fundraising activities of ACF, by, among other methods, sending you newsletters or materials regarding charitable or community causes, programs, activities and events organized by ACF which you have requested from us, and providing you with information that is relevant to your interests;
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meeting any obligations, requirements or arrangements of ACF, or in connection with (a) any law, regulation, judgment, court order, sanctions regime, within or outside Hong Kong; (b) any guidelines, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside Hong Kong; or (c) any of the rules or bye-laws of ACF relating to its operations;
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inviting you to participate in surveys or researches;
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prevention, detection or investigation of crime; and
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facilitating communications between you and ACF.
ACF may also, from time to time, use non-identifying information about the American Club’s members or non-members to promote and/or improve ACF and/or the activities it organizes or services it offers which will not particularly identify any individual.
The Personal Data collected is primarily intended to understand the ACF community’s interests, to offer better programs, to support the work of the ACF and to improve communications.
Photo-taking
During ACF’s activities or events, our staff may take pictures of you and may publish them (with or without captions which may also include Personal Data) on ACF’s or the American Club’s social media and/or communications for ACF’s marketing or promotional purposes. Please contact ACF if you have any concerns or if you do not wish to have images of you recorded for distribution.
Communications
For the purpose of ACF’s marketing and promotion, we may from time to time send you various communications, including newsletters, event notices and other ACF announcements, through post or e-mail. Please also see “Direct Marketing” below.
Direct Marketing
Subject to your consent, ACF may use your Personal Data for direct marketing carried out by ACF, and your Personal Data held by ACF may be provided to other entities for their use for direct marketing. The term “direct marketing” means the provision of marketing, advertising and promotional information in relation to any charitable or non-profit making causes or events which may be offered or arranged by ACF or third parties. It is our intention to only send you communications that you may want to receive. When you opt-in or do not opt-out from receiving promotional materials in a form in which we collect the Personal Data from you, we will contact you regularly via post and/or e-mail.
For the purpose of direct marketing, ACF intends to use your name, contact details and demographic information and market or promote the events offered or arranged by ACF or third parties. We may not use your Personal Data for such purpose unless we have received your consent.
You can unsubscribe from all marketing communications. Every time you receive a mail or an e-mail from us, you will be provided with the choice to opt-out of future mails or e-mails by following the instructions provided therein. You may also opt-out by contacting ACF if you no longer wish any of your Personal Data to be used in any of the above described direct marketing purposes without charge.
Disclosure of Personal Data
All Personal Data we collect will be kept confidential.
Where disclosure is necessary to satisfy the purpose, or a directly-related purpose, for which the Personal Data was collected, ACF may provide such Personal Data to:
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any person or company who is acting for or on behalf of ACF in respect of the purpose or a directly-related purpose for which the Personal Data was provided;
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any other person or company who is under a duty of confidentiality to ACF and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
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the business partners of ACF for direct marketing use as described in “Direct Marketing” above;
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any financial institutions, including banks, necessary to establish and support the donations of any funding activities organized by ACF or payment for any services provided to you;
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agents, contractors, suppliers and any third party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to ACF in connection with its operations;
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government and regulatory authorities, investigative bodies and law enforcement agencies and other organizations, as required or authorized by law, by court order or in response to any legally valid inquiry, or otherwise necessary to the establishment of legal claims or defenses, to obtain legal advice, or to exercise and defend ACF’s legal rights; and
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your authorized representatives when requested by you to do so.
As ACF may release your Personal Data to a third party, we will take steps to prohibit such third parties from using the Personal Data for any purpose other than for the purpose specified in their respective contracts. Your Personal Data may be transferred to, stored and processed in Hong Kong or other jurisdictions where the third parties are located or from which the third parties provide us services.
By submitting your Personal Data to ACF, you understand and consent to the transfer of such information as described above.
Retention of Personal Data
All Personal Data we collect will be stored only for a duration that is relevant to the purpose for which it was collected and for as long as permitted or required by the applicable law.
Use of Cookies
Cookies are small text files that are created by some websites to a visitor’s hard drive while that visitor is browsing the website. ACF may use cookies on its website to track preferences of its visitors. Cookies are commonly used to provide business and marketing information to the website owners and to track the number of page visits from the same computer or browser for statistical purposes. Cookies identify your browser but cannot be used to disclose your individual identity. You may refuse to accept cookies but doing so may affect certain functions or your access to certain content on our website.
By continuing browsing on our website, you consent to our use of cookies and agree that we can store and access cookies, IP addresses and use other methods in order to collect website usage data and improve on-line experience.
Data Security Measures
ACF is committed to protecting the security of your Personal Data. ACF’s employees are trained on the importance of privacy and protection of Personal Data. We intend to limit the number of individuals within ACF with access to Personal Data to those directly involved in the process of organizing activities or events or providing services to you.
Notification of Data Breach
In the unlikely event of a data breach, we will comply with any applicable laws and regulations which would require us to notify you of the disclosure of personal data.
Third Party Websites
ACF’s website may contain links to other websites which are operated by third parties.
ACF is not responsible for the privacy practices of these third party websites. ACF has no control over the content of the linked websites or how they deal with your Personal Data. You should review the privacy policy for such third party websites to understand how your Personal Data may be used by those third parties.
Children’s Privacy
ACF understands the importance of protecting children’s privacy. ACF does not knowingly solicit or collect Personal Data from persons who are under the age of 16 without prior consent from a parent or guardian.
Changes to the Privacy Policy Statement
As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will review our policies, procedures and processes from time to time. Any changes to this Privacy Policy Statement will be published by ACF on this website and will become effective upon publishing of the revised statement.
Data Access, Correction Requests and Other Enquiries
You have the right to request access to and correction of your Personal Data held by ACF. ACF may charge a reasonable fee for the processing of such data access or correction request.
If you wish to do so, please send an e-mail or a letter to:
The American Club Foundation
48th Floor, Two Exchange Square
8 Connaught Place
Central, Hong Kong
Attention: Data Protection Officer
E-mail: info@acfhk.org
In relation to your request to access or correct your Personal Data, we will require that you prove your identity to us in order to protect your Personal Data, which may include your identification document and your correspondence address. Where a request is made, any correspondence or application may be kept and added to your Personal Data.
Please contact us if you have any privacy questions or concerns.
Your Consent
By using the internet service provided by ACF, you consent to your Personal Data being used in the manner set out above. You further consent to ACF using your Personal Data for the purposes as stated and for ancillary purposes.
PERSONAL INFORMATION COLLECTION STATEMENT (PICS)
The American Club Foundation (“ACF”) recognizes its responsibilities under the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”) in relation to the collection, holding, processing, use and transfer of personal data it collects from the American Club’s members and non-members. This Personal Information Collection Statement (“PICS”) is provided to you pursuant to the Ordinance which intends to outline how ACF collects, uses, processes and transfers your personal data in connection with any of our activities, events or services (the “Event”) you applied or registered.
By submitting your application or registering for or participating in the Event, you agree to be bound by this PICS. If you do not agree to this PICS, you must not submit any such application or register for or participate in the Event.
Supply of your personal data to ACF is non-obligatory but failure to do so may result in ACF being unable to process your registration or application for the Event and/or to provide you with the relevant services or information, and eventually, may prevent you from participating in the Event.
If you provide us personal data of any other individuals (such as your spouse or children), you warrant and undertake that you have obtained the authorization of such individuals before providing to ACF for its use, disclosure and transfer of their personal data in accordance with this PICS. If necessary, ACF may require you to provide any supporting documents in proving such authorization.
Purposes of Collection of Personal Data
The personal data you provided to us may be used for the following purposes or any directly-related purposes:
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processing donations and donation-related administration, such as issue of acknowledgement, receipts, payment collection notices and donation records;
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performing services or administration work related to the operations of ACF, including the provision of volunteering or community services and other charitable or non-profit making causes;
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processing applications to participate in the Event, including verifying the identity of applicants, assessing their suitability and collecting statistical information relating to the applicants, in order to assist ACF in the planning and management of the Event;
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promoting activities, including fundraising activities of ACF, by, among other methods, sending you newsletters or materials regarding charitable or community causes, programs, activities and events organized by ACF which you have requested from us, and providing you with information that is relevant to your interests;
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meeting any obligations, requirements or arrangements of ACF, or in connection with (a) any law, regulation, judgment, court order, sanctions regime, within or outside Hong Kong; (b) any guidelines, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside Hong Kong; or (c) any of the rules or bye-laws of ACF relating to its operations;
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inviting you to participate in surveys or researches;
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prevention, detection or investigation of crime; and
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facilitating communications between you and ACF.
ACF may also, from time to time, use non-identifying information about the American Club’s members or non-members to promote and/or improve ACF and/or the activities it organizes or services it offers which will not particularly identify any individual.
The personal data collected is primarily intended to understand the ACF community’s interests, to offer better programs, to support the work of the ACF and to improve communications.
Photo-taking
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During Events, our staff may take pictures of you and may publish them (with or without captions which may also include personal data) on ACF’s or the American Club’s social media and/or communications for ACF’s marketing or promotional purposes. Please contact ACF if you have any concerns or if you do not wish to have images of you recorded for distribution.
Direct Marketing
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Subject to your consent, ACF may use the personal data provided in any such application or registration for direct marketing carried out by ACF, and such personal data held by ACF may be provided to other entities for their use for direct marketing. The term “direct marketing” means the provision of marketing, advertising and promotional information in relation to any charitable or non-profit making causes or events which may be offered or arranged by ACF or third parties.
For the purpose of direct marketing, ACF intends to use your name, contact details and demographic information and market or promote the events offered or arranged by ACF or third parties. We may not use the personal data for such purpose unless we have received your consent.
You can unsubscribe from all marketing communications. Every time you receive a mail or an e-mail from us, you will be provided with the choice to opt-out of future mails or e-mails by following the instructions provided therein. You may also opt-out by contacting ACF if you no longer wish any of the personal data provided in any such application or registration to be used in any of the above described direct marketing purposes without charge.
Disclosure of Personal Data
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All personal data we collect will be kept confidential.
Where disclosure is necessary to satisfy the purpose, or a directly-related purpose, for which the personal data was collected, ACF may provide such personal data to:
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any person or company who is acting for or on behalf of ACF in respect of the purpose or a directly-related purpose for which the personal data was provided;
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any other person or company who is under a duty of confidentiality to ACF and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
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the business partners of ACF for direct marketing use as described in “Direct Marketing” above;
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any financial institutions, including banks, necessary to establish and support the donations of any funding activities organized by ACF or payment for any services provided to you;
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agents, contractors, suppliers and any third party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to ACF in connection with its operations;
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government and regulatory authorities, investigative bodies and law enforcement agencies and other organizations, as required or authorized by law, by court order or in response to any legally valid inquiry, or otherwise necessary to the establishment of legal claims or defenses, to obtain legal advice, or to exercise and defend ACF’s legal rights; and
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your authorized representatives when requested by you to do so.
By submitting the personal data in any such application or registration to ACF, you understand and consent to the transfer of such information as described above.
Retention of Personal Data
All personal data we collect in any such application or registration will be stored only for a duration that is relevant to the purpose for which it is collected and for as long as permitted or required by the applicable law.
Data Security Measures
ACF is committed to protecting the security of your personal data. ACF’s employees are trained on the importance of privacy and protection of personal data. We intend to limit the number of individuals within ACF with access to personal data to those directly involved in the process of organizing activities or events or providing services to you.
Data Access, Correction Requests and Other Enquiries
You have the right to request access to and correction of your personal data submitted to us. ACF may charge a reasonable fee for the processing of such data access or correction request.
If you wish to do so, please send an e-mail or a letter to:
The American Club Foundation
48th Floor, Two Exchange Square
8 Connaught Place
Central, Hong Kong
Attention: Data Protection Officer
E-mail: info@acfhk.org
In relation to your request to access or correct your personal data, we will require that you prove your identity to us in order to protect your personal data, which may include your identification document and your correspondence address. Where a request is made, any correspondence or application may be kept and added to your personal data.