The WEMP Foundation Limited (“The WEMP Foundation”, “WEMP”, “we”, “us”, or “our”) recognizes and understands that customers, website visitors are concerned about the privacy of personal data. WEMP pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).

This Privacy Policy Statement outlines WEMP’s practices and the choices you have concerning the collection and use of your personal data. This Privacy Policy Statement should be read together with the applicable Terms and Conditions of the relevant service and the website provided by WEMP (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Privacy Policy Statement and the Terms and Conditions concerning matters relating to personal data, this Privacy Policy Statement shall prevail. This Privacy Policy Statement should be also read together with the applicable personal information collection statement of the relevant service and the website provided by WEMP (the “PICS”), provided that, in the event of any inconsistency between this Privacy Policy Statement and the PICS concerning matters relating to personal data, the PICS shall prevail.

In this Privacy Policy Statement, “personal data” means data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.

You may be invited to provide to WEMP your personal data on WEMP’s relevant website(s), or through other media for different purposes at different times. If you are under the age of eighteen (18), you must obtain consent from your parent or guardian before you provide WEMP with your personal data.

We will identify any information which is mandatory when we collect information from you. You may choose not to provide us with the information, but failure to do so may inhibit our ability to provide our goods and/or services to you and you may not be able to use all the functions of WEMP’s website(s).

When you visit WEMP’s website(s), the servers of WEMP will collect only data relating to your visits to/use of such website(s), including but not limited to your IP address, domain name, browser type and access time (“Log Files”) but will not collect your personal data. However, if you register on our website, we may combine your Log Files with other personal data we collect from you, in which case such Log Files shall be considered your personal data for the purposes of, and will be used in accordance with, this Privacy Policy Statement and the PICS.

When you browse the website(s) of WEMP, cookies will be stored in your computers, mobile phones or other devices for internal navigation and programming only. We may use cookies and other tracking mechanisms described below to track information about your use of WEMP’s website(s) (“Tracking Data”). We may combine this Tracking Data with other personal data we collect from you, in which case such Tracking Data shall be considered your personal data for the purpose of, and will be used in accordance with, this Privacy Policy Statement and the PICS.

Cookies are alphanumeric identifiers that we transfer to your computers, mobile phones or other devices through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate WEMP’s website(s), while others are used to enable a faster log-in process, or to allow us to store and track information about your interests and preferences at WEMP’s website(s).

We may also engage third parties to track and analyse non-personally identifiable data from WEMP’s website(s). We use the data collected by such third parties to help us administer and improve the quality of WEMP’s website(s) and to analyse usage of the same. This is unrelated to and separate from your personal data. Such third parties may combine the non-personally identifiable data that we provide about you with other information that they have collected. You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functionality of the website(s) (where applicable) of WEMP.

If you interact with WEMP on social media platforms (for example if you “Like” WEMP’s Facebook page), WEMP can interact with you and send you messages via these platforms. WEMP will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your personal data. You should read the privacy policies of the respective platform operators. Furthermore, we are not responsible for what third parties post on our social media accounts.

For the different purposes in the course of conducting WEMP’s business, you may be required to provide to WEMP your personal data, which may include your name, gender, age (or age range), month of birth, contact details, e-mail address, mailing/residential/correspondence address, contact number, membership number, marital status, family status, educational level, occupation, username and password, Log Files, Tracking Data, interests and favourite activities, transaction information (including your characteristics and transaction behavior), social media account information, etc. Details of personal data to be collected will also be set out in the relevant PICS provided to you on or before collection of such personal data.

WEMP will use your personal data for the following purposes and for other specific purposes identified in the PICS provided to you on or before your personal data is collected, agreed between you and WEMP or required by applicable laws, rules or regulations from time to time:

1. to offer you our programmes, funding initiatives and services,
2. to process your application for participating in any of our programmes, funding initiatives and/or services;
3. to verify of your identity and eligibility to participate in our programmes, funding initiatives and/or services;
4. to make payments or provide you with goods and services;
5. to handle your enquiries, requests, complaints and other communications with you;
6. to manage WEMP’s accounts and records;
7. to conduct statistical analysis to improve our programmes, funding initiatives, services and WEMP’s website(s);
8. to make such disclosures as required by law; and
9. to fulfil any other purposes directly relating to any of the above purposes.

WEMP may share your personal data with, and your personal data may be used by, third parties as set out in the PICS for those specified purposes.

You may be requested to provide to WEMP certain personal data for specific services. If you fail to provide accurate or update information as requested for each specific service, the provision of such services by WEMP may be affected.

WEMP will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are or are to be used. If you are a subscriber of WEMP services, your personal data will be retained for a reasonable period after termination of your subscription for verification and audit purposes. The above is subject to any legal, statutory, regulatory or accounting requirements.

WEMP may have on-line stores or some services and/or products which are hosted in the website(s) and/or mobile application(s) of WEMP but are operated by third party merchants. If you provide your personal data to the third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that your personal data is beyond the control of WEMP and thus is outside the scope of protection afforded by WEMP.

The website(s) of WEMP may from time to time contain linkages to other third party websites and/or mobile applications. These other third party websites and/or mobile applications are independent from the website(s) or mobile application(s) of WEMP. WEMP has no control or management over the contents of such other websites, mobile applications or their privacy policies or compliance with law. You should be fully aware that the provisions of such links do not constitute an endorsement, approval, or any form of association by or with WEMP. WEMP does not provide your personal data to such other websites or mobile applications, unless expressly stated otherwise. WEMP has no control over your personal data submitted by you, if any, to other websites and/or mobile applications. This Privacy Policy Statement only applies to the website(s) and/or mobile application(s) of WEMP. You should read the respective privacy policies of other websites or mobile applications.

WEMP may provide your personal data to the people and/or companies providing services (whether within or outside Hong Kong) to WEMP in connection with the specific purposes set out in the PICS and paragraph 6 above (the “WEMP Service Providers”). In these cases, the WEMP Service Providers are required to use your personal data consistent with the agreements WEMP enters into with them as well as this Privacy Policy Statement and the PICS.

The physical records of your personal data will be stored in secured places (whether within or outside Hong Kong) with restricted access by us or those who we share your personal data with in accordance with this Privacy Policy Statement and the PICS. The electronic records of your personal data will be stored in the servers of WEMP and/or relevant WEMP Service Providers as our data processors (whether within or outside Hong Kong) located in secured places and protected by adequate IT security measures (e.g. encryption for transmission of sensitive data through the internet in appropriate cases), or we will procure by contract or use our reasonable endeavours to ensure that those who we share your personal data with (whether within or outside Hong Kong) in accordance with this Privacy Policy Statement and the PICS do the same. Only authorized personnel of WEMP (who have been trained to handle your personal data properly and bound by a duty of confidentiality) will have access to these records and servers on a “need-to-know” and “need-to-use” basis, or we will procure by contract or use our reasonable endeavours to ensure that those who we share your personal data with (whether within or outside Hong Kong) in accordance with this Privacy Policy Statement and the PICS do the same.

We will take all reasonable measures to ensure that your personal data is stored and processed securely and to protect your personal data against unauthorised or accidental access, processing, erasure, loss or use, regardless of the place or country in which it is stored, and we will procure by contract or use our reasonable endeavours to ensure that any third parties will do the same. Our cross-border transfer of your personal data will be conducted in accordance with this Privacy Policy Statement, the PICS and applicable laws for the protection of your personal data.

No data transmission over the internet or any other public network can be guaranteed to be completely secure, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorized access to your password. You are advised to sign out from your account when finished particularly when using a shared computer.

WEMP may disclose your personal data as required by law, any government departments, regulatory authorities, enforcement agencies and courts of competent jurisdiction. WEMP excludes all liability for disclosure of your personal data in this manner.

WEMP may provide your personal data to competent courts of law, law enforcement agencies and/or regulatory bodies for compliance with applicable laws and regulations and for the protection or enforcement of our legal rights.

You have the right to request in writing to the Personal Data Privacy Officer of WEMP to:

1. check whether WEMP hold any of your personal data;
2. access your personal data held by WEMP (if any);
3. require WEMP to correct your personal data that is inaccurate (if any);
4. ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us; and
5. withdraw your consent to the use of your personal data for direct marketing purposes (see below).
   
   

All such requests will be handled promptly in accordance with the requirements of the PDPO. WEMP may charge you a reasonable fee for processing your personal data access request. Please refer to paragraph 19 for the Personal Data Privacy Officer’s contact details.

We cannot use or provide to third parties (whether intra-group and/or external parties) your personal data for direct marketing purposes without your consent. Subject to your consent, we may use or provide to third parties (whether intra-group and/or external parties) your personal data (including your [name, email address, mobile telephone number] and other relevant contact information) for direct marketing purposes in accordance with the PICS provided to you on or before collection of your personal data. You may withdraw your consent any time by writing or email to the Personal Data Privacy Officer (please refer to paragraph 19 for the contact details).

This Privacy Policy Statement may from time to time be updated, revised and amended. Any update, revision or amendment will be effective immediately upon being posted on website(s) of WEMP. Where legally required, we shall notify you and/or obtain your consent for specific material updates, revision or amendment. If you do not accept the updates, revision or amendment, and/or provide your consent, then we may not be able to provide goods or services to you. You are advised to check the website(s) of WEMP for updates to this Privacy Policy Statement on a regular basis.

In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our affiliates or our affiliates’ businesses, WEMP may need to transfer your personal data to the new entity in accordance with the PICS. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.

If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by WEMP for direct marketing purposes, please contact the Personal Data Privacy Officer of WEMP at:

Unit B, 10/F, Neich Tower
128 Gloucester Road, Wanchai
Hong Kong
Attention: Personal Data Privacy Officer
(Marked Confidential, and with the name of WEMP)

or by email at hello@hkwemp.org.

If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.