Privacy Policy

Last updated 1 June 2024, v.2

This Privacy Policy describes the practices of Social Career Limited ("Social Career") and The Hong Kong Jockey Club Charities Trust (the "Trust", and together with Social Career, the "Provider") in respect of the collection, use and disclosure of your Personal Data that we may collect from time to time when you use the JCVTP (as defined below).

We take our obligations regarding your privacy seriously. By accessing or using the JCVTP, you agree to this Privacy Policy and our Terms of Service.

When we collect any Personal Data from you, we will provide you with a PICS (defined below). This Privacy Policy is not intended to supersede any PICS or any express consent provided by you. In the event of any inconsistency, the PICS provided to you on or before the collection of your Personal Data, or your express consent, will take precedence over this Privacy Policy.

1. Definitions

1.1 Capitalised terms used in this Privacy Policy shall have the following meanings:

"App" means the Provider’s proprietary mobile application available on the Apple App Store and Google Play Store, which can be used to access the JCVTP.

"JCVTP" means the JC Volunteer Together Platform, and includes the volunteer opportunity aggregator and recognition platform and App, operated by Social Career and funded by the Trust.

"NGO" means a not-for-profit non-governmental organisation, and for purposes of this Privacy Policy, shall include all forms of Hong Kong based not-for-profit organisations.

"Personal Data" means any data or information relating to an individual and from which it is practicable for the identity of that individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.

"PICS" means any personal information collection statement provided by us to you on/or before the collection of your Personal Data.

"Social Career", "we", "us" or "our" means Social Career Limited, a company incorporated under the laws of Hong Kong with its registered office at Unit 20-135 HK Hong Kong Island, 21/F 14 Tai Koo Wan Rd, Tai Koo.

"Terms" means the terms of service for use of the JCVTP found at Terms of Service, and which may be amended by us from time to time at our sole discretion, without notice.

"Trust" means The Hong Kong Jockey Club Charities Trust

"Users" means any individual, entity or organisation, who accesses, views or uses the JCVTP.

"User Account" means an account established by us in connection with the JCVTP for a User to be able to use the JCVTP.

"you" or "your" means you, the person who is accessing, using or viewing the JCVTP.

"Volunteer Contribution Record" means the record of time spent by a User at volunteer activities or events in Hong Kong, including a Volunteer Opportunity.

"Volunteer Opportunities" means opportunities offered, posted or featured on Volunteer Platform seeking volunteers to provide services to an NGO for free.

"Volunteer Platform" means third party volunteer platforms accessed via JCVTP offering the Volunteer Opportunities.

1.2 Whenever the words include, includes, including or in particular (or similar deviates) are used, they are deemed to be followed by the words without limitation.

2. What type of Personal Data is collected by us?

2.1 The types of Personal Data we may collect, from time to time, includes:

(a) your full name and email address;

(b) your mobile number and residential district;

(d) information regarding your volunteer experience and Volunteer Opportunities in which you have participated (including the NGO you volunteered with, and the date, time, venue and nature of the Volunteer Opportunity);

(e) the types of Volunteer Opportunities in which you may be interested;

(f) any communications between you and the Provider;

(g) details of your visits to our JCVTP and your User Account activities; and

(h) the information described in paragraph 3 below.

2.2 If you do not provide us with your full name and either your email address or mobile number, we cannot set up your User Account and you will be unable to use the JCVTP.

2.3 When we request any other Personal Data from you, we will notify you at the time of collection as to whether or not it is mandatory for you to provide such Personal Data to us. If you do not provide any mandatory Personal Data to us, then we may not be able to: (i) process or complete your application for a User Account; (ii) keep a record and generate a certificate reflecting the Volunteer Opportunities in which you have participated; (iii) respond to any queries submitted by you; or (iv) redeem rewards through the JCVTP.

3. Information We Collect Automatically

We use technologies such as, but not limited to, cookies and pixel tags to provide, monitor, analyse, promote and improve the JCVTP. For example, a cookie is used to remember your user name when you return to the Website, and to improve our understanding of how you interact with the JCVTP. You can block cookies on your web browser; however please be aware that some features of the JCVTP may not function properly if the ability to accept cookies is disabled.

Log Files

When you use the JCVTP, our servers automatically record certain information in server logs. These server logs may include information such as your web request, Internet Protocol (IP) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the JCVTP, domain names, landing pages, pages viewed, mobile carrier, and other such information. Log files help us to monitor, analyse, improve and maintain the JCVTP and to diagnose and fix any JCVTP-related issues.

Device Identifiers

When you access the JCVTP using a mobile device, we collect specific device information contained in your mobile device's "device identifier." This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your User Account and will use data associated with your device identifier to customise our JCVTP to your device and to analyse any device-related issues.

Location Information

We may collect and process information about the location of the device from which you are accessing the JCVTP. Location data may convey information about how you browse the JCVTP and may be used in conjunction with personally identifiable information.

4. How we use your Personal Data

We will collect, retain and use your Personal Data for the purposes set out in the relevant PICS, or in accordance with any further express consent provided by you. Such purposes may include the following:

(a) processing and completing your application for registration of a User Account;

(b) administering your User Account;

(d) to keep a record and provide you with information and details regarding: (i) your User Account activities; and (ii) any Volunteer Opportunities for which you have participated;

(e) performing our obligations under the Terms of Service or any other agreement entered into between you and us;

(f) enabling us to communicate with you in relation to your queries, feedback, complaints or claims, your User Account, your activities under your User Account, updated information related the usage of the JCVTP, and any Volunteer Opportunities for which you have participated;

(g) providing you with a more personalised experience in respect of the JCVTP or your User Account;

(h) subject to you prior consent and paragraphs 5 below, providing you with promotional materials, unless you notify us in writing of your objection to receiving such promotional materials;

(i) enforcing our rights against you in any legal proceedings, or to defend ourselves against any claim, in relation to you;

(j) complying with applicable laws or regulations; or

(k) for any other purpose that you have consented to and/or which has been notified to you on or before the time when the Personal Data is collected.

5. Marketing Activities

5.1 We shall not use your Personal Data without your prior consent for the purposes of providing you with Marketing Materials (as defined below). Unless with your prior consent, we will not transfer your Personal Data to any third parties (including any NGOs) for their use in direct marketing.

5.2 Subject to your prior consent, and the further details set out in the relevant PICS provided to you, we may use your name, email address, and mobile number to send you messages, announcements and/or information regarding:

(a) the JCVTP; or

(b) any Volunteer Opportunities offered by NGOs, or events or campaigns hosted by NGOs, that we think you may be of interest to you ("Marketing Materials").

5.3 You can always opt not to receive some or all of the Marketing Materials, or not to have your Personal Data transferred to the NGOs for marketing purposes, by checking the opt-out box on the relevant forms we use to collect your Personal Data. You can also opt-out of receiving any Marketing Materials at any time by notifying us in writing at the email address stated in paragraph 12 below, or through your User Account.

6. How we share your Personal Data

6.1 You agree that we may share the information we collect from you with third parties as detailed below, in order to achieve the purposes outlined in the PICS provided to you on or before the collection of your personal data, and/or in accordance with any express consent provided by you. Some of the below third parties may be located in countries outside the country in which you are located, including in countries that may not provide the same level of data protection.

With Trusted Service Providers

6.2 We may utilise trusted third party service providers to assist us in delivering the JCVTP. For example, we may use third parties to help host the JCVTP, send out email updates, process payments, or provide back-office or IT services, on our behalf. These service providers may have access to your Personal Data for the limited purpose of providing the service we have hired them to provide, and solely for our benefit. They are required to have a privacy policy and security standards in place that are at least as protective of your Personal Data as is this Privacy Policy. We may also store Personal Data in locations outside the direct control of the Provider (for instance, on servers or databases co-located with hosting providers).

When you connect to Volunteer Platform via JCVTP, your Volunteer Contribution Record and other related information submitted to the Volunteer Platform will be shared with the JCVTP.

With Law Enforcement or In Order to Protect Our Rights

6.3 We may disclose your Personal Data if required to do so by law or pursuant to any order issued by a court, tribunal or regulatory authority of competent jurisdiction. We may also disclose your information to our legal counsel, governmental authorities or law enforcement if we believe that it is reasonably necessary to do so in order to enforce our legal rights; comply with a law or regulation; to protect the safety of any person; to address fraud, security or technical issues; or to protect the Provider’s rights or property.

In an Aggregate and Non-Personally Identifiable Manner

6.4 We may disclose aggregate non-personally identifiable information (such as aggregated and anonymised data usage, platform types, etc, which do not amount to Personal Data) about the overall

use of the JCVTP, to the public or to interested third parties to help them understand, or to help us improve the JCVTP.

In Connection With a Sale or Change of Control

6.5 If the ownership of all or substantially all of our business changes, we may transfer your information to the new owner so that the JCVTP can continue to operate. In such case, your Personal Data would remain subject to the promises and commitments contained in this Privacy Policy until such time as this Privacy Policy is updated or amended by the acquiring party upon notice to you.

7. How We Protect Your Information

7.1 The security of your Personal Data is important to us. When you provide Personal Data through the JCVTP, we encrypt the transmission of any Personal Data that we deem to be particularly sensitive by using industry-standard encryption.

7.2 The Provider uses commercially reasonable and industry-standard physical, managerial and technical safeguards to preserve the integrity and security of your Personal Data. For example, we continuously and regularly back-up your data to help prevent data loss and aid in data recovery. We also guard against common web attack vectors, we host data in secure data centres, and we have firewalls and access restrictions on our servers to secure our network and to better protect your Personal Data.

8. Risks Inherent in Sharing Information

Although we take reasonable steps to safeguard your Personal Data from unauthorised access, use or loss, please be aware that no security measures are perfect or impenetrable.

9. Your Rights to Request Access to or Correction of Your Data

9.1 You have the right to request access to or correction of your Personal Data or Your Content held by us, by issuing a request in writing to the email address set out in paragraph 12 below. During the correction of your data as per your request, you understand that we will be able to access the Personal Data and Your Content held within your User Account.

9.2 You must keep your Personal Data held by us up-to-date. You may update or correct your User Account information at any time by logging in to your User account and making the changes yourself, or by contacting us (see contact details in paragraph 12 below).

10. Children's Privacy

The Provider recognises the importance of protecting the privacy of children and is committed to complying with The Personal Data (Privacy) Ordinance (the “PD(P)O”). If you are under the age of 18, before you provide the Provider with your personal data, your parent or guardian is required to:

(a) review and agree to this Privacy Policy and any data collection and usage related to children’s Personal Data,

(b) provide explicit consent for the collection, use, and sharing of the child’s Personal Data when creating the child’s account in accordance with the Terms of Service.

11. Changes to Our Privacy Policy

11.1 We may change this Privacy Policy at any time by posting the revised Privacy Policy in the 'Privacy' section of our JCVTP. The revised Privacy Policy is effective immediately when posted on the JCVTP.

11.2 It is the responsibility of each User to review the JCVTP and the Privacy Policy periodically to learn of any revisions to this Privacy Policy. Your continued use of the JCVTP after the effective date of such revisions will constitute your acknowledgment and acceptance of the terms of the revised Privacy Policy.

12. Contact Us

Please contact the Provider at support@jcvtplatform.hk, if you:

(a) have any questions regarding this Privacy Policy or the way in which we handle your Personal Data;

(b) wish to submit a request to access or correct your Personal Data held by us; or