A. ABOUT THIS POLICY
ICS is committed to providing you with professional services while protecting your privacy.
The provision of your personal data in connection with your use of the Online Platforms is voluntary. If you do not provide such information, we may not be able to provide you with access to or full use of the Online Platforms or fulfil any other applicable purposes of collection.
• references to “ICS”, “we”, “us” or “our” means ICS Mission Limited and/or the Affiliate (defined below); and
• references to “you” and “your” are to the Data Subjects.
We collect Personal Data from you when you use the Online Platforms. We will also collect and process your Personal Data by using cookies in accordance with the Section E (Cookies) below.
B. WHO IS RESPONSIBLE FOR YOUR DATA?
ICS Mission Limited, with its registered address at: Room 3602, Level 36, Tower 1, Enterprise Square Five, 38 Wang Chiu Road, Kowloon Bay, Kowloon, Hong Kong (“ICS”) is the data user in relation to your Personal Data.
We can be contacted at by email: email@example.com or by post using the address set out above.
C. SOCIAL MEDIA & THIRD PARTY PLATFORMS
We are not responsible or liable for the collection, use, disclosure and processing by social media and third party platform providers, such as WeChat, Facebook, Instagram or Youtube of any content or Personal Data relating to you posted on or collected through such platforms. You are encouraged to carefully review the platform provider’s privacy and cookie policies.
D. WHAT PERSONAL DATA DO WE PROCESS AND WHY?
We set out below a non-exhaustive list of the types of Personal Data that we collect and process and the purposes for which that Personal Data is processed.
Our business purposes: We will also use your Personal Data for our internal business purposes including:
• for record keeping, statistical analysis, internal reporting and research purposes;
• to investigate any complaints you make;
• for business and disaster recovery (e.g. to create back-ups);
• to ensure network and information security;
• to host, maintain and otherwise support the operation of our Online Platforms, including to customise various aspects of our Online Platforms to improve your experience;
• for document and data retention/storage;
• to protect the rights, property, and/or safety of ICS , any of its Affiliates, its personnel and others;
• to comply with our legal requirements; and
• to ensure the quality of the services we provide to users of our Online Platforms, participants in our events and activities and our members.
Cookies are small files which, when placed on your browser or the hard drive of your device, are used to collect data, including personal data, from you, and enable us to provide certain features and functionality in our website. Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies are stored on your browser by websites or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognize the Cookies and your browsing device.
F. HOW AND WHEN DO WE SHARE PERSONAL DATA WITH THIRD PARTIES?
This section describes with whom we may share your Personal Data.
a) Data sharing with ICS Affiliate
ICS may share your Personal Data with its Affiliate:
• where we need to do so in order to provide the services that you have requested or organize the events and activities that you have registered for; or
• for the purposes of IT support and maintenance; or
• internal governance and administration; or
• if you consent to us doing so; or
• to comply with our legal or regulatory obligations.
b) Data sharing with service providers and volunteers
We also share your Personal Data with our third party service providers and volunteers, whom we engage to provide various services, which include but are not limited to:
• organizing of our events and activities (e.g. event organizers and event venues);
• our websites (e.g. hosting and maintaining our websites); and
• IT services and solutions (e.g. providing data storage, assisting us with database management).
c) Data sharing with other recipients
We may also share your Personal Data with:
• our accountants, auditors, lawyers or other professional advisers when we ask them to provide us with professional advice;
• any other third party if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or to protect the rights, property and/or safety of ICS, any of its Affiliates, its personnel and others;
• any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a court order or acting in accordance with an applicable law or regulation;
• competent law enforcement agencies in connection with the prevention and detection of crime; or
• any relevant third parties in the event of a legal transaction related to ICS and/or any of its Affiliates.
G. INTERNATIONAL TRANSFERS OF PERSONAL DATA
The transfer of your Personal Data to and between the Affiliates, service providers or other recipients may involve your Personal Data being sent outside of Hong Kong to recipients in Mainland China. If we transfer Personal Data overseas, we will implement appropriate and suitable safeguards to ensure that such Personal Data will be protected as required by applicable data protection laws.
H. HOW LONG DO WE STORE PERSONAL DATA?
It is our policy to retain your Personal Data for the length of time required for the specific purpose(s) for which it was collected (e.g. for the provision of services requested by you). However, we may be obliged to store some Personal Data for a longer time, taking into account factors including:
• legal obligation(s) under applicable law to retain data for a certain period of time (e.g. compliance with tax and accountancy requirements); and
• the establishment, exercise or defence of legal claims (e.g., for the purposes of a potential dispute).
I. HOW DO WE PROTECT YOUR PERSONAL DATA?
We implement technical and organisational security measures to protect your Personal Data against the risk of accidental or unauthorised access, processing, erasure, loss, misuse, alteration or destruction. Such measures may include the use of firewalls, encryption (where appropriate, such as the use of TSL/SSL encryption (https) for secure data connection between our users and our servers ), access rights management processes, careful selection of processors and other technically and commercially reasonable measures to provide appropriate protection for your Personal Data. Where appropriate, we may also make backup copies and use other reasonable means to prevent accidental damage to or destruction of your Personal Data.
Please note however that your transmission of information to us over the internet can never be guaranteed to be 100% secure.
J. YOUR RIGHTS
The following explains your data protection rights that you can exercise. The rights may only apply in certain circumstances and are subject to certain exemptions. You can exercise these rights using the contact details set out in Section L (How to Contact Us).
• The right of access: You have the right to access and to receive a copy of your Personal Data that we hold about you, subject to certain exemptions.
• The right to rectification: You have the right to ask us to take measures to correct your Personal Data if it is inaccurate or incomplete (e.g. if we have the wrong name or address for you).
Before assessing your request, we may request additional information in order to identify you. If you do not provide the requested information and, as a result, we are not in a position to identify you, we may refuse to action your request. We may charge a reasonable fee in order to comply with a data access request.
K. THIRD PARTY LINKS
Our websites and mobile apps may include links to third-party websites, plug-ins and applications, including but not limited to those used for the purposes of processing your registration for our events and activities. 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 how they handle your Personal Data. When you leave one of our websites, we encourage you to read the privacy notice of every website you visit.
L. HOW TO CONTACT US
We will try to respond to your enquiry or complaint within a reasonable period. If we do not respond to a complaint within a reasonable time or if you are dissatisfied with our response, you may submit a complaint to your local data protection authority.