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Privacy Policy

A. ABOUT THIS POLICY

ICS is committed to providing you with professional services while protecting your privacy.

This Privacy Policy (“Privacy Policy”) governs our online data collection and processing activities including, without limitation, through various channels such as our websites, mobile apps, WeChat official accounts, Facebook account, Instagram account and Youtube account (“Online Platforms”). This Privacy Policy outlines when, why and how we collect, use, disclose and/or otherwise handle (collectively “process”) personal data relating to users of the Online Platforms (“Data Subjects”).

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.

Personal Data” is any information relating to you which can be used to personally identify you, either directly or indirectly. We will process your Personal Data in accordance with this Privacy Policy and as described when we collect data from you. This Privacy Policy must be read together with any other legal notices or terms and conditions provided or made available to you when we collect data from you or at a later stage, or that are available on other pages of our Online Platforms.

In this Privacy Policy
• 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: info@icshq.org or by post using the address set out above.

Where ICS shares Personal Data with the following affiliated company of ICS (“Affiliate”), the Affiliate is also a data user as explained in this Privacy Policy: ICS Enterprise Management Consulting (Shanghai) Ltd. with its principal place of business at: Room 306, 3rd Floor TianHong Building, No. 80 Xianxia Road, Changning District, Shanghai, China

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.

Data Subject CategoryType of InformationPurposes of Processing
Subscribers to the ICS Weekly Newsletter• your first name
• your last name
• your e-mail address
• processing your subscription and sending the ICS Weekly Newsletter to you
Persons signing up for our events and activities through our websites or mobile app app or through third-party registration platform providers. (For any other personal data processing activities carried out by third-party registration platform providers, e.g. cookies, tracking, marketing and advertising, which falls outside the processing purposes mentioned here, please see the relevant third-party provider’s privacy policy.  Please also see Section K “Third Party Links” below.)• your first name
• your last name
• your e-mail address
• your telephone number
• your company name (where requested for certain events as optional information and you choose to share)
• your gender (where required for specific events for the purposes of the organization of the event)
• other personal data which you may share when you sign up for our events or activities through our website or mobile app
• responding to your requests relating to the events and activities and taking the relevant actions associated with your requests
• registering you for the events and activities which you have signed up for
• administering the events and activities which you have signed up for
• other legitimate purposes
Users of our websites and mobile app• your username and password (should registration and login be implemented at any stage)
• other personal data which you may share with us through our website and mobile app
• cookies
• IP address
• geographical location
• browser type and version
• operating system
• information about your visits to and use of our website/mobile app
• administering our websites and mobile app
• personalising our websites and mobile app
• enabling your use of the services available on our websites and mobile app
• to analyze website traffic/viewership
• other legitimate business purposes
Users of our WeChat official accounts• your WeChat ID (where you follow our WeChat official accounts or like any articles posted on our WeChat official accounts• sending you communications relating to our events, activities or services, if you have followed any of our WeChat official accounts
• to assess popularity of the posts on our WeChat official accounts
Users of our Facebook and Instagram accounts• your Facebook or Instagram ID (where you follow our Facebook or Instagram account or like any articles posted on our Facebook or Instagram account• sending you communications relating to our events, activities or services, if you have followed our Facebook or Instagram account
• to assess popularity of our posts on our Facebook and Instagram accounts
Youtube accounts• your Youtube ID (where you follow our Youtube account) • sending you communications relating to our events, activities or services, if you have followed our Facebook or Instagram account

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.

E. COOKIES

Our Online Platforms use cookies and other similar technologies (e.g. pixels and web beacons) (collectively, “Cookies”) to distinguish you from other users of our Online Platforms in order to enhance your experience of our Online Platforms and to allow us to improve our Online Platforms.
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.

We will obtain your consent to the use of Cookies where required under applicable law.

For more information about how we use Cookies, please refer to our service provider’s Cookie Policy at: https://wordpress.org/about/privacy/cookies/.

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 to be informed: You have the right to be provided with clear, transparent and easily understandable information about how we use your Personal Data. This is why we are providing you with the information in this Privacy Policy and in any legal notices or terms and conditions provided to you.

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

If you would like to request further information regarding this Privacy Policy or the way we use your Personal Data, or if you wish to exercise any of the rights set out in Section I or make a complaint, you can contact us at: info@icshq.org.

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.