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Uplifters Limited (Uplifters) treats the protection of privacy in relation to personal data very seriously. All personal data collected by Uplifters shall be treated with respect and we are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and to implement applicable Privacy Commissioner for Personal Data best practice. We may from time to time update this policy and all information will be governed by our most recent policy as available on our website.

By using or accessing the Website or by contracting with us in any manner (including as a client, service provider, donor, volunteer or employee), you acknowledge that you accept the practices and policies outlined in this Privacy Policy which sets out how we will collect and use your personal data.

Remember that your use of the Website and services provided by Uplifters is at all times subject to the Terms, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

Collection of Personal Data

We do not collect information about individuals except where this is specifically stated and provided with your knowledge. From time to time it is necessary for data subjects to supply Uplifters with personal data in connection with the use of the Website; registration, enrolment in a course and establishment of a user account, or the use or continuation of provision of educational services, products and facilities or our relationship with you as your current, future or former employer or volunteer organisation, or your provision of services to us (or your position as a representative of a company which provides services to us). Failure to supply such personal data may result in Uplifters being unable to register, enrol, establish a user account or use or continue the provision of educational services, products and facilities or our employer or volunteer arrangement.

You may voluntarily choose to share additional personal data on the Uplifters’ website/online learning platform including through chatbots and on Uplifters’ social media  on third-party platforms, for example:

• In your Uplifters’ account profile
• When participating in a course, forum or other interactive experience on the Uplifters’ website and Uplifters’ chatbots or pages on social media platforms such as Facebook;
• You are an applicant for a job or volunteering role with us.

Types of Personal Data Collected

Uplifters directly collects personal data relating to members of the public who use Uplifters’ services or the Website or donate to Uplifters when you:

• Sign up for an Uplifters course (on your own behalf or on behalf of another individual) and create an Uplifters user profile;
• Enrol and participate in Uplifters’ online courses;
• Purchase a product or service on your own behalf or on behalf of another individual);
• Send email messages, chatbot or Facebook chat messages to Uplifters (including messages to learner support);
• Participate in public forums and other interactive experiences on the Uplifters website/online learning platform and social media platforms or in person;
• Donate to Uplifters;
• Make an enquiry, complaint or data access or correction request.

Such personal data includes: full name, personal details, such as nationality, age, date of birth, gender, marital status and number of children, contact details including telephone numbers, email and residential address, payment details such as credit card information or bank account details, employment details (including income) and history, other personal information such as financial habits and situation, plans for the future and well-being level.

We will always try to collect your personal data directly from you. However, there may be instances where we will need to collect your information from other persons or entities, including, for example, if your employer registers you for an Uplifters course. Where we obtain your information from a third party, in particular your employer, we may ask them to provide you with a copy of this Privacy Policy to ensure you know we are processing your information and the reasons why.

We may collect personal data relating to our employees, officers, volunteers including personal particulars, Hong Kong identification card number and copy/passport number and copy, education and qualifications, employment history, salary and allowances, bank account details, job applications, terms and conditions of service, rank and post, training, appraisal reports, promotion board assessments, conduct and discipline, awards, benefits, medical records, leave, retirement and pension, professional qualifications, Mandatory Provident Fund and provident fund account details, and legal assistance.

We may collect personal data relating to or in connection with your provision of services to us or your position as a representative of a provider of services to us including full name and contact details.

Uplifters also indirectly collects usage information about your visit to the Uplifters website and use of the e-learning platform as described in the ‘Cookies and Tracking Technologies’ section below.

Cookies and Tracking Technologies

We collect non-specific information on visitors’ and registered users’ activities on the Website by third-party web beacons and cookies from vendors including Google, via means of web analytics tools such as Google Analytics on most parts of the Website, which may include information such as where the visitor or registered user has come from (e.g. referring domains, search engines, marketing campaigns), the type of browser or operating system used to access our Website, pages viewed, date and time of access, the site path of the visitor, what content visitors are clicking on, which courses visitors are interested in and sign up for/participate in. You can find out more about Google Analytics (http://www.google.com/analytics/) on its website. We do not collect any personal data (e.g. name, address, email address) using the web analytics but we do collect IP addresses. Uplifters does not link any web analytics information to an individual. Uplifters uses this information to ensure that the Website is providing the best possible user experience and providing relevant services. Most web browsers automatically accept cookies but you can disable this function by changing your browser settings if you wish. However, if you do so you may not be able to take full advantage of our Website.

Uplifters may track and collect information from emails that we send you, for example, whether you opened the email or clicked on any links in the email.

We may share overall visitor trends and other generic information collected on our Website with third parties but we will not disclose any personal details or personally identifiable information without your consent.

Our Website may contain links to websites operated by third parties. We have no control over the content of the linked websites or how the operators of those websites deal with your personal data. We encourage you to review the privacy policies applicable to those third-party websites to understand how your personal data may be used by those third-party websites.

Purposes  for which your Personal Data may be Used

Uplifters collects and uses personal data for the following purposes, to:

• Operate and improve the Website – including creating and improving features that support the Uplifters’ community and enable Website use at scale. This also includes personalising the Website, so your learning experience is tailored to your interests and needs;
• Create, administer, provide and teach courses – including creating and improving the delivery of online courses and programmes on the Website. This also includes personalising courses, so your learning experience is tailored to your interests and needs, and assessing your attendance/performance and awarding certificates;
• Offer and improve products and services – including enabling you to navigate the Website, to enrol and participate in courses and programmes on the Website, to learn effectively on such courses and programmes, and as applicable to purchase or obtain products and services on the Website;
• Develop and maintain the security of the Website – including tracking Website outages and creating software solutions, detecting contraventions of the Terms of Service, and monitoring uses, misuses, and potential misuses of the Website;
• Communicate with you – including answering your course/programme and Website questions, notifying you of courses/programmes and Website/e-learning platform technical issues;
• Conduct or research studies, invitation of participation in programmes/activities, assessment of applications, assessment of qualifications, issue of certificates, monitoring of employees, users, and volunteers’ progress, processing of applications for reimbursement of fees, assessment of nominations and dissemination of awards, verification of assessment, planning, provision, development, implementation and recording of services, referral and placement, and education researches;
• Perform a range of employment-related and volunteer-related purposes, such as appointments, integrity checking, postings and transfers, offer/renewal/extension of agreements, incremental credit, training and career development, revision of terms or conditions of service, promotion, conduct and discipline, legal assistance, benefits, continuation in or removal from office;
• Collect, process and administer donations;
• Enable us to operate our services efficiently and sustainably;
• If required by applicable law, a competent authority or under order by the courts; and
• Recruitment; administering, servicing, and administration of various schemes, an arrangement of payments for services delivered, dealing with complaints and enquiries or requests for personal data and information.

Disclosure of Personal Data

We do not sell your information nor make it generally available to others but we may disclose personal data to other organisations or agencies that are bound to handle your information in the same way we do. The circumstances where we may disclose your personal data to such third parties include when another organisation helps us process transactions, store data, access data or provide services to you (including courses) in order for them to perform their role.  Uplifters does not otherwise share any personally-identifiable or personal data of users with third parties, unless with your consent or as required to do so under applicable law or judicial process.

Direct Marketing

Uplifters requires consent (which can include an indication of non-objection) in order for us to use your personal data for direct marketing, including name, contact details, nationality, occupation, gender, health and family status to provide you with marketing communications relating to personal development services, member activities, donations and contributions for charitable and/or non-profit-making purposes (including by email, SMS, chatbot or other instant messengers on social media). Such consent is given can subsequently be withdrawn without charge by emailing the Data Protection Officer at hello@uplifters-edu.org.

We will not sell your personal data to anyone. We require your consent before providing any of your personal data [name, contact details, nationality, occupation, gender, health and family status] to the community or educational partners for their direct marketing. Such consent is given can subsequently be withdrawn without charge by emailing the Data Protection Officer at hello@uplifters-edu.org.

 Storage of Personal Data and Security

All personal data collected is stored securely to prevent any unauthorized or accidental access, disclosure, processing or erasure. Uplifters implements appropriate physical, electronic and managerial measures to safeguard and secure personal data including password protection and limiting physical access.

Uplifters takes all practicable steps to ensure that personal data is not kept longer than necessary and in compliance with applicable statutory requirements relating to the retention of personal data.

Even though we take steps to secure your personal data, you should be aware that no system is impenetrable and no information provided over the Internet is totally secure. Accordingly, we cannot and do not guarantee the security of information that you transmit or receive over the Internet. You should not send confidential details or credit card numbers, for example, by email unless specifically requested by us.

You should take precautions not to share, provide or facilitate unauthorised use of your Uplifters account profile and/or username and/or password. If in the unlikely event unauthorised access or transactions have been discovered, you should notify Uplifters immediately.

Data Access or Correction Requests

Data access or correction requests must be made in writing by email. Requests should be addressed to the Data Protection Officer at hello@uplifters-edu.org.

Uplifters may require you to provide identity proof such as your Hong Kong Identity Card and impose a reasonable charge to cover the costs of processing the data access request.

Enquiries

Any enquiries regarding personal data policies and practices should be addressed to the Data Protection Officer at hello@uplifters-edu.org.

Marie Kretz Di Meglio

Uplifters CEO

19.12.2019