The Plan International Hong Kong Website, found at plan.org.hk, including all information and materials contained on it (“Website”), is managed by Plan International Hong Kong, 21/F., 9 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong. (“Plan International Hong Kong Ltd” “We”, “Us” or “Our”).
To contact us or provide feedback on the Website please go to the contact us page or call us at (852) 3405 5305.
This policy sets out the basis on which we (or Plan appointed service providers dealing with Personal Data on our behalf) collect, handle, process, store, transfer and destroy Personal Data. Please read this policy carefully.
Plan International Hong Kong Ltd is committed to ensuring the privacy of all our users and takes your privacy and our responsibilities in protecting and safeguarding this information in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) as amended or revised from time to time and, for users residing in the European Union, the General Data Protection Regulation (GDPR), very seriously.
Definition of Data Protection Terms
Data means any representation of information (including an expression of opinion) in any document, and includes any personal identifier.
Data Subject means an individual who is the subject of Personal Data.
Personal Data means any 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.
Data User means an individual who, either alone or jointly or in common with other persons, controls the collection, holding, Processing or use of Personal Data.
Data Processor means a person, whether within or outside of the HKSAR, who processes Personal Data on behalf of Plan International Hong Kong Ltd and does not process the Personal Data for any of the person’s own purposes.
HKSAR means the Hong Kong Special Administrative Region of the People’s Republic of China.
Processing includes, in relation to Personal Data, amending, augmenting, deleting or rearranging the Data, whether by automated means or otherwise.
Data Protection Principles
Any Data User collecting and using Personal Data must comply with the following principles of good practice:
- Personal Data must be collected for a lawful purpose directly related to a function or activity of the Data User;
- Personal Data must be collected by means which are lawful and fair in the circumstances;
- Personal Data must be adequate and not excessive for the purpose for which it was collected;
- Personal Data must be accurate;
- Personal Data must not be kept longer than necessary for the purpose for which it was collected;
- Personal Data must be used only for the purpose for which it was collected;
- Personal Data must be secure from any unauthorised or accidental access, processing, erasure, loss or use;
- Personal Data must not be transferred to Data Processors without contractual or other safeguards for the security of, and proper retention practices in relation to, the transferred Personal Data
- Personal Data must be accessible by the Data Subject to whom it relates; and
- Data Users must maintain transparency in their practices for handling Personal Data;
- Pursuant to compliance with the principles of good practice, we require that: any Data Processor processing Personal Data on our behalf are contractually responsible for following good Data protection practice; any Data Processor processing Personal Data on our behalf is appropriately trained to do so;
- any Data Processor processing Personal Data on our behalf is appropriately supervised;
- any enquiries relating to the processing of Personal Data are promptly dealt with;
- appropriate methods of processing Personal Data are clearly communicated to any Data Processor who is processing Personal Data on our behalf;
- any Data Processor maintains retention practices which ensure that Personal Data is not retained for longer than is necessary;
- any Data Processor maintains adequate security measures to prevent unauthorised or accidental access, processing, erasure, loss or use of Personal Data; and
- regular reviews and audits are made of the way Personal Data is collected, stored and processed by us or on our behalf.
Collection of Personal Data
We may also ask you to provide Personal Data as a donor, supporter or fundraiser of Plan International Hong Kong Limited. You are not required to provide this information to us, but if you do not, we may not be able to contact you or to process donations, applications or requests. We will collect Personal Data in accordance with applicable law and regulations, including the PDPO.
Typically, we collect your Personal Data in the following ways:
- from your completion of donation forms;
- during our street fundraising activities;
- during our fundraising telemarketing calls;
- when you make a donation;
- when you apply for positions in the Plan International Hong Kong Limited office;
- when you enroll to our fundraising events;
- when you opt-in to receive marketing information from us;
- when you email us your comments, feedback, opinion or suggestions;
- when you register to participate in a discussion on our bulletin boards, forums or social media on our website;
- in the course of your establishing or maintaining a donor/supporter relationship with us; and/or
- from your completion of our surveys.
Personal Data that we may collect from you include:
- Your name;
- You mailing address;
- Your email address;
- Your phone number;
- Your date of birth;
- Your Hong Kong ID card number; and/or
- Your payment card information (when you make a donation).
With respect to the Website, the type and amount of information we receive and store depends on how you use the Website. You can access most pages on the Website without telling us who you are and without providing any Personal Data. Our web servers collect anonymous logs during user visits to the Website. This information may be used to create aggregate statistics about how the Website is used.
We do not collect personal information (such as your name, e-mail address or country of residence) from use of the Website unless you choose to provide it to us. For example, if you express an interest in subscribing to our email updates.
How do we use information collected?
When Personal Data is collected from you, processing of Personal Data will only be for the specific purposes notified to you at the time of collection or for other purposes specifically permitted under PDPO. If at any time it becomes necessary to change the purpose(s) for which Data is processed you will be informed and your consent obtained before Processing occurs.
Typically, we collect Personal Data for the following purposes:
- to conduct fundraising activities;
- to process any donations made by you;
- to conduct donor surveys;
- to conduct market research and for direct marketing purposes,
- described in more detail under the “Direct Marketing” section below;
- to issue receipts for your donation;
- to foster communications between you and Plan International Hong Kong Limited;
- for any purposes in connection with any claims made by or against or otherwise involving you in respect of any fundraising activities organised or held by us including, without limitation, to make, defend, analyse, investigate, process, assess, determine or respond to such claims;
- to exercise any rights we may have in connection with our fundraising activities from time to time;
- to comply, where reasonably necessary, with any court orders, law, rules, regulations, codes of practice, guidelines or requests binding on us, including without limitation to make disclosures of your Personal Data to regulators, governmental bodies, tax authorities or industry recognized bodies, all of which may be within or outside the HKSAR; and/or
- for any purposes relating to the above or any other purposes in accordance with this Policy and other policies in relation to our fundraising activities as set out in any notices or other terms and conditions made available by us to you from time to time.
Your Personal Data will be retained by Plan International Hong Kong Ltd and its service providers in a secure environment, will be kept confidential and will only be used in connection with the purposes for which it is submitted, or as otherwise explained on the Website or as necessary for us to comply with our legal obligations.
From time to time, we may use your Personal Data (including your name, contact details and donation history) to send you emails, updates, invitations, or newsletters about our sponsorship program, fundraising events and initiatives, event recruitment and/or to invite you to make a donation, but we cannot do so unless you consent.
Sharing of your personal information
The information you provide will not be sold or rented. Where you have given your permission, we may share your Personal Data with our international headquarter as part of our sponsorship tracking system.
Even if you have consented for us to use your Personal Data for direct marketing purposes, you may withdraw your consent at any time free of charge. Any e-mail we send you will enable you to opt out of receiving further e-mail from us and you can also request that we remove you from our mailing lists by contacting us through one of the channels listed on this website’s contact us page. The withdrawal of your consent will be processed and will take effect as soon as possible but may take some time but we will aim to process this request within three working days of receipt.
Transfer of Your Personal Data
The disclosure of your personal information discussed above may involve transfer of that information outside of the HKSAR. To the extent necessary to achieve the purposes specified under this policy, as notified at the time of collection and to the extent permissible by law, we will only transfer Personal Data to third party Data Processors, service providers and other fundraising offices if they agree, contractually or otherwise, to comply with the procedures and policies in relation to the retention and security of Personal Data as outlined in this policy, or if they have adequate and appropriate retention and security measures in place.
Typically, we provide Personal Data to the following persons:
- our head office located in the UK and Plan’s appointed service providers engaged in marketing, advertising or campaigning, to help us to conduct campaign analyses, prepare donations, appeal letters and surveys;
- any agent, contractor or third party service provider who provides administrative, telecommunications, printing, information technology, payment processing, data processing or storage services to us;
- any of our auditors, legal and/or other professional advisors;
- any person to whom we are under an obligation to make disclosure under the requirements of any law, rules, regulations, codes of practice, guidelines or voluntary arrangements binding on us including applicable regulators, governmental bodies, or industry recognised bodies (all of which may be within or outside the HKSAR) and where otherwise required by law; and/or
- subject to your consent, any agent, contractor or third party service provider who provides marketing services to us in connection with the development and promotion of our fundraising activities.
Addresses submitted through ‘Contact us’
Please note that the addresses of those using the ‘Contact us’ facility are only retained for the purposes of reply or to be forwarded to the appropriate Plan office for action. E-mail addresses are not otherwise retained. E-mail addresses used to contact us in this way are not passed to any third party.
A cookie is a text-only piece of information that a website transfers to your computer’s hard disk so that the website can remember who you are. A cookie will normally contains the name of the Internet domain from which the cookie has come, the “lifetime” of the cookie, and a value, usually a randomly generated unique number.
Users have the opportunity to set their devices to accept all cookies, to notify them when a cookie is issued, or not to receive cookies at any time. To prevent the download of cookies, or otherwise control how cookies are used on your computer, please read the help information supplied with your Internet browser software or go to: www.allaboutcookies.org.
The Website uses Google Analytics to help analyse how users use the site. This analytical tool uses ‘cookies’, which are text files placed on your computer, to collect standard internet log information and visitor behaviour information in an anonymous form.
The information generated by the cookie about your use of the Website (including your IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of the Website and to compile statistical reports on website activity for Plan.
Plan International Hong Kong Ltd will not (and will not allow any third party) to use the statistical analytics tool to track or to collect any personally identifiable information of visitors to our site. We will not associate any data gathered from this site with any personally identifying information from any source as part of our use of the Google statistical analytics tool.
Google will not associate your IP address with any other data held by Google. Neither Plan International Hong Kong Ltd nor Google will link, or seek to link, an IP address with the identity of a computer user.
Disabling and enabling cookies
You have the ability to accept or decline cookies by modifying the settings on your browser.
Browsers are usually set to accept cookies. However, if you would prefer not to receive cookies, you may opt out of being tracked by any website using Google Analytics by visiting http://tools.google.com/dlpage/gaoptout.
Social Media Plugins
Our website also uses social plugins of social networking sites including www.facebook.com (“Facebook”), www.twitter.com (“Twitter”), www.youtube.com (“Youtube”) and www.weibo.com (“Weibo”). The plugins can be identified by the websites’ logos (e.g. a white “f” on a blue tile or a “thumbs-up” icon for Facebook, a blue bird for Twitter, a red and white square for Youtube, and a red black and orange eye logo for Weibo or the phrase “Social Plugin”.
Because our website uses social plugins, your browser will connect to the servers of the relevant social media websites.
You can deactivate social plugins at any time by changing your browser preferences.
Access to and accuracy of your personal information
We will take all practicable steps to ensure that the Personal Data we hold is accurate and kept up-to-date. We will therefore take reasonable and appropriate steps to check the accuracy of any Personal Data at the point of collection and at regular intervals afterwards. Personal Data which is found to be inaccurate or out of date will be destroyed.
All practicable steps will be taken to ensure that your Personal Data is not kept longer than is necessary. We will therefore destroy or erase from our systems Personal Data when it is no longer required.
Once we receive your Personal Data, we will make our best efforts to ensure its security on our systems and we will take all practicable and reasonable steps to protect your Personal Data from unauthorised or accidental access, processing, erasure, loss or use.
You have the right of access to, and correction of, Personal Data kept and used by Plan International Hong Kong in accordance with the provisions of the Personal Data (Privacy) Ordinance.
For access and/or correction of Personal Data please contact us at:
Plan International Hong Kong Ltd, 21/F., 9 Chong Yip Street, Kwun Tong, Kowloon, Hong Kong
Or please e-mail us at [email protected]。
Nothing in this Policy shall limit your rights under the PDPO.
This Policy shall be deemed an integral part of forms and applications you may submit to Plan International Hong Kong Ltd.
If you wish to make a formal complaint to the supervisory authority where you live, or work or where you believe there has been an infringement of your rights under the PDPO or GDPR, please contact the supervisory authority in your home state. In Hong Kong the supervisory authority is the PCPDPrivacy Commission for Personal Data, Hong Kong.
21 June 2018