The Hong Kong Jockey Club Charities Trust (the "Trust") and The Hong Kong Jockey Club (the "Club") are committed to ensuring the privacy and security of the Personal Data they hold.  The Trust and the Club aim to meet this commitment by implementing the principles and requirements of the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (the "Ordinance").  This Privacy Policy Statement is intended to explain the Trust's and/or the Club's privacy practices.

For the purpose of this Privacy Policy Statement, an "HKJC Entity" refers to the subsidiaries of the Club and the Trust as set out in the annual report of the Club and shall also include The Jockey Club CPS Limited and The Jockey Club Kau Sai Chau Public Golf Course Limited.

Collection of Personal Data

From time to time and for the purpose of carrying on any operation or business of the Trust and/or the Club, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data").  The scope of Personal Data required from you may vary depending on the circumstances but in general may include, but is not limited to, the following:-

1. Full name, gender, date and place of birth;
2. Information for verification of identity or citizenship including identification type and identification number such as Hong Kong Identity Card or passport details, visa information, residence or work permit;
3. Contact details such as office and/or home address, telephone number, mobile phone number, fax number and email address;
4. Educational and professional background including details of examination results, references, past scholarships, awards, employment, community services or extra-curricular activities;
5. Financial and billing information including income, expenses, financial statements, identity of other funders and details of funding, identity and contact details of beneficiaries, employees or contractors, bank account information and details etc.;
6. Your image and voice, including photograph, video or audio recordings; and 
7. Demographic information such as age, gender, nationality, marital status, preferences etc.

Supply of Personal Data to the Trust and/or the Club is generally non-obligatory but failure to do so may result in the Trust and/or the Club being unable to process your applications or to provide you with the relevant facilities or services.

Occasionally, you may need to provide Personal Data about other individuals to the Trust and/or the Club (such as spouse or children, funders, beneficiaries, members, employees, suppliers or contractors).  In that event, for the compliance with the Ordinance, you are required to have first obtained the authorisation of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to the Trust's and/or the Club's possible use, disclosure and transfer of their Personal Data, for the purposes you would want to achieve from the Trust and/or the Club.  If necessary, the Trust and/or the Club may require you to provide to the Trust and/or the Club any supporting documents which may be necessary to prove such authorisation.  You should also advise them that the Trust and/or the Club can be contacted for further information.

Use of Personal Data

Your Personal Data may be used for the following purposes or any directly-related purposes:-

1. The Trust's and/or the Club's management and administration of their funding programmes including grants, loans, scholarships, sponsorship, membership or fellowship of any association established by the Trust and/or the Club in connection with such funding programmes and/or other related charitable matters;
2. Processing of applications in relation to the funding programmes of the Trust and/or the Club as set out in paragraph 1, including verifying your identity and assessing your suitability and verifying your eligibility for the same (regardless of whether you are a new applicant or an applicant who re-applies for such funding programmes);
3. Collating statistical information relating to the applicants, to assist the Trust and/or the Club in the management and administration of its funding programmes;
4. Matching (as defined in the Ordinance) your Personal Data with other data collected for other purposes (by the Trust, the Club or any third party), in relation to the processing, assessment, administration and/or management of the Trust and/or the Club's funding programmes and/or the performance of any service or administration work in connection with the Trust and/or the Club's operations;
5. Handling matters relating to the administration of awarding scholarships or related matters, including making arrangement for placement with or admission to educational institutions or related associations or organisations;
6. Promoting the grants, loans, scholarship or other funding programmes of the Trust, the Club or an HKJC Entity, such as sending you annual reports, newsletters, information or promotional materials regarding charitable or community causes, activities and events organised or sponsored by the Trust, the Club or an HKJC Entity (please see further details in "Direct Marketing");
7. Facilitating and maintaining communication with recipients of grants, loans, scholarships and other award recipients during the grant or award period and upon expiry of such period;
8. Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, of the Trust and/or the Club, or in connection with:
   • any law, regulation, judgment, court order, sanctions regime, within or outside the Hong Kong Special Administrative Region ("Hong Kong") existing currently and in the future;
   • any guidelines, guidance, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside Hong Kong; or
   • any of the rules or bye-laws of the Trust and/or the Club relating to the Trust and/or the Club's core operations.
9. Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the Trust, the Club and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
10. Prevention, detection or investigation of crime;

Direct Marketing

Occasionally, the Trust, the Club and/or an HKJC Entity (or an agent on behalf the Trust, the Club or an HKJC Entity) may use your Personal Data (including your name and contact details) to send you marketing or promotional communications containing news, offers and/or promotions about charitable, community or other non-profit making events, causes or activities organised, sponsored or arranged by the Trust, the Club, or an HKJC Entity.  For such purposes, your Personal Data may be provided to an HKJC Entity.  However, the Trust, the Club and/or the HKJC Entities will first obtain your consent before doing so.

You can always opt-out from receiving such marketing or promotional communications free-of-charge by contacting the Club's Data Privacy Compliance Officer.

Disclosure of Personal Data

Personal Data supplied to the Trust and/or the Club will be kept confidential.  However, the Trust and/or the Club may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, provide such Personal Data to the following parties:

1. Any HKJC Entity for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above);
2. External personnel or organisations (including but not limited to educational or other institutions, associations or organisations, your referees, governmental authorities, assessment or examination boards and awarding bodies) for the purposes or a directly-related purpose for which the personal data was collected or where it is permitted under the Ordinance;
3. Any other person or company who is under a duty of confidentiality to the Trust and/or the Club and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
4. Consultants, agents, contractors, suppliers and any third party service provider of the Trust and/or the Club which provide administrative, marketing and research, distribution, data processing, telecommunications, computer, financial, payment or other services to Trust and/or the Club in connection with their operations;
5. Government and regulatory authorities, investigative bodies and law enforcement agencies and other organisations, as required or authorised by law;
6. Any financial institutions, including banks, necessary to and solely for the purposes of establishing and supporting payment in connection with the funding programmes;
7. Your authorised representatives or legal advisers when requested by you to do so.

The Trust and/or the Club may also disclose your Personal Data to third parties: (i) when required by law, by court order, or in response to a search warrant or other legally valid inquiry; or (ii) pursuant to the Trust and/or the Club's good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defences, to obtain legal advice, to exercise and defend the Trust and/or the Club's legal rights, or to protect the life, body or property of an individual.  This also applies when the Trust and/or the Club has reason to believe that disclosing the Personal Data is necessary to identify, contact or bring legal action against someone who may be causing interference with the Trust and/or the Club's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

Where applicable, the Trust and/or the Club may also transfer any information it holds about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Trust and/or the Club or as part of a corporate reorganisation or other change in corporate control.

The Personal Data that the Trust and/or the Club collects or obtains may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction.  By submitting Personal Data to the Trust and/or the Club or applying for any of the funding programmes of the Trust and/or the Club, you understand and consent to such transfer. 

Links to Third Party Websites

The Trust and/or the Club's websites may contain links to other sites and pages which are operated by third parties.  The Trust and/or the Club have no control over the content of the linked websites or the way in which the operators of those websites deal with your Personal Data.  You should review the privacy policy for those third party websites to understand the ways in which your Personal Data may be used by those third parties.

Use of Cookies

By using The Trust and/or the Club's websites ("Websites") and mobile apps, if any, you agree that the Trust and/or the Club can store and access cookies, IP addresses and use other methods in order to collect website usage data and improve your on-line experience.

Cookies are small files that are placed on your computer by websites that you visit or certain emails you open.  They are widely used in order to make websites function properly, as well as to provide business and marketing information to the website owners.

The Trust and/or the Club use cookies on its Website to track visitor preferences. These cookies allow the Website to remember information that changes the way the Website behaves or looks, such as your preferred language. These cookies can also assist you in changing text size, font and other parts of webpages that you can personalise. You may refuse to accept cookies by altering the settings on your internet browser but it should be noted that if you choose not to permit cookies, some areas of the Website may not function properly.

Data Retention

All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.

Commitment to Data Security

The Trust and/or the Club are committed to protecting the security of your Personal Data.  A variety of physical, technological and organisational measures are used to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.

Changes to the Privacy Policy Statement

The Trust and/or the Club will post on its Website any changes to its Privacy Policy Statement, so that you will always know what information the Trust and/or the Club gather, how they might use that information and whether they disclose such information to anyone.

Access to and Correction of Personal Data

You are entitled to request access to Personal Data held by the Trust and/or the Club about you and to correct such data. The Trust and/or the Club may charge a reasonable fee for the processing of such data access request. You may direct your request in writing to:

Data Privacy Compliance Officer
Jockey Club Headquarters
1 Sports Road
Happy Valley, Hong Kong.

This notice is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.