1. Collection of Data
1.1 We do not collect any personally identifiable information from users during their browsing of our websites. When users visit our websites, we may record their visit only as a ‘hit’ and do not collect any personal data from them. We may, however, make a record of their visit that shows only the IP addresses (and domain names), the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites visited (visitor data). We may use such visitor data for website enhancement, optimization and “security incident investigation” (e.g. tracing the origin of a suspected hacker’s attack).
1.2 At times, we may request that you voluntarily supply us with personal data. The personal data may be obtained by electronic means or in written form. Generally, the following data may be requested and/or collected when you register for an event organized by The Community Lab, when you attend to events organized by The Community Lab, and/or subscribe to updates, programme offered or service provided by The Community Lab:
- your name and/or company name;
- contact number and e-mail address;
- relevant log-in information for access to our platform and/or programme;
- other information supplied or collected in connection with your registration and participation in our events or programmes, your subscription and/or use of our services and facilities;
- other records, including records of visitors to our premises, members of public making enquiries or responding to our surveys and other operational and administrative records that contain personal data and other information as may be set out in the relevant form or collection channel; or
- information we may generate and compile about you.
It is not obligatory to supply the requested personal data but if you fail to supply the requested data or any part thereof, we may not be able to provide you with the updates, services, facilities or activities or allow entry to our premises.
2. PURPOSE AND USE OF DATA
2.1 Personal data and information we collected will be used for the following main purposes:
- verifying your identity and eligibility for any services, programme, activities or events;
- processing your application and registration;
- evaluating your compliance with any programme offered or to be offered by the Community Lab;
- providing updates, services, facilities, activities or events (including our website) to which you may have subscribed and our daily operation and administration
- communicating with you (including responding to your enquiries or requests for information);
- subject to your consent, promoting and marketing programme, products, services facilities, premises, activities, conference or events the Community Lab, any group companies of Hysan Development Company Limited (“Hysan”) and Hong Kong Science and Technology Parks Corporation (“HKSTP”) or our business partners may offer from time to time (collectively referred to as “direct marketing”) (please see further details in “Direct Marketing” section below and you may opt out from receiving marketing information);
- administering and maintaining our website and diagnosing problems where necessary;
- designing, reviewing, evaluating and enhancing our services, products, facilities or activities (including conducting research, survey and analysis for those purposes);
- investigating and handling complaints, claims or incidents involving us or any of our visitors, service, facilities or website users;
- performing any research or data analytics;
- collating statistics where the statistical information obtained will not be released or made available to any third party in a form that is personally identifiable;
- preventing, detecting or investigating suspicious or illegal activities;
- enforcing our legal rights;
- making disclosure when required by any law, court order, direction, code or guideline applicable in or outside Hong Kong;
- purposes varying according to the nature of the information and record, including for administration and operation of the websites, the programme, events, activities and premises; and
- purposes relating to any of the above.
3. Transfer of Data
3.1 Data collected will not generally be disclosed or transferred to any other party in a form that would identify you except in the following circumstances:
- If we use third party suppliers or service providers who provide administrative, insurance, telecommunications, information technology, computer, data processing, content delivery, marketing support or other services to support our business operation or facilitate provision of our services, products, facilities or activities, we may provide data collected to these suppliers or service providers.
- We may disclose data collected to any governmental or law enforcement agency, judicial body or regulatory authority to whom we are required to make disclosure according to any law, regulation, court order, direction, code or guideline, or any person to whom we believe in good faith that disclosure is necessary or advisable, including to protect our rights or properties, to identify, bring or defend legal action or in circumstances considered to be related to any of the purposes for which data are collected;
- In addition, data collected may be accessed by, disclosed or transferred to any person under a duty of confidentiality to us (including our accountants, auditors, legal advisers or other professional advisers) and any of the subsidiaries, holding companies, associated companies or affiliated companies of Hysan and HKSTP for the purposes described in the “Purpose and Use of Your Data” section above.
3.2 As the parties mentioned above may have places of business outside Hong Kong, your information may be provided or transferred out of Hong Kong. By subscribing to our website or by logging-in, you agree to us providing or transferring your information to these parties outside Hong Kong and accept all risk of such transfer. We will try to ensure, as far as possible and practicable, that data transferred outside Hong Kong is protected to standards in line with the requirements of the Ordinance, subject to any other requirements and limitations of the particular jurisdiction.
4. Data Security and Retention
4.1 Subject to any legal and regulatory requirements, the data collected will be kept in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above, after which it will be destroyed.
4.2 In order to ensure the correct use and to maintain the accuracy of data collected, as well as to prevent unauthorised or accidental access, processing, erasure or other use of the data, we have implemented various physical, electronic and management measures to safeguard and secure the data we collect and have appropriate security policies in place. However, we cannot guarantee that data transmission over the internet or other media is completely secure.
5. Our Commitment to Children’s Privacy
5.1 Protecting the privacy of children is our primary concern. If you are under the age of 18, you should obtain consent from your parent or guardian before providing us with your data.
6. Direct Marketing
6.1 We may only use your personal data for the purposes of direct marketing if you have consented to such use. You may indicate your consent to us to use your personal data for direct marketing by selecting the relevant option in the appropriate online or paper form or any other means submitted to us.
6.2 You can withdraw your consent for use by us of your data for direct marketing at any time by sending an email to our Data Privacy Officer at email@example.com or as indicated in the relevant materials.
7. Links to other Web Sites
7.1 Our website may contain links to other web sites maintained by other persons, which may collect your personal data in the course of your interaction with these persons. The collection and use of personal data by these persons are beyond our control and are subject to the privacy policies of the relevant persons.
8. Cookies and Other Tracking Mechanisms
8.1 We may automatically collect information about your computer or device, including where available your IP address, device ID, MAC address, operating system and browser type, when you access our website or applications or use our WiFi services. This is statistical data which does not reveal your identity. Similarly, cookies may be left on the hard drive of your computer, mobile phone or other devices.
8.3 We use analytics tools to automatically measure how visitors interact with content on our websites and applications, or in relation to your use of our WiFi services. If you log-in to our websites, applications or WiFi services via your social media accounts (if applicable), we may collect information you have made available on the relevant social media site and link your interaction with us to such information. Where you have consented to direct marketing, we may also engage social media sites or send you push notifications via mobile applications to show you advertisements that are customised (which may be automatic) based on analysis of any data we may retain in relation to you, your interactions with us and/or aggregated and anonymous non-personally identifiable information we collect via analytics technologies.
8.4 We may feature embedded links, “share” buttons or widgets on our websites or applications to enable you to connect to third party sites, including social media sites. These third party sites may set cookies which can identify you as an individual when you are logged in to their services. We do not control these cookies or how these sites collect and handle your data. You should read the relevant third-party sites for their privacy policies before submitting any data to these sites. We have no control over and are not responsible or liable for the contents of third party sites or third party posts on our social media accounts.
8.5 We may use analytic technologies to collect non-personally identifiable information about you on an aggregated and anonymous basis, such as information captured by devices in real-time during your visit (e.g. visitor counts and information), and those which are collected via our WiFi services through your WiFi enabled device (even if it is not connected to our WiFi services) (e.g. IP address, MAC address, location data, visitor statistics and preferences, activity patterns and device information). If you do not wish us to collect the aforesaid information via our WiFi services, then you can turn off the WiFi on your device. We use this data for research and analytics purposes, including helping us to study activity patterns and visitor preferences in order to improve service experience. If you are a member of one of our programmes, and you sign in to use our WiFi services through your log-in details, such non-personally identifiable information may be linked to any data we may retain in relation to you, and if you have consented to receive direct marketing materials, we may provide you with targeted advertisements, content, features, deals and offers through push notifications via mobile applications. Otherwise this data will not be linked to any data we may retain in relation to you, and cannot be used to identify or re-identify you.
9. How to Access or Correct Your Data or Contact Us
9.1 You are entitled to access or correct any data related to you held by us. If you wish to obtain a copy of any of your data or if you believe that the data related to you which we collect and maintain is inaccurate, please contact our Data Privacy Officer at firstname.lastname@example.org or at the following address:
Data Privacy Officer
24/F, Lee Garden Five,
18 Hysan Avenue,
9.2 In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request. You may also contact us at the above details for any other data privacy related matters.
11.1This statement is written in the 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 statement, the English version shall prevail.
Last version date: May 2022