Positive Wellbeing Ltd.
© 2024, Positive Wellbeing Ltd. All Rights Reserved.
Purpose
1. This policy provides guidance on the safe, secure and proper management of personal data. Personal data (“Personal Data”) is information that can be used to identify a person. This includes names, phone numbers, addresses, identity card numbers, photos and employment records
Legislation
2. Personal Data Privacy Ordinance (Cap 486 of the laws of Hong Kong)
Principles
3.1 We notify those from users whom we collect data (“Data Subjects”) of the purpose for collecting their data, how this data will be used and to whom it may be transferred. This is summarised in the Personal Information Collection Statement (PICS) which is maintained on the website. The PICS is in the appendix of this document.
3.2 We take all practicable steps to safeguard personal data from unauthorised or accidental access, processing, erasure, loss or use. Steps we take include:
Database software is modern and kept updated
Access to databases containing personal data is controlled through the CEO.
Emails to Data Subjects are sent from authorised Positive Wellbeing email addresses.
Mass emails are sent via email software (eg Mail Chimp) that does not disclose the Data Subjects’ email addresses. Emails to multiple people not sent via Mail Chimp are sent bcc.
3.3 Data Subjects may, on written request, access your personal data held by Positive Wellbeing. If the personal data that Positive Wellbeing is holding is incorrect, you may request to have the information be corrected. You may also inform us that the information is incorrect, and we will correct it. You may also withdraw your consent to us using your personal data.
3.4 We may share your Personal Data with third parties as described in this section:
your representatives, advisers and others you have authorised to interact with us on your behalf;
our staff members who need the information to discharge their duties;
our affiliates within the same corporate group, third-party partners and/or business affiliates;
our agents and service providers that assist us in operating the website, providing services to you, or otherwise conducting our business; and
competent court of law, law enforcement agencies and/or regulatory bodies for compliance with applicable laws and regulations and protection of our legal rights.
3.5 Except as provided herein, we will not disclose your Personal Data to any third parties unless it is necessary to provide the services, when required by law, or if we have good faith belief that such action is reasonably necessary to:
3.6 Data Subjects have the choice to opt out from receiving direct marketing from us. Direct Marketing in the context of Positive Wellbeing is:
offering or advertising services (and goods, if relevant) including training, information sessions, lectures, events.
3.7 All direct marketing email communications contain a link to the Privacy Policy and the option to unsubscribe from receiving communications. The Data Subjects who opt out are placed on the Opt-Out List and we will not send them any communications
3.8 If you access our information or services through the Positive Wellbeing website, you should be aware that the Positive Wellbeing website uses cookies. Information that you supply in this way will not be shared with any third party except where needed to provide a requested service.
3.9 We use the information collected about you through the Positive Wellbeing website to improve its understanding of web visitors and to send information that you have requested or that may be considered of interest to you. As a general rule, we will not disclose any information identifying you personally, except with your permission or where required by law. Please refer to the PICS for more details on the third party software used on this website.
Appendix
Positive Wellbeing Personal Information Collection Statement
1.Positive Wellbeing recognises its responsibilities in relation to the collection, holding, processing and use of personal data. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by Positive Wellbeing is secure and accurate and to avoid unauthorised or accidental access, erasure or other use. The personal data that Positive Wellbeing may collect from time to time includes your name, contact details, gender, date of birth.
2. All personal data handled by Positive Wellbeing will be kept confidential and will be collected knowingly from you.
3. The uses for which data may be collected are:
Sending communications including newsletters, information about programmes, seminars, events and other activities delivered by Positive Wellbeing or other agencies in conjunction with Positive Wellbeing.
Enrolling in training courses, programmes, lectures, seminars and other events.
Accessing resources through the Positive Wellbeing website.
Improve understanding of the Positive Wellbeing website traffic Positive Wellbeing
4. We may share your Personal Information with third parties as described in this section:
a) your representatives, advisers and others you have authorised to interact with us on your behalf;
b) our staff members who need the information to discharge their duties;
c) our affiliates within the same corporate group, third-party partners and/or business affiliates;
d) our agents and service providers that assist us in operating the website, providing services to you, or otherwise conducting our business; and
e) competent court of law, law enforcement agencies and/or regulatory bodies for compliance with applicable laws and regulations and protection of our legal rights.
f) The Positive Wellbeing website uses cookies with the third party software
5. Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website and cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites. Please note that Positive Wellbeing is not affiliated with, nor does it sponsor or endorse, any linking websites owned by third parties and it does not endorse any product or service offered by such linking sites.
6. Individuals who have provided data to Positive Wellbeing may submit a written request to access or to correct personal data held by Positive Wellbeing.
7. If you do not wish to receive information from us you may choose to opt out from our communications. You may contact us on training@positivewellbeinghk.com.
We may change this privacy policy from time to time. The updated version will be maintained on our website.