PRIVACY POLICY
SPC Pool Management Limited and each of our group or affiliated companies (“Company”, “we”, “our” or “us”) take your privacy very seriously and wish to assure you that your personal information will be treated as confidential. This is how we will manage information we collect from you through our mobile application (the “App”) that link to this Privacy Policy (collectively the “Sites”) and through our swimming pools (“Services” or “work”). We will meet the standards of personal data privacy protection in complying with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) as amended from time to time.
1. Types of Data We Collect
When you register with our App, when providing service(s) to us or work for us, we may collect from you the following information which may contain personal data as defined under the PDPO (“Data”):
1.1 Your personal information such as your name, address, phone number, email address, and International Mobile Equipment Identity (IMEI);
1.2 Your service(s)/ work time, location, or any other details of services or work;
2. Purposes for Collection and Use of Data
The Data provided by you will be used by us for the purpose for which it was requested, and for directly related purposes as follows:
2.1 For security reasons to confirm that you are who you say you are when you log in to our App;
2.2 Provision of App;
2.3 Considering or fulfilling requests or application of any nature submitted by you, whether online, over the phone or through other channels;
2.4 Record your activities including sign in and sign out time, location, and/or any other related details;
2.5 Provide your information to, including but not least, school(s), organization(s), etc. for settling your service(s) fee/ payroll, completing HR or accounting procedure, business development and/or organizing activities;
2.6 Conducting Company internal analysis;
2.7 Handling and following up of complaint, enquiry or feedback;
2.8 Administering contests and sweepstakes conducted by us, including policy announcement and collection of document;
2.9 Updating and enhancing our records;
2.10 Meeting the requirements to make disclosure to any governmental, legal or regulatory authority in Hong Kong under the requirements of any law binding on us; and
3. Use of Data in Direct Marketing
3.1 We intend to use your Data in direct marketing, and we may not so use your Data unless we have received your consent (which includes an indication of no objection).
3.2 We would like to use the Data in our records including your name, phone number, email, address and/or your response to any online survey to contact you about the following, and we may not so use your data unless we have received your consent (which includes an indication of no objection):
3.2.1 Future Company promotions or events; and
3.2.2 Products, services and promotional events of our business partners (“Business Partners”)
3.3 Your Data may be used by or provided to our Business Partners located within or outside Hong Kong for their direct marketing purposes. However, we will not disclose your Data to any third parties for direct marketing purposes without your consent.
3.4 You can choose not to receive these marketing notifications as described in section 3.2, and/or request us not to transfer your Data to our Business Partners by contacting us via any one of the free response channels in section 9. You can also choose not to receive such marketing materials by email us.
4. Disclosure of Information to Third Parties
We do not transfer, sell, rent or trade your Data to or with third parties (including our Business Partners). Your Data may however be transferred within or outside Hong Kong as follows:
4.1 Companies engaged by us to perform services on our behalf, including fulfilling using the App, sending emails, conducting market surveys, performing customer relations management services, printing promotional materials, advertising our products/ services and providing gift redemption services (together “Third Party Service Providers”);
4.2 Governmental, legal or regulatory authority in Hong Kong;
4.3 Our legal and financial advisers;
4.4 Credit information or reference bureau;
4.5 Debt collection agencies; and
4.6 Our assigns or successor in title in the event of a transfer of SPC Pool Management Limited and/or any other associates, such as acquisition by or merger with another company.
4.7 Our Third Party Service Providers may be supplied with or have access to your Data solely for the purpose of providing the above services on our behalf.
5. Security and Accuracy of Data
5.1 The Data we collect from you are stored in limited-access servers or are encrypted and transferred to other servers of the authorized third parties listed in section 4.1. We will maintain safeguards to protect the security of these servers and your Data.
5.2 The security of your Data depends on the protection by you of your login password. Please do not disclose your login password to unauthorized people.
5.3 We shall take reasonable steps to keep your Data as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Data that is used on an ongoing basis, including information that is disclosed to third parties, will generally be kept accurate and up-to-date. You can update or correct the Data held by us in accordance with section 9.
6. Cookies
6.1 Your information will also be retained in a database for statistical purposes in order to improve the quality of our service. We also collect other non-personally identifiable information when you visit our website, which may include your IP address and what browser you are using.
6.2 We do this by sending small amounts of data called Cookies to your browser. Most browsers are initially set up to accept cookies. You can set your browser so that it refuses cookies if you wish.
6.3 The personally identifiable information can be used to evaluate how our service providers and staff use and navigate our App, including the number of visit, time and access device, in order to evaluate and monitor the usage of the APP.
7. Retention of Data
7.1 We will not keep your Data longer than is necessary for fulfillment of the purposes specified above for which they are, or are to be, used.
7.2 Data provided by you is retained if the purpose for which the Data was collected still exists, it is so required by law, statue or regulation, or it is in the public interest.
8. Children
8.1 We do not knowingly accept information from children under the age of fifteen (15) as they are not eligible to provide services to us and must not submit any Data to us.
8.2 However, as we cannot distinguish the age of persons who access our App, our privacy policy applies to all who access our App. If a child has provided us with personal information without the consent of his parent or guardian, the parent or guardian should email us to request the removal of the information.
9. Data Access and Correction
9.1 You may at any time request access to or update/correct your Data held by us. You may also ask us to delete you or your Data from any active mailing or distribution list.
9.2 If you would like to obtain a copy of your Data held by us in order to correct or delete it from our data base, please contact our HR department at 852-3188 1622.
9.3 If you choose to unsubscribe from our promotional emails or if you have any questions or comments, please contact our HR department on 852-3188 1622. This will be effective ten working days later.
10. Third party websites
10.1 Our privacy policy does not extend to third-party websites that may be linked from our website, or from any other broadcast affiliated with us.
11. General
11.1 By using our App, you signify your consent to our Privacy Policy. We reserve the right to change this policy at any time.
11.2 This policy was last updated on 2 May 2024.
11.3 In the case of discrepancies between the English and Chinese versions, the English version shall apply.