Purpose

This statement sets out the policies and practices of Be Priceless Limited (“Be Priceless”, “we,” “us,” or “our”) in relation to our collection, use and processing of personal data.

General Principles

Be Priceless is committed to safeguarding the privacy and security of personal data held by us, including personal data of any applicants to and participants of our Self-value, Empower, Educate, and Protect from Dangers (“SEED”) program, including but not limited to the children enrolling or attending the SEED program and their parents, legal guardians and/or emergency contact (“you”, “your”). Be Priceless pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“PDPO”). We have implemented the following principles to ensure compliance and protect personal data: least privilege, by restricting access to authorized individuals on a need-to-know basis only; integrity, by maintaining the accuracy and completeness of data; and confidentiality, by ensuring data will not be disclosed to any third parties. These principles guide our efforts to handle personal data responsibly and securely.

Key Definition of PDPO

• Personal data means information which relates to a living individual and can be used to identify that individual, in a form which access to or processing of is practicable.
• Data subject is the individual who is the subject of the personal data.
• Data user is a person who, either alone or jointly with other persons, controls the collection, holding, processing or use of personal data.
• Data processor is a person who processes personal data on behalf of another person (a data user), instead of for his/her own purpose(s). Data processors are not directly regulated under the PDPO. Instead, data users are required to, by contractual or other means, ensure that their data processors meet the applicable requirements of the PDPO.

Types of Data Collected

The types of personal data we may collect from or about you include but are not limited to the following:

• name;
• gender;
• age;
• date of birth;
• email address;
• phone number;
• living conditions;
• nationality;
• special education needs, medical conditions or food allergies;
• viii) financial information and other information relating to the living conditions of the child’s household;
• information collected from the child attending the SEED course and participating in the associated study (“Study”), including visual and audio recordings and photos taken during the course, responses to questions of self-evaluation and course feedback; and
• other data collected in or imported from our Study.

Main Purposes of keeping Personal Data

At Be Priceless, we prioritize the confidentiality and privacy of all personal information shared when applying for or attending the SEED Health Education Programme. Any details you provide, such as names and contact information, will be kept strictly confidential. When reporting on the findings of the study, we ensure that NO identifiable information about you or your child will be disclosed. We hold personal data in order to:

• Administer our health behavioural programs and services (including coordination, communications, services implementation, monitoring, follow-up, and reporting relating to the same), and to ensure the safety of all attending participants and our team
• Communicate with and support our program participants and partners, including notifying you of our future activities with your consent
• Engage the public in our works, including publishing reports and stories using aggregated or anonymized data from our studies
• Develop and manage our donations and other sources of funding
• Evaluate and improve our programs and to train our staff
• Comply with legal and regulatory obligations

The information relating to the studies conducted or findings and results of the same may be reviewed by the research staff and study partners. If necessary, it may be reviewed by the research monitoring board to make sure that the study is properly done and the data is properly used. Data provided for this reason will NOT show personal data of any participants, their names will NOT be linked to the study content reported. Unless specified above, permitted or required by law, Be Priceless will not disclose the personal data of participants to any third parties without obtaining participants’ prior consent.

Retention of Your Personal Data

The personal data we retain will be stored on a secure database for as long as necessary to fulfil the purposes for which the personal data were collected. Personal data which is no longer required will be destroyed or dealt with in accordance with the PDPO. In the event you request to remove personal information of you and your child, the data will be removed as soon as practicable. Partner Organization shall destroy and erase all personal data upon delivery of the personal data to Be Priceless after expiration of the Term or early termination of the Agreement. Be Priceless shall destroy and erase all personal data after 7 years after publication of the Evaluation Report of the Study (which Study shall continue until the child reaches the age of 17).

Data access and correction

Under and in accordance with the PDPO, you have the right to ascertain whether we hold your personal data upon presentation of proof of your personal identity, to obtain a copy of that data, and to correct any data that is inaccurate.

If at any time, you and your child feel uncomfortable or unsafe, or want to exercise your right to request for access and/or correction of your personal data as mentioned above, please contact our data protection officer at privacydata@bepriceless.org.

Enquiries

Any enquiries regarding personal data, or requests for access to or correction of personal data, can be made to our [data protection officer] at Be Priceless by post or email.

Address: 17B Billion Plaza Phase 2, 10 Cheung Yue Street, Cheung Sha Wan, Kowloon

Email: privacydata@bepriceless.org

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