Hong Kong-Macao Conference of Seventh-day Adventists (HKMC) and its affiliates
(hereinafter referred to as “HKMC”, “we”, “us” or “our”) undertake to fully meet the
requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong
Kong. In doing so, we will ensure our staff comply with the strictest standards of security
and confidentiality in respect of all personal information and data submitted by you via our
ministries, services, and website.

To protect your privacy, we are committed to safeguarding your personal information (or
“personal data”) to maintain users’ trust.

When we collect personal data from individuals, we will provide them with a Data Collection
Statement ("DCS") on or before the collection in an appropriate format and manner (e.g. in
the same paper form or web page that collects the personal data for reference).

This Privacy Policy Statement (the “Policy”) describes how HKMC collects, uses, and shares
information about you and the choices you can make about how your data is collected,
used, shared, and transferred.

Services covered by this Privacy Policy

This Policy applies to the provisions of all services available from HKMC. We strongly
recommend you read this Policy before using any service related to our services. By using
our services, you agree in advance to the current and future terms of this Policy. This Policy
is applicable to both registered and non-registered users. The provisions herein may be
updated, revised, varied or amended from time to time as HKMC deems necessary.

Information we collected

Personal Data

Personal data is information or data that identifies you as an individual, such as your name,
date of birth, age, gender, nationality, mailing, home address, email address, mobile
number, photo, employment information, income level, pre-paid card, credit card, bank
account, etc. We occasionally collect additional personal information from you to facilitate a
transaction and comply with all applicable anti-money laundering and counter-terrorist
financing laws, regulations, and internal policies.

You are not obliged to provide the information requested; however, we may not render
certain services if you fail to do so.

Device and Connection Information

We automatically collect device information when you install, access, and use our services.
These include your mobile carrier, mobile device model, operation system, browser type
and version, and IP address.

Transaction Pattern

We collect your transaction pattern and behaviour, financial background and demographic
data, products and other service portfolio information.

Usage and Log Information

We collect service-related, diagnostic, and performance information. These include
information about your activity, log files, diagnostic, crash, website, performance logs, and
reports.

Cookies

We use cookies to operate and provide our services, remember your choices, such as your
language preferences, and customise our services for you. Cookies are small data files
placed on your device when you visit certain parts of our website or click on our online
advertisements. Cookies and similar technologies are used to identify your device for the
following purposes:

Strictly necessary cookies. These essential cookies are set throughout our website and are
required for the operation of our website to:
allow our web server to determine whether the cookies setting on your web browser has
been enabled or disabled. It allows us to know whether data can be collected from your web
browser;
temporarily allow you to carry information between pages of our website to avoid having to
re-enter that information;
temporarily identify your device after you have logged in to a secure page on our website so
that our web server can maintain a dialogue with your web browser for you to carry out
certain activities.

Analytical/performance cookies. These are used to help us improve our website by:
tracking your visits to our website and recognising your web browser when you are a repeat
visitor to gather statistics on new and repeat visitors to evaluate site effectiveness.

Functionality cookies. These are used to recognise you when you return to our website. It
enables us to:
personalise our content for you and remember your preferences (for example, your choice
of language and region);
store your login and other preferences, so you do not have to re-enter that information
when you return to the website.

Targeting/advertising cookies. These cookies record your visit to our website, your response
to our online promotions, track the pages you have visited and the website links you have
followed. We use this information to:
make our website more relevant to your interests;
provide online promotions on our website or third-party websites which are most likely to
interest you;
evaluate the effectiveness of our online promotion programs.

The above cookies may be placed on your device by third parties or by us on our behalf. No
personally identifiable information about you is collected or shared with third parties due to
this research.

Status Information

We collect information about your online and status message changes on our services, such
as whether you are online (your “online status”), when you last used our services (your “last
seen status”), and when you last updated your status message.

How we use

Our primary purpose in collecting personal information is to provide you with a safe and
efficient experience, and provide you with services and features that better meet your
needs or requests.

We collect your information for the following purposes:

To verify your identity;
To process your application for any service;
To communicate with you;
To facilitate the daily operation of the services provided to you;
To conduct customer due diligence as required by law and regulations;
To provide you with promotional materials for your interests;
To compile and analyse aggregate statistics about the users’ use of our website and service
for our internal use;
To handle and investigate complaints;
To facilitate HKMC’s use of your personal data for purposes relating to the provision of
services offered by HKMC and/or our affiliates, and promoting services, special events
and/or promotions of HKMC and/or our affiliates;
To meet our obligations, requirements, or arrangements in connection with any law,
regulation, judgement, court order, sanctions regime, within or outside Hong Kong, existing
currently and in the future, and to comply with any guidelines, guidance or requests given or
issued by any legal, regulatory, governmental, tax, law enforcement or other authorities,
self-regulatory or industry bodies or associations of financial services provided within or
outside Hong Kong (the “Authorities”); and
To assist in the prevention, detection, and investigation of crime and suspicious transactions

How we collect information

We collect data when you provide information to us or through the use of web technology.

Disclosure or Transfer of Data

We agree to take all practicable steps to keep all your personal data confidential and/or
undisclosed, subject to the provisions in this section. Generally speaking, we will only
disclose and/or transfer your personal information to our personnel and staff to provide
services to you. However, we may disclose and/or share such information to third parties
under the following circumstances:

Where the information is disclosed and/or transferred to any third party whom we have
duly authorised to use such information under a duty of confidentiality;
Where the information is disclosed and/or transferred to any HKMC agents, affiliates, or
associates whom we have duly authorised to use such information;
Where HKMC needs to protect and defend our rights and property;
Where HKMC considers necessary to do so in order to comply with the applicable laws and
regulations, including without limitation compliance with a judicial proceeding, court order,
or legal process served on HKMC and/or our affiliates;
Where HKMC deems necessary to do so in order to maintain and improve the services; and
personal data collected may be transferred, stored, and processed in any country in which
HKMC operates. You are deemed to have agreed to, consented to, and authorised us to
disclose and/or transfer your personal information under the circumstances stated above.

For the purposes set out above, we may provide your personal information to the following
parties or any of them:

any agents, affiliates, or associates of the HKMC (including their employees, officers, agents,
contractors, service providers, and professional advisers);
any third party service providers who provide services to us or any affiliate of our parent
institutions, in connection with the operation or maintenance of our ministries (including
their employees and officers);
any Authorities;
any persons under a duty of confidentiality to us or any affiliate of Seventh-day Adventist
Church which have undertaken to keep such data confidential;
any credit reference agencies;
any affiliate of Seventh-day Adventist Church;
third party financial institutions and credit card companies;
and charitable or non-profit making organisations.

Access and correct your information

You may access your personal information that we have collected and correct factual errors
in your personal information by sending us a request that credibly shows the error. You also
have the right to ascertain our policies and practices in relation to personal data and be
informed of the kind of personal data held by us.

To protect your privacy and security, we will take reasonable steps to verify your identity
before granting access or making corrections. We reserve the right to charge you a
reasonable fee for complying with any request for access to your data.

Security

We will always strive to ensure that your personal data will be protected against
unauthorised access and have implemented appropriate electronic and managerial
measures in order to safeguard, protect, and secure your personal information.

All personal information provided by you is only accessible by the authorised personnel of
HKMC or our authorised third parties. Such personnel shall be instructed to observe the
terms of this Policy when accessing such data. You may rest assured that your personal
information will only be kept for as long as is necessary to fulfil the purpose for which it is
collected.

You should safeguard your username and password and keep them secret and confidential;
never write them down. We will never ask you for your password, given that you should be
the only person who knows it.

When choosing your username and password, do not use readily identifiable information
such as your birthday, telephone number, or a recognisable part of your name.

If you think your username or password has been disclosed to another person, is lost or
stolen, or an unauthorised transaction has been conducted, you are responsible for
informing us immediately.

We may use third party payment gateway service providers to facilitate electronic
transactions. Regarding sensitive information provided by you, such as pre-paid card or
credit card number for completing any electronic transactions, the web browser and thirdparty
payment gateway communicate such information using secure socket layer
technology (SSL).

No method of transmission over the Internet or method of electronic storage is 100%
secure. Therefore, while we strive to protect your personal information against
unauthorised access, we cannot guarantee its absolute security.

Retention of Personal Data

Once we obtained your personal data, it will be maintained securely in our system. We will
retain the personal information and other data after the deactivation of the relevant service
within a certain period, subject to the law requirements.

Contact us

All requests regarding access to or correction of your personal information should be made
in writing to:

Hong Kong-Macao Conference of Seventh-day Adventists
G/F, 26-28 Hillwood Road
TST, Kowloon
Hong Kong

If you have questions regarding this Policy, please contact our Information Technology
Department at +852 2270 9325 or email us at it@hkmcadventist.org.

Changes in this Policy

We reserve the right to update, revise, modify, or amend this Policy in the following manner
at any time as we deem necessary. You are strongly recommended to review this Policy
frequently. Any update, revise, modify or amend this policy, we will post the latest version
to our website: https://www.hkmcadventist.org/......... and/or other places we deem
appropriate.

Updated on 1 June 2021 in Hong Kong.