Last updated 19 April 2021
A reference to “Social Career,” “we,” “us” or the “Company” is a reference to Social Career Limited and its relevant affiliates involved in the collection, use, sharing, or other processing of Personal Data. Under the Ordinance, Personal Data means any data or information relating to an individual and from which it is practicable for the identity of that individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.
We are committed to protecting the privacy, confidentiality and security of the Personal Data we hold by complying with the requirements of the Personal Data (Privacy) Ordinance (Cap 486) (the “Ordinance”) with respect to the management of Personal Data. We are equally committed to ensuring that all our employees and volunteers uphold these obligations.
2. Processing activities covered
· you sign-up for or use the Services;
· you use our App;
· you visit our branded social media pages;
· you receive communications from us, including emails;
· you register for, attend or take part in our Events, Social Services or Volunteer Opportunities; or
· processing of Personal Data is required for receiving the Services.
Our Website, App and Services may contain links to other website, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy policies, which you should review to better understand their privacy practices.
3. What Personal Data do we collect?
Personal Data we collect directly from you
The Personal Data we collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information.
Examples of such information your full name and email address, your mobile number and location, and your photograph or any other optional profile information (such as gender, date of birth, living district) provided by you in relation to your User Account (“Profile Information”) and the types of Events, Volunteer Opportunities or Social Services in which you may be interested.
We collect such information in the following situations:
· when you register for a User Account (including your preferences in respect of Events, Volunteer Opportunities and Social Services);
· when you apply for or participate in any Event or Volunteer Opportunity (including the date, time, venue and nature of the Event or Volunteer Opportunity);
· if you express an interest in obtaining additional information about the Services, request customer support, use our “Contact Us” or similar features, or download certain content, we may require that you provide us your Profile Information;
· if you interact with our Website, App or emails, we automatically collect information about your device and your usage of our Website, App or emails (such as Internet Protocol (“IP”) addresses or other identifiers), which may qualify as Personal Data using cookies or similar technology;
· if you use and interact with the Services, we automatically collect information about your device and your usage of the Services through log files and other technologies, some of which may qualify as Personal Data;
· if you communicate with us via a phone call from us, we may record that call; and
· if you voluntarily submit certain information or content to the Services, we collect the information you have provided as part of that request.
When we request any other Personal Data from you, we will notify you at the time of collection through a PICS as to the Personal Data we require from you.
Please note that it is voluntary for you to provide your Personal Data when signing up for a User Account, which may include your name, contact telephone number, email address, mailing address. It is mandatory for you to provide your Personal Data when signing up for an Event. In the event you do not provide such Personal Data, we may not be able to:
· process or complete your application for a User Account;
· provide you with the Services;
· process or complete your request to participate in any Events or Volunteer Opportunities or to keep a record of the Events or Volunteer Opportunities in which you have participated;
· respond to any queries submitted by you; or
· publish any of Your Content, as requested by you.
If you believe that your Personal Data has been provided to us improperly, or want to exercise your rights relating to your Personal Data, please contact us by using the information in the “Contact us” section below.
4. Information we collect automatically
We use common information-gathering tools, such as tools for collecting usage data, cookies, pixels, and similar technologies to automatically collect information that may contain Personal Data as you navigate our Website, our App, the Services, or interact with emails we have sent to you.
Device and usage data
As is true of most websites or applications, we gather certain information automatically when individual users visit our Website or use our App. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the Website or App. This information is used to analyze overall trends, help us provide and improve our Website and App, offer a tailored experience for Website and App users, and secure and maintain our Website and App.
In addition, we gather certain information automatically as part of your use of the Services. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, Website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage. This information is used to maintain the security of the Services, to provide necessary functionality, to improve performance of the Services, to assess and improve client and user experience of the Services, to review compliance with applicable usage terms, to identify future opportunities for development of the Services, to assess capacity requirements, to identify client opportunities, and for the security of Social Career generally (in addition to the security of our Services).
Some of the device and usage data collected by the Services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.
Tracking technologies on our Website and App and in email communications
We use certain technologies to provide, monitor, analyze, promote and improve the Services, alone or in conjunction with cookies, to gather information about the use of our Website and App and how people interact with the Services.
When you visit our Website, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer-browsing preferences, and improve and customize your browsing experience. For example, a cookie is used to remember your user name when you return to the Services, and to improve our understanding of how you interact with the Services. You can block cookies on your web browser; however please be aware that some features of the Services may not function properly if the ability to accept cookies is disabled.
We also use pixels on our Website, App and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our Website, App and marketing emails. For instructions on how to unsubscribe from our marketing emails, please see below.
When you use the Services, our servers automatically record certain information in server logs. These server logs may include information such as your web request, IP address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Services, domain names, landing pages, pages viewed, mobile carrier, and other such information. Log files help us to monitor, analyze, improve and maintain the Services and to diagnose and fix any Services-related issues.
When you access the Services using a mobile device, we collect specific device information contained in your mobile device's device identifier. This device identifier includes information such as the type of device you are using, its operating system, and mobile network information, which may include your mobile phone number. We may associate this device identifier with your User Account and will use data associated with your device identifier to customize the Services to your device and to analyze any device-related issues.
We may collect and process information about the location of the device from which you are accessing the Services. Location data may convey information about how you browse the Services and may be used in conjunction with personally identifiable information. You can disable location based services in settings associated with the Services; however please be aware that some features of the Services may not function properly if location services are turned off.
Social media features
Our Website and App may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (collectively, “Social Media Features”). Social Media Features may allow you to post information about your activities on our Website and App to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our Website, our App or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our Website and App. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our Website, the platform may receive information showing that you have visited our Website or App. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our Website or App with your social media profile.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
5. Purposes for which we process Personal Data and the legal bases on which we rely
We will collect, retain and use your Personal Data for the purposes set out in the relevant PICS, or in accordance with any further express consent provided by you. In addition to verifying your identity, such purposes may include the following:
Promoting the security of our Website, App and Services: We process your Personal Data by tracking use of our Website, App and Services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others.
Managing user registrations: If you have registered for an account with us, we process your Personal Data by processing and completing your application for registration of a User Account and administering your User Account.
Volunteer Opportunities and Events: We process your Personal Data to: (i) provide you with information regarding any Volunteer Opportunities and Events for which you have applied; (ii) to keep a record and provide you (and, if relevant, your employer or school) with information and details regarding: (1) your User Account activities; (2) any Volunteer Opportunities and Events for which you have applied or participated; (3) Your Content; or (4) any NGOs, Social Enterprises, Volunteer Opportunities and Events, or types of NGOs, Social Enterprises, Volunteer Opportunities and Events, for which you have expressed an interest.
Managing registrations and attendance: We process your Personal Data to plan and host Volunteer Opportunities or Events for which you have registered or that you attend, including sending related communications to you, to perform our contract with you.
Developing and improving our Website, App and Services: We process your Personal Data to analyze trends and to track your usage of and interactions with our Website, App and Services to the extent it is necessary for our legitimate interest in developing and improving our Website, App and Services and providing our users with more relevant content and service offerings, or where we seek your valid consent.
Assessing and improving user experience: We process device and usage data as described above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering, or where we seek your valid consent.
Reviewing compliance with applicable usage terms: We process your Personal Data to review compliance with the applicable usage terms in the Agreement to the extent that it is in our legitimate interest to ensure adherence to the relevant terms.
Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of the Services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offering.
Identifying User opportunities: We process your Personal Data to assess new potential User opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our Users and their users’ experiences.
Recording phone calls: We may record phone calls for training, quality assurance, and administration purposes. If required under applicable law, we will obtain your prior consent or give you the option to object to a call being recorded.
Displaying personalized advertisements and content: We process your Personal Data to provide you with a more personalised experience in respect of the Services and your User Account, including conducting marketing research and to provide other personalized content based upon your activities and interests to the extent you have provided your prior consent.
Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our Website or App, protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes. We also process your Personal Data to enforce our rights against you in any legal proceedings, or to defend ourselves against any claim, in relation to you.
Additional: We process your Personal Data for any other purpose that you have consented to and/or which has been notified to you on or before the time when the Personal Data is collected.
6. Marketing activities
We cannot use your Personal Data without your prior consent or ‘no objection’ for the purposes of providing you with marketing materials. We also cannot transfer your Personal Data to any third parties (including any NGOs and Social Enterprises) for their use in direct marketing without your prior consent.
Please note that it is voluntary for you to provide your Personal Data for direct marketing and Marketing Materials.
Subject to your prior consent, and the further details set out in the relevant PICS provided to you, we may use your name and email address to send you messages, announcements and/or information regarding:
· the Services;
· any mentoring opportunities organised by us in relation to Volunteer Opportunities; or
· any Volunteer Opportunities, Events or Social Services that we think you may be of interest to you (“Marketing Materials”).
Subject to your consent, we may transfer your Personal Data to specified NGOs or Social Enterprises to enable them to directly send you messages, announcements and/or information in relation to the activities of the NGO or Social Enterprise, or any Volunteer Opportunities, Events or Social Services hosted or operated by the NGO or Social Enterprise.
You can exercise your right not to receive some or all of the Marketing Materials, or to not have your Personal Data transferred to the NGOs or Social Enterprises for marketing purposes, by checking the opt-out box on the relevant forms we use to collect your Personal Data. You can also opt-out of receiving any Marketing Materials at any time by notifying us in writing at the email address stated below, or through your User Account.
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt of marketing and non-transactional communications from Social Career by clicking on the “unsubscribe” link located on the bottom of Social Career marketing emails or by emailing us at firstname.lastname@example.org.
Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as communications about your subscriptions or event registrations, service announcements or security information.
7. Who do we share Personal Data with?
You agree that we may share the Personal Data we collect from you with third parties as detailed below, in order to achieve the purposes outlined in the PICS provided to you on or before the collection of your personal data, and/or in accordance with any express consent provided by you. Provided you have given your consent in writing, some of the below third parties may be located in countries outside the country in which you are located, including in countries that may not provide the same level of data protection.
As directed by you
We will display your Profile Information on your profile page and elsewhere on the Services in accordance with the preferences you set in your User Account. You can review and revise your Profile at any time.
We will display Your Content on the Services, as directed by you. You understand and agree that Your Content submitted via your User Account for posting on the Services, shall be publicly available and can be viewed by anyone who accesses or uses the Services.
Anyone using our Services, Website or App may read any Personal Data or other information you choose to submit and post.
With trusted service providers
We may also store Personal Data in locations outside the direct control of Social Career (for instance, on servers or databases co-located with hosting providers).
NGOs and Social Enterprises
We may provide your Personal Data to NGOs and Social Enterprises who are hosting or operating the Volunteer Opportunities, Events or Social Services that you have applied to join or use, in order to enable the NGO and Social Enterprise to process your application and to provide you with information regarding the Volunteer Opportunity, Event or Social Service.
As stated in paragraph 5, subject to your consent we may transfer your Personal Data to specified NGOs or Social Enterprises for the purposes of enabling them to send you Marketing Materials.
If you use our Website or App to register for a Volunteer Opportunity, Event or Social Service organized by one of our affiliates, we may share your Personal Data with the affiliate to the extent this is required on the basis of the affiliate’s contract with you to process your registration and ensure your participation in the event; in such instances, our affiliate will provide you with further information on the processing of your Personal Data, where required.
Employee Volunteers and Schools
If you are volunteering through your employer or school, then you agree that your Personal Data may be shared by us with your employer or school.
In individual instances, we may share your Personal Data with professional advisers acting as service providers, processors, or joint controllers - including lawyers, bankers, auditors, and Hong Kong based provide consultancy, banking, legal, insurance and accounting services, and to the extent we are legally obliged to share or have a legitimate interest in sharing your Personal Data.
With law enforcement or in order to protect our rights
We may disclose your Personal Data if required to do so by law or pursuant to any order issued by a court, tribunal or regulatory authority of competent jurisdiction. We may also disclose your information to our legal counsel, governmental authorities or law enforcement if we believe that it is reasonably necessary to do so in order to enforce our legal rights; comply with a law or regulation; to protect the safety of any person; to address fraud, security or technical issues; or to protect Social Career's rights or property.
In an aggregate and non-personally identifiable manner
We may disclose aggregate non-personally identifiable information (such as aggregated and anonymised data usage, platform types, etc, which do not amount to Personal Data) about the overall use of our Services, to the public or to interested third parties to help them understand, or to help us improve, the Services.
In connection with a sale or change of control
8. Privacy of Children
Social Career does not knowingly collect or solicit Personal Data from anyone under the age of 13 or knowingly allow such persons to register for a User Account. Children under the age of 13 must obtain parental consent before they apply for a User Account, use our Service and/or provide us with any of their Personal Data. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contact us” section below and we will take steps to delete their Personal Data from our systems.
9. How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection or as long as required to fulfil our legal obligations. We determine the appropriate retention period for Personal Data on the basis of the amount, nature, and sensitivity of the Personal Data being processed, the potential risk of harm from unauthorized use or disclosure of the Personal Data, whether we can achieve the purposes of the processing through other means, and on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Data will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will implement appropriate measures to prevent any further use of such data.
10. Your rights relating to your Personal Data
You have certain rights relating to your Personal Data, which include the right to:
· access your Personal Data held by us;
· know more about how we process your Personal Data;
· rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
· erase or delete your Personal Data, to the extent possible;
· restrict our processing of your Personal Data, to the extent possible;
· object to any processing of your Personal Data;
· where we process your Personal Data for direct marketing purposes or share it with third parties for their own direct marketing purposes, you can exercise your right to object at any time to such processing without having to provide any specific reason for such objection;
· opt out of certain disclosures of your Personal Data to third parties;
· not be discriminated against for exercising your rights described above;
· withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.
How to exercise your rights
To exercise your rights, please contact us by using the information in the “Contact us” section, below. Your personal data may be processed in responding to these rights. We try to respond to all legitimate requests within fourty (40) days unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us by using the information in the “Contact us” section, below.
Your rights relating to Customer data
11. How we secure your Personal Data
The security of your Personal Data is important to us. When you provide Personal Data through the Services, we encrypt the transmission of any Personal Data that we deem to be particularly sensitive by using industry-standard encryption.
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use. Social Career uses commercially reasonable and industry-standard physical, managerial and technical safeguards to preserve the integrity and security of your Personal Data. For example, we continuously and regularly back-up your data to help prevent data loss and aid in data recovery. We also guard against common web attack vectors, we host data in secure data centres, and we have firewalls and access restrictions on our servers to secure our network and to better protect your Personal Data.
Although we take reasonable steps to safeguard your Personal Data from unauthorised access, use or loss, please be aware that no security measures are perfect or impenetrable. We cannot control the actions of other Users with whom you share Your Content and we are not responsible for any third party circumvention of any privacy settings or security measures on the Services. You are solely responsible for protecting your password, limiting access to your devices and signing out of our Website and App after your sessions. If you have any questions about the security of our Website and App, please contact us by using the information in the “Contact” us” section, below.
13. Contacting us
Please contact the Customer Service of Social Career at email@example.com, if you:
· wish to submit a request to access or correct your Personal Data held by us; or
· wish to withdraw your consent to the receipt of any Marketing Materials.
Whenever the words include, includes, including or in particular (or similar derivates) are used, they are deemed to be followed by the words without limitation.
In addition to the above defined terms, capitalised terms used in these Terms shall have the following meanings:
“Agreement” means the Terms of Service at https://socialcareer.org/en/legal/terms/tos, the Master Services Agreement at https://socialcareer.org/en/legal/msa, and any terms and policies incorporated herein by reference, including any additional terms and each update or amendment of any of the foregoing from time to time.
“App” means Social Career’s proprietary mobile application available on the Apple App Store and Google Play Store, which users can access our Services through.
“Event” means any form of event, activity, campaign or webinar posted on the Website and App.
“Features List” means the list at https://socialcareer.org/#!/nonprofit maintained by Social Career specifying the services Social Career will provide to its Users according to the plan elected by the User under the Agreement.
“Ordinance” means the Personal Data (Privacy) Ordinance (Cap 486).
"Personal Data" means any data or information relating to an individual and from which it is practicable for the identity of that individual to be directly or indirectly ascertained, and in a form in which access to or processing of the data is practicable.
"PICS" means any personal information collections statement provided by us to you on/or before the collection of your Personal Data.
“Profile Information" means your full name and email address, your mobile number and location, and your photograph or any other optional profile information (such as gender, date of birth, living district) provided by you in relation to your User Account.
"Services" means, as applicable, the Software and services provided by Social Career, as set out in detail in the Features List, and the processing, administration and provision of the following on our Website or App:
· publishing of Events, Volunteer Opportunities and Social Services onto the Website and App to be viewed and applied for by Users;
· provision of information to Volunteers and their employers or schools (as applicable) regarding the Volunteer Opportunities and Events that the Volunteers have participated in; and
· other related services that we decide to provide, from time to time, in our sole discretion.
“Software” means the client relationship management (‘CRM’) platform, all cloud-based software components (and any associated APIs, if applicable) and any downloadable tools provided by Social Career to the Customer under the Agreement, and any copies, updates, modifications, derivative works or enhancements thereto.
"Social Career", "we", "us" or "our" means Social Career Limited, a company incorporated under the laws of Hong Kong with its registered office at Unit 7, 12/F, Siu Wai Industrial Centre, 29-33 Wing Hong Street, Lai Chi Kok, Kowloon, Hong Kong.
"Social Enterprise" means a for-profit company formed and registered under the new or a former Hong Kong Companies Ordinance which comply with our onboarding requirements.
“Social Services” means the public services provided by the government, NGOs, Social Enterprises and other forms of organizations posted on the Website and App.
"User(s)" means any individual, entity or organisation who accesses, views or uses the App, Website or Services.
"User Account" means an account established for a User to be able to use the Services.
"you" or "your" means you, the person who is accessing, using or viewing the App, Website or Services, and any NGO or Corporate Volunteer on whose behalf you are accessing, using or viewing the App, Website or Services.
"Your Content" means any content that is provided, uploaded, transmitted, submitted or posted by or sourced from you.
"Volunteer" means a person who holds a User Account, and who uses the Services to volunteer and provide services to an NGO for free.
"Volunteer Opportunities" means opportunities offered and posted by NGOs and Social Enterprises on the Website and App seeking volunteers to provide services to that NGO or Social Enterprise for free.
“Website” means www.socialcareer.org, or any related subdomains hosted by Social Career from time to time.