PERSONAL INFORMATION COLLECTION STATEMENT ("PICS")
1. YOUR PRIVACY
Fitness Academy (HK) Company Limited (“FAHK”, together with its subsidiaries, “we”, “our” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this PICS explains our privacy practices. It is our policy to pledge to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region (“Hong Kong” or “HK”). In doing so, we will ensure compliance by our staff to the strictest standards of security and confidentiality.
We limit the collection and use of personal data (which is information about individuals from which it is possible to identify that individual) to the specific information we need to operate our business, provide our services to you and offer various opportunities and information which may be of interest to you. Where we do collect personal data from you, we :
tell you that we are doing so and the use that we will make of such personal data we collect;
give you the opportunity to object to use of your personal data; and
tell you how we will store your personal data and how you can review, change and delete the personal data we have stored.
This statement explains our practice in relation to the collection, retention, storage and sharing of personal data.
2. COLLECTION AND USE OF PERSONAL DATA
We collect your personal data once you register as a user (for purpose of this PICS, including trial user) at our website at the URL www.fitnessacademyhk.com (“Website”). If you are under the age of 13 you must ask a parent or your guardian before providing any personal data to us.
If you want us to process your registration to be a user of the Website, you must provide the personal data marked as “mandatory” in the Membership Registration Form. Such personal data provided by you will be used by FAHK for the purposes of:
the daily operation of us and our products and services provided to users;
application, administration, continuation, alteration, enhancement and termination of the use of our products and services;
providing you with news, notices and other communications of us;
processing and requesting billing and payment, determining amounts outstanding, and if necessary, collection of outstanding payments;
handling and following up service request, enquiries and complaints by call, emails, correspondence or other appropriate means;
verification of your identity;
complying with obligations, requirements, recommendations and instructions to make disclosure to any regulatory or other authorities (including industry and self-regulatory bodies) in Hong Kong under the requirements of any laws binding on us;
enabling us to better understand the demographics and background of our registered users; and
purposes directly relating to any of the above purposes.
It is entirely voluntary for you to provide personal data which is not marked as “mandatory” in the Membership Registration Form. Purposes for which it is only voluntary for you to provide your personal data are:
to enable our actual and potential investors or business partners to better understand the demographics and background of our users; and
to enable us to provide and develop other services better tailored to your needs.
3. USE OF DATA IN DIRECT MARKETING
We intend to use your personal data in direct marketing, and we may not so use your personal data unless we have received your consent (which includes “an indication of no objection” to the use or provision). We shall use your surname, given name and contact information for following activities:
marketing of the products and services of FAHK;
marketing of rewards, promotions, events and benefits related to or offered by FAHK; and
joint promotion with merchants and business partners offering discounts, special offer or other benefits of us or such merchants and business partners to our users from and in relation to goods and services of or relating to the following industries:
food and beverages;
health and lifestyle;
apparels, equipments and accessories; and
entertainment, leisure and sports.
The provision of a user’s personal data to the other persons above may be for our gain.
If you desire to opt-out from receiving any direct marketing materials from us in the future, you can do so at any time by contacting us at email@example.com.
Some personal data may be gathered over the Internet through the use of “cookies”. Cookies are small bits of information that are automatically stored by a website on a person’s web browser in their computer that can be retrieved by that website. The information collected by “cookies” is anonymous aggregated research data and contain no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means. Most web browsers automatically accept cookies, but you can edit your browser options to block them. However, if you do so, you may not be able to access certain areas of our Website.
We will take all practicable steps to keep your personal data confidential but we may transfer/assign such data to all the following parties (i) for the purposes set out in mandatory usage under paragraph 2 above and (ii) if the user agrees, the purposes set out under paragraph 3 above:
any agent, adviser, auditor, contractor or service provider who provides services to us in connection with our operations insofar as required to enable us to provide, or assist us in providing, the services to you;
any person to whom FAHK is under an obligation to make disclosure under the requirements of any law binding on FAHK or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities (including industry and self-regulatory bodies) with which FAHK is expected to comply;
any other person under a duty of confidentiality to us which has undertaken to keep such information confidential;
if FAHK decides to sell any relevant part of business, to any actual or proposed assignee, transferee or successor of or to FAHK’s rights in respect of your personal data;
any actual or proposed assignee of us or participant or sub-participant or transferee of our rights in respect of the users;
merchants and business partners having joint promotion relationship with us to provide marketing services on their behalf), for marketing purposes (including informing user of services which we believes will be of interest to users); and
to any other parties whom the user has expressly or impliedly authorized us to make such disclosures as may be reasonably necessary or expedient to procure or fulfill the user’s request(s) for services.
Except as mentioned in paragraph 5 above, your personal data, however stored, will be accessed only by our employees, agents or contractors who are authorised to do so. Where personal data is stored electronically, it will be kept on a server and will be password-protected (or under some equivalent form of protection) and accessible only by authorised personnel of FAHK or its contractors. Employees, agents and contractors designated to handle personal data will be instructed to do so only in accordance with this PICS.
7. USE OF PERSONAL DATA IN LEGAL PROCEEDINGS
If it becomes necessary that we have to take action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and taking legal action against you.
8. DATA ACCESS AND CORRECTION
You may at any time request access to and to correct personal data relating to you in any of our records. You may also ask us to delete and alter you or your personal data from any active mailing or distribution list. To exercise any of your rights, contact us at the address or email below, marking your communication “Confidential”. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days, but we may charge you a reasonable fee for doing so. We will not retain your personal data if you request us to terminate your registration. In the case of termination, we will erase your personal data as soon as practicable after we are no longer obliged to retain such data by law.
9. PERSONAL DATA PRIVACY OFFICER
The person to whom (1) requests (i) for access to data or correction of data, (ii) for general information regarding our policies and practices with respect to personal data and (iii) about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:
Fitness Academy (HK) Company Limited
Shop D, G/F, King’s View Court
901-907 King’s Road, Quarry Bay
Hong Kong SAR
Attention: Personal Data Privacy Officer (Marked Confidential)
10. RETENTION OF DATA
We will keep your personal data for as long as necessary to fulfill the purpose for which the data was collected. We may also retain archived personal data for statistical purposes. Personal Data which is no longer required will be destroyed.