Personal Information Collection Statement and Privacy Policy Statement

Your privacy and security are very important to us. This Personal Information Collection Statement and Privacy Policy Statement governs your use of Open Up, describes what information we collect through the Service provided by Open Up, and explains how we use, transfer, and store your information after we collect it. This Personal Information Collection Statement and Privacy Policy Statement will inform you if and to whom we disclose any of that information, and what choices you have in how we use that information. So before using the Service, please read the following.

Collection and Use of Personally Identifiable Information

Personally Identifiable Information” is any data or information that can be used to identify you, directly or indirectly, including but not limited to, your full name, location data, home address or an online identifier, one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity. We do not collect any Personally Identifiable Information from you other than the phone number you text us from and such other Personally Identifiable Information that we believe would help us to better serve you. During your use of Open Up, you may be prompted (but never required) to voluntarily provide other types of Personally Identifiable Information, including but not limited to, your name or home address.

You will need to use a channel (i.e. WeChat, our web-based chat platform, each a “Channel”) in order to use Open Up. The specific information provided to us by the Channels is determined by these third parties and may vary by Channel. In all cases, the permissions page for a Channel will describe the information being shared. You should consult their respective privacy policies for information about their practices.

When you communicate with us (via our website, email, phone, WeChat, or other Channels), we may maintain a record of your communication.

While we may collect Personally Identifiable Information, we will not share it with any third parties except as noted in this Privacy Policy.

Open Up uses any information collected from you to help us evaluate, develop, deliver, and improve our services. More importantly, Open Up uses such information to assess if you are reasonably suspected to be, or is actually, involved in a life-threatening situation.

We may also use such information for internal purposes such as auditing, data analysis, research, and training to improve Open Up’s services. We may also use such information for teaching purposes.

Our use of such information for research, training, and teaching purposes will follow the Operational Guidelines and Procedures issued by the Human Research Ethics Committee of The University of Hong Kong. These guidelines may be found in the following link: http://www.rss.hku.hk/HREC/guidelines.pdf. When your personal data is transferred for research and analysis, your data will be anonymized (i.e. Personally Identifiable Information will be removed) and will no longer be personally identifiable .

Caritas Hong Kong, The Boys’ & Girls’ Clubs Association of Hong Kong, The Hong Kong Federation of Youth Groups, Hong Kong Children and Youth Service, St James’ Settlement and the University of Hong Kong, as joint-data controller, are located in Hong Kong, outside the European Union.

Collection and Use of Non-Personally Identifiable Information

Caritas Hong Kong, The Boys’ & Girls’ Clubs Association of Hong Kong, The Hong Kong Federation of Youth Groups, Hong Kong Children and Youth Service, St James’ Settlement and the University of Hong Kong also collect non-Personally Identifiable Information, which is information that cannot be directly used to identify or contact you, such as age, gender, language, district , conversation volume and average length of conversation.We may collect, use, transfer, and disclose non-Personally Identifiable Information for any purpose, including but not limited to improving volunteer services, disclosing to third parties (including, for the avoidance of doubt, to Hong Kong Jockey Club Charities Trust) to, among other things, generate support for Open Up, or as required by law.

Volunteers and Counselors

We operate the Service in conjunction with volunteers and counselors. Any information that you share with the service may be viewed by our volunteers or counselors for quality control, to contact emergency services, or to better assist you with your problems.

DISCLOSURE TO THIRD PARTIES

In certain circumstances, we may disclose information we collect from you to additional third parties if we believe such disclosure is necessary: (A) to comply with the law or in response to a subpoena, court order, or other legal process; (B) to protect the interests, rights, safety, or property of Open Up, its affiliates, employees, or agents; (C) to enforce these Terms of Service, or (D) to address fraud, security, technical issues, or to operate the service or its infrastructure systems properly.

We may communicate the data to competent authorities and / or your immediate family members or guardians for the purpose of the protection of your vital interests.

We will not provide your personal data to third parties for direct marketing or other unrelated purposes without your consent.

ACCESS TO, CORRECTION AND ERASURE OF PERSONAL DATA

You understand that pursuant to the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”), you have the right to request access to and correction of your personal data held by Open Up. Under the PDPO, Open Up is entitled to charge a fee to process the said request. In order to verify the relevant data belong to you, requests for access to your data, correction or erasure of your data shall be made via the same Channel using the same account that you communicated with us .

In relation to information regarding data protection policies and practices and kinds of data held, requests shall be made to the Personal Data (Privacy) Officer of [Open Up] at [1/F, 22 Tin Wan Street, Aberdeen, Hong Kong].