Privacy policy

Statement of Policy

The Osage Publications (“OP”) respects personal data privacy. We will comply with the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong SAR) (“the Ordinance”) and are committed to fully implement the data protection principles promulgated under the Ordinance.

Statement of Practices

INFORMATION WE COLLECT

From time to time, we may collect various types of personal information (such as email address, name and contact number) from you in connection with our provision of services, activities and facilities, including but not limit to account registration, ticketing transaction, e-newsletter subscription, product purchase, event registration, membership, Wi-Fi usage, payment, following up on enquiries, conducting customer surveys, venue booking, fundraising campaigns etc.

MAIN PURPOSE OF KEEPING PERSONAL DATA

The main purposes of keeping the personal data are as follows:
for processing your service requests (i.e. event registration, ticket purchase, e-newsletter subscription, product purchase, WiFi usage, member registration, venue booking, donation etc.) with us and provide you with the services;

for facilitating communications between you and us;

for notifying you of changes to our services that may affect you;

for responding to and follow up on your enquiries;

for personalising your experience of OP with programmes and offerings that are most relevant to your interests;

for direct marketing upon obtaining explicit consent from you;

for managing customer relationships;

for communicating with you for potential support to OP that is relevant to your interests and appropriate;

for conducting statistical analysis, research, surveys, quality assurance and review; and

for other purposes directly relating to any of the above.

We may combine information you provide to us through various channels, such as online channels like websites / mobile applications, offline channels like physical application forms, or publicly available information about you. We use this combined information to help personalise your experience and communicate with you about events or offerings that may be of particular interest to you.

IMPLEMENTATION OF PRACTICES

We will implement the practices at (a) to (e) below in accordance with the data protection principles in the Ordinance.

(a) Collection of personal data

When collecting personal data, OP will satisfy itself that:

the purposes for which the data is collected are lawful and directly related to a function or activity of OP;

the manner of collection is lawful and fair in the circumstances; and

the personal data collected is necessary but not excessive for the purpose(s) for which it is collected.

When we collect personal data from a data subject, the data subject will be provided with a Personal Information Collection Statement (“PICS”) on or before the collection in an appropriate format and manner. Practicable steps will be taken to ensure that –

the data subject is informed of whether it is obligatory or voluntary to supply the data and, if obligatory, the consequences in failing to do so; and

the data subject is explicitly informed of the purpose(s) for which the personal data is to be used, the classes of persons to whom the data may be transferred or disclosed, the rights of the data subject to request access to and correction of the data, and the contact of the office to whom any such request may be made.

If OP intends to use the personal data collected for a new purpose, other than the purpose of first collection as stated in the PICS, we will obtain a prior consent from the data subject before the usage. We will, manually or electronically, keep track of the PICS to ensure that the personal data is only used for the purpose(s) stated in the PICS.

(b) Accuracy and retention of personal data

Personal data collected and maintained by OP will be as accurate, complete, and up-to-date as is necessary for the purpose(s) for which it is to be used.

OP maintains a personal data inventory, which contains the kinds of personal data that we hold, the purposes for which the personal data is collected, used and disclosed, and how the personal data is stored. The personal data inventory will be reviewed on an annual basis to ensure that it is accurate and up-to-date.

We will only retain your personal data for as long as is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We will not keep more information than we need. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. Personal data that is no longer required will be erased unless such erasure of personal data is prohibited under any law or it is in the public interest for the data not to be erased. Should there be a need to retain personal data for statistical purposes, such personal data will be anonymised so that the individuals concerned can no longer be identified.

A destruction of records containing personal data will be conducted as and when necessary. Destruction of paper records will be carried out by irreversible means and electronic records will be cleared or destroyed from storage media before disposal by means of sanitisation or physical destruction.

(c) Use of personal data

All personal data collected will be used only for purposes which are directly related to the discharge of OP’s functions. We will never sell, rent or exchange your details with any other organisation outside OP. We will ask for your consent to share personal information with third parties. Some of our service providers may have access to your data in order to perform services on our behalf. We require all service providers to respect the security of your personal data and comply with the Ordinance. We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. Personal data may also be disclosed to other entities which are authorised to receive information for law enforcement, prosecution or review of decisions. The data subject will be informed of the transferees of personal data when the data subject’s personal data is collected. For personal data that is stored in cloud servers of cloud service providers for OP, personal data may be transferred out of Hong Kong where the cloud servers are located.

If personal data is to be used for a purpose other than the purposes for which the data is collected, prior consent will be sought from the data subject. In seeking the consent, all practicable steps will be taken to ensure that (i) information provided to the data subject is clearly understandable and readable; and (ii) the data subject is informed that he is entitled to withhold his consent or withdraw his consent subsequently by giving notice in writing.

We will not use personal data or provide personal data for use in direct marketing without data subject’s explicit consent. If OP intends to use the personal data for direct marketing, we will obtain explicit consent from the data subject before using the data subject’s personal data, and will notify the data subject when using personal data in direct marketing for the first time, and will cease to use the data in direct marketing if the data subject so requires. If OP intends to provide personal data to another person for use by that other person in direct marketing, we will inform the data subject in writing in advance that OP intends to provide the personal data and will not provide the personal data unless it has received the data subject’s explicit consent. A data subject may, at any time, require OP to cease using the data subject’s personal data in direct marketing by informing the OP through the channels as stated in practice (e) below.

(d) Security of personal data

We observe strictly all relevant security standards and regulations. Security arrangements will be reviewed regularly to ensure that personal data is protected against loss and unauthorised or accidental access, use, disclosure, modification and erasure. The security arrangements include, without limitation, the following:

restriction of access to personal data on a “need-to-know” basis;

regular review and enhancement of security measures for protection of personal data in the servers, user computers, or transmission of electronic messages;

regular change of passwords for IT facilities, or accounting and personnel systems;

encryption of all backup tapes that are to be transported to offsite storage;

limited staff access rights to office areas storing confidential information; and

provision of clear guidelines to staff as to the types of data that may or may not be disclosed to a phone enquirer and implementation of appropriate identity verification procedures to confirm the enquirer’s identity.

(e) Access to and correction of personal data

We recognise a data subject’s rights of access to and correction of his own personal data in accordance with the Ordinance. To make a data access request, a data subject should complete the form specified by the Office of the Privacy Commissioner for Personal Data, which is available at http://www.pcpd.org.hk/english/publications/files/Dforme.pdf, and submit the completed form to OP in any one of the following ways –

By email/post/in person:

By email at enquiry@osagepublications.com; or

By post to Osage Publications, 4/F, 20 Hing Yip Street, Kwun Tong, Kowloon, Hong Kong.

Attn: Personal Data Privacy Department

(Marked Confidential)


When handling a data access or correction request, we will check the identity of the requester to ensure that the requester is the person legally entitled to make the data access or correction request.

OP may impose a fee for the necessary cost of complying with a data access request. We will clearly inform the requester the amount to be charged.

We may refuse a data access request in the circumstances specified in Section 20 of the Ordinance.

We maintain a log book recording the data access or correction requests received as required under Section 27 of the Ordinance.

Use of Cookies – When you browse this website, cookies will be stored in your computer’s browser. The purposes of using cookies are to remember the browsing preferences (e.g. language, font size) you have chosen in this website to customise your experience. You have a choice not to accept the cookies. If you do not accept the cookie, this website will not be able to remember your browsing preferences and we may not be able to deliver the full features of our website to you. We also use third party cookies such as Google Analytics to analyse anonymised data to help us understand how our audiences interact with our site so that we can improve the overall experience. The cookie itself does not collect any Personally Identifiable Information.

Website Statistics–When you visit our websites, we will record your visit only as a “hit”. The webserver makes a record of your visit that includes your IP addresses (and domain names), the types and configurations of browsers, language settings, geo-locations, operating systems, previous sites visited, and time/duration and the pages visited (webserver access log).

We use the webserver access log for the purpose of maintaining and improving the website such as to determine the optimal screen resolution, or which pages have been most frequently visited. We use such data only for website enhancement and optimisation. User data is all anonymous.

INCIDENT REPORTING AND BREACH HANDLING

A mechanism is set up for incident reporting and breach handling in case there is a loss or leakage of personal data, or there is a reason to believe that the personal data held by OP has been compromised.

ONGOING MONITORING AND REVIEW

We will keep this Privacy Policy Statement and relevant policies under regular review. Officers responsible for handling personal data will attend relevant training courses to keep themselves updated of the latest personal data policies.

ENQUIRIES

Any enquiries regarding personal data privacy policy and practice may be addressed to above correspondence addresses, via email at enquiry@osagepublications.com.
Attn: Personal Data Privacy Department
(Marked Confidential)

INTERPRETATION

Words used herein which import the singular only also include the plural and vice versa where the context so admits.

Words used herein which import one gender (whether masculine, feminine or neuter) shall be taken to include any other gender where the context so admits.

PERSONAL INFORMATION COLLECTION STATEMENT

COLLECTION OF YOUR PERSONAL DATA

OP collects your personal data to provide our services to you and to improve customer experience. Please note that it is mandatory for you to provide personal data marked with asterisks. In the event that you do not provide such personal data, we may not be able to provide you with certain information, materials and/or your requested services.

PURPOSES OF PERSONAL DATA COLLECTION AND USAGE

We will use your personal data for one or more of the following purposes:

for processing your service requests (i.e. event registration, ticket purchase, e-newsletter subscription, product purchase, WiFi usage, member registration, venue booking, donation etc.) with us and provide you with the services;

for facilitating communications between you and members of OP in respect of your service requests;

for personalising your experience of OP with programmes and activities that are most relevant to your interests;

for notifying you of changes to our services that may affect you;

for responding to and follow up on your enquiries;

for conducting statistical analysis, research, surveys, quality assurance and review; and

if you give your consent for direct marketing:

for communicating with you on events, services, promotions and special offers at OP and/or provided by OP that are most relevant to your interests;

for communicating with you for potential support to the OP that is relevant to your interests and appropriate; and

for other purposes directly relating to any of the above.

We will combine information you provide to us through various channels, such as online channels like websites / mobile applications, offline channels like physical application forms, or publicly available information about you. We use this combined information to help personalise your experience and communicate with you about events and offerings that may be of particular interest to you.

TRANSFER OF PERSONAL DATA

The personal data collected will be used only for purposes as stated above. We will never sell, rent or exchange your details with any other organisation outside OP. We will ask for your consent to share personal information with third parties. Some of our service providers will have access to your data in order to perform services on our behalf. We require all service providers to respect the security of your personal data and comply with the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong SAR) (“the Ordinance”). We do not allow our service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

TRANSFER OF PERSONAL DATA OUTSIDE HONG KONG

Please also note that your personal data transferred to us may or may not be located within Hong Kong, and your information may be subject to cross-border transfer to places outside Hong Kong for necessary handling, processing or storage.

PERSONAL DATA SECURITY AND RETENTION OF DATA

Please note that your personal data will not be kept longer than necessary in accordance with the Ordinance and that we will comply with all statutory and regulatory requirements in the Hong Kong SAR concerning the retention of personal data. The information you submit in filling the online application form will be encrypted when it is sent electronically to us. Your personal data stored will be accessed only by our employees or service providers who are authorised to do so.

LINKING WITH THIRD PARTIES

Please be aware that our site may contain links to other sites hosted by third parties. Different rules may apply to their collection, use, or disclosure of your personal information. We encourage you to review other websites’ policies before revealing any personally identifiable or sensitive information. We do not control, and are thus not responsible for, the content or privacy practices and policies of such other sites and under no circumstances shall we have any liability whatsoever for the activities conducted by or at any website accessed from or through OP’s website.

DATA ACCESS AND CORRECTION REQUESTS

You have the right to request access to and correction of your personal data held by OP. Such request should be made in writing to enquiry@osagepublications.com or by post to the address: Osage Publications, 4/F, 20 Hing Yip Street, Kwun Tong, Kowloon, Hong Kong.
Attn: Personal Data Privacy Department
(Marked Confidential)

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 intended use).

We may use your name, contact details (such as email address), preferences and interests, profile information, transaction data for providing you with information that are most relevant to your interests on events, services, promotions and special offers at OP and/or provided by OP, and ways to support OP. Please UNTICK THE BOX if you do not agree to such use.

If you do not wish to receive information from OP for the aforementioned direct marketing purposes, you may choose to opt-out from direct marketing at any time, free of charge, by emailing us at enquiry@osagepublications.com.

If you do not wish to receive information in particular relevant to fundraising activities (including promotion of donations or contributions for charitable or non-profit making events), you may choose to opt-out from fundraising activities at any time, free of charge, by emailing us at enquiry@osagepublications.com.