Personal Information Processing Rules

Please read and understand the Personal Information Processing Rules (‘the Processing Rules’) carefully before completing this survey. If you provide answers to any survey question below, it means that you fully understand the Processing Rules and agree that Datality Lab Limited (‘the Company’) and The Hong Kong Jockey Club (‘the Club’) (collectively, “we”, “us” or “our”) will collect, store, use, process, transmit, provide, and/or delete your personal information in accordance with the Processing Rules. If you do not agree to any part of the Processing Rules, please do not proceed with this survey.

1. Why and how we collect and use your personal information

1.1 In order to understand your needs, preferences and future expectations towards the facilities and services [provided by the Club and/or its subsidiaries], we will be collecting [your opinions in relation to] to your lifestyle, personal values & attitudes, perceptions & experience with current offerings in [the Club and/or its subsidiaries] and expectations towards [their] future offerings.

1.2 [We will also collect the first four digits of your membership ID at Beijing Hong Kong Jockey Club Clubhouse (‘BJCH’) in order to separate your survey responses from survey responses provided by other BJCH members.]

1.3 [We will not procure further information about you that will lead to exposure of your personal identity other than those described in this Section 1].

1.4 We will collect your responses via Tencent Survey (“騰訊問卷”) developed by Shenzhen Tencent Computer System Co., Ltd. (深圳市腾讯计算机系统有限公司) which is a third-party data collection platform hosted on the internet. Data collected via this platform is subject to the data Privacy Policy, Tencent Service Agreement and other terms and conditions published by Tencent Survey via its website at (“Tencent T&C”). Please read the Tencent T&C carefully and ensure you understand and agree with all the details. While we make our best effort to protect the personal information you provide to us, we cannot assume responsibility for any breach of the Tencent T&C by Tencent Survey. You agree that the Company, the Club and its subsidiaries shall not be liable for any loss or damage arising from any breach of the Tencent T&C by Tencent Survey. In case there are any inconsistencies between this Processing Rules and the Tencent T&C in relation to the personal information processing activities among you, the Club and the Company, the terms and conditions in this Processing Rules will prevail.

2. How we share, transfer, and publicly disclose your personal information

2.1 Share

We may share your personal information with the Club’s subsidiaries to facilitate provision of services to you, including Beijing Hong Kong Jockey Club Clubhouse Limited (北京香港马会会所有限公司) for delivering to you the gift for responding to the survey. However, we will only share your personal information for purposes that are legitimate, proper, necessary, specific and clear and only to the extent necessary. The above-mentioned subsidiaries of the Club may be entities within or outside of the PRC.

Prior to sharing your personal information with the Club’s subsidiaries, the Company and/or the Club will enter into appropriate data processing agreements with them, requiring them to handle your personal information in accordance with relevant confidentiality and security measures.

2.2 Transfer

We will not transfer your personal information to any company, organization or individual, except in the following cases:

2.2.1 With your explicit consent;

2.2.2 In the event of a merger, division, liquidation or bankruptcy, we will require the new company or organisation that will obtain your personal information to remain bound by the Processing Rules or to otherwise obtain your consent separately.

2.3 Public disclosure

We will only publicly disclose your personal information under the following circumstances:

2.3.1 With your explicit consent;

2.3.2 As required by law: we may publicly disclose your personal information when required by law, legal procedures, litigation, or compulsory government authorities.

3. How we protect your personal information

3.1 We are committed to protecting the security of personal information. We will use a variety of physical, technological and organisational measures to help protect your personal information from unauthorised or accidental access, processing, deletion or other use. We also ensure that our employees receive appropriate training in relation to the protection of personal information.

3.2 The transmission of information via the internet or mobile network is not completely secure. The security measures described above do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not guarantee that our servers or network will be immune from such attacks. Although we will implement security measures to protect your personal information, we cannot guarantee security of the data transmitted via internet or mobile network. You agree that the Company and the Club shall not be liable for any loss or damage arising from risks relating to any transmission.

3.3 In order to respond to data security incidents, we will comply with reporting and notification obligations required by laws and regulations, the scope of the notification may include: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, remedial measures for you, etc. Meanwhile, we will also proactively report the handling of data security incidents in accordance with the requirements of the regulatory authorities.

4. Your rights

4.1 Access, reproduce, rectify, and delete your personal information

You have the right to access, reproduce, rectify, and delete your personal information, subject to the exceptions provided by laws and regulations. You also have the right to request the transmission of personal information, provided that it complies with the law. To exercise the aforesaid rights or require us to provide an explanation, please contact us via the contact information set out in Article 7 of the Processing Rules.

4.2 Withdraw consent and change the scope of consent

4.2.1 We collect and process your personal information on the basis of your consent. You can withdraw your consent at any time by contacting us via the contact information set out in Article 7 of the Rules below, whereupon you should specify the consent you would like to withdraw. Unless otherwise permitted by law, upon withdrawal of your consent, we will no longer process your personal information. This decision will not affect the survey responses processing activities conducted based on your authorisation before such withdrawal.

4.2.2 By contacting us via the contact information set out in Article 7 below, you may change the scope in your consent with respect to the collection and use of the personal information you provide.

5. Retention of personal information

For the purposes of collection as set out herein and for the performance of the Company’s obligations under the relevant contracts, laws and regulations, all personal information collected from you by us shall only be stored for a reasonable period of time, specifically:

5.1 Your personal information collected for the purposes stated in Article 1.1 and Article 1.2 above shall be stored for a period of up to [30 days from the date of completion of survey reporting unless a longer time is required by applicable laws and regulations].

6. Cross-border transmission

6.1 [As the Company and the Club, both of which are legal entities in the Hong Kong SAR, will download your survey responses from Tencent Survey, there will be a cross-border transmission of your personal information]. The Company and the Club will take all steps reasonably necessary to ensure that your personal information is handled securely and in accordance with the Processing Rules and applicable laws.

6.2 If cross-border transmission will be made beyond the scope as stipulated herein, we will obtain separate authorisation from you and fulfil the conditions precedent for cross-border transmission as required by relevant laws and regulations on personal data protection.

7. How to contact us

If you have any questions, concerns or suggestions regarding the Processing Rules, you may contact our Data Privacy Compliance Officer. You may direct your request in writing to:

Datality Lab Limited

Data Privacy Compliance Office

5/F The Quayside, 77 Hoi Bun Road, Kwun Tong, Hong Kong SAR


8. Interpretation

This Processing Rule is written in Chinese and may be translated into English and other languages. The Chinese version shall have the same legal validity as other translated versions. In the event of any inconsistency between the Chinese version and the translated versions of this Processing Rule, the Chinese version shall prevail.


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