Privacy Policy
Last updated: 9 April 2024
1. Data Protection Principles
Hong Kong Watch is committed to processing data in accordance with its responsibilities under the EU General Data Protection Regulations (“GDPR”) and the following six data protection principles are followed at all times.
Article 5 of the GDPR requires that personal data shall be:
processed lawfully, fairly and in a transparent manner in relation to individuals;
collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;
adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
accurate and, where necessary, kept up to date; every reasonable step must be taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay;
kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes subject to implementation of the appropriate technical and organisational measures required by the GDPR in order to safeguard the rights and freedoms of individuals; and
processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.”
2. Personnel
Data Protection Officer
In the considered opinion of the Trustees the scope and nature of the personal data held by Hong Kong Watch is not sufficient to warrant the appointment of a Data Protection Officer. Accordingly, no Data Protection Officer is appointed.
Data Controller
The Board of Trustees is the Data Controller for Hong Kong Watch.
Data Processor
The Board of Trustees will appoint at least 2 and not more than 5 of its number, or other appropriate persons, to be the Data Processors for the Hong Kong Watch.
Access to Data
Except where necessary to pursue the legitimate purposes of Hong Kong Watch, only the Data Processors shall have access to the personal data held by Hong Kong Watch.
Training
The Board of Trustees and Data Processors will periodically undergo appropriate training commensurate with the scale and nature of the personal data that the Charity holds and processes under the GDPR.
3. Collecting your Personal Data
We collect personal information in two ways from your use of the Website:
anonymous data that is automatically collected from all visitors to the Website
personal data that you voluntarily submit so that we can provide you with a service or so that you can make a donation, join as subscribers or join our events.
The type and amount of personal information we collect depends on how you use the Website.
ANONYMOUS DATA
You can access all pages on our website without telling us who you are and without revealing any personal information.
WEBSITE ANALYTICS
We collect some information when you visit the website but this does not allow us to identify you personally. The information we collect includes the type of browser visitors use, time and date of visits, which pages are most viewed and which other websites and search engines direct visitors to the Hong Kong Watch website. This enables us to evaluate the website and work to improve it.
This website collects personal data to power our Squarespace analytics, including:
Information about your browser, network, and device
Web pages you visited prior to coming to this website
Your IP address
This information may also include details about your use of this website, including:
Clicks
Internal links
Pages visited
Scrolling
Searches
Timestamps
We share this information with Squarespace, our website analytics provider, to learn about site traffic and activity.
We do not link any of this anonymous data with any personal information that you may provide to us.
COOKIES
This website uses cookies and similar technologies, which are small files or pieces of text that download to a device when a visitor accesses a website or app. For information about viewing the cookies dropped on your device, visit The cookies Squarespace uses.
These functional and required cookies are always used, which allow Squarespace, our hosting platform, to securely serve this website to you.
These analytics and performance cookies are used on this site, as described below, only when you acknowledge our cookie banner. We use analytics cookies to view site traffic, activity, and other data.
PERSONAL DATA (INCLUDING SENSITIVE PERSONAL DATA) THAT YOU VOLUNTEER TO US DIRECTLY
We may collect information directly from you which personally identifies you (such as your name, address or email) when you participate in the following activities:
contacting us, for example by email, post or through our online contact forms
subscribing to an email list to receive more information about our work and how you can get involved or donate
attending an event
joining as a Hong Kong Watch subscriber
donating to Hong Kong Watch
In addition, we may collect financial information from you when you:
join or renew your Hong Kong Watch subscription
make a donation to support Hong Kong Watch
4. Legal Basis For Using Your Data
We collect your financial data for the purpose of fulfilling our contractual duties to you or to others – i.e. when we need this data to process your donation.
Where we have no contractual basis for retaining financial data (i.e. when transactions have been processed) we retain only that financial data which is required either to:
satisfy our obligations to maintain accurate financial and tax records, or
satisfy our legitimate interest in supporting future fundraising. This will include retaining information on the date of the donation, the amount donated and your personal data on our fundraising database.
If you make a donation to Hong Kong Watch, we rely on our legitimate interest in providing you with information about what your donation will help to fund as the legal basis for sharing information about Hong Kong Watch’s work and services with you by email only.
If you have not made a donation to Hong Kong Watch – but have given us your personal data for another purpose – we will seek your opt-in consent for all email communication after a confirmation of your initial interaction.
You have the right to withdraw your consent to these activities. You can do so at any time by contacting us at info@hongkongwatch.org.
We do not think that any of the above activities prejudice you in any way. However, you have the right to object to us processing your personal data on this basis. You can do so by contacting us at info@hongkongwatch.org.
5. Use of Your Data
If you are making a donation or signing up to an event, we will process your data in order to satisfy this specific action.
If you make a donation or joining as Hong Kong Watch subscribers, we may contact you by email to give you further information about ways in which you can support Hong Kong Watch.
For all other actions, if you give opt-in consent, we may contact you by email to give you further information about Hong Kong Watch’s work and ways in which you can support us.
6. Third Party Access to Data
We do not disclose your personal data to anyone outside Hong Kong Watch except:
where we have your permission
to other organisations who provide a service to us or you (such as payment processing companies), or
where we are required to do so by law.
7. Financial Data – Processing of Your Personal Data by Third Party Payment Providers
When making a one-off online donation, joining or renewing a Hong Kong Watch subscription directly on our website, your payment details are processed by Donorbox and Stripe. The privacy policy of Donorbox can be found here and this is the link to the Stripe privacy policy. You also have the option for your online donation to be processed by PayPal. You can read PayPal’s privacy policy here.
When you make a payment, we ask for your name but you have the option to make your donation anonymous. We also need an address, email address and credit or debit card information. This information is used to process your payment and to verify credit or debit card data.
Your credit or debit card details will only be retained by Donorbox and Stripe, or PayPal. These details are not retained by Hong Kong Watch, although in the case of a suspected fraudulent transaction, card details may be disclosed to us for the sole purpose of performing further checks.
The other data provided (name, address, email address, and whether you opt in to receiving correspondence from Hong Kong Watch) is retained by Hong Kong Watch for the purpose of managing our communication and fundraising function.
We also accept donations through a variety of payroll giving providers (e.g. Charities Aid Foundation, Benevity) and other fundraising platforms (e.g. PayPal Giving Fund, JustGiving and Enthuse).
If you give to Hong Kong Watch through these third parties, they will provide you with their own privacy notices. We will normally receive your name, address, donation amount and date of the donation, and make use of this data in the manner described in this policy.
8. Data Processing and Storage
Your personal data will be kept by Hong Kong Watch in a secure environment.
We care about protecting your information, which is why we put in place appropriate measures designed to prevent unauthorised access to, and misuse of, your personal data.
We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access.
The scale and nature of the personal data held by Hong Kong Watch is not sufficient to justify the Hong Kong Watch purchasing dedicated computers for the processing of personal data.
Instead Hong Kong Watch will purchase and own at least 2 and not more than 5 removable storage devices to store the personal data that it holds and processes.
The removable storage devices will also act as backup devices.
Whilst the data will be processed on the computers/laptops to which the Data Processors have access, no personal data covered by the GDPR will be stored on those computers/laptops.
All interim working data transferred to such computers/laptops for processing will be deleted once processing has been completed.
When not in use the removable storage devices will be kept in a secure location and reasonably protected against accidental damage, loss, avoidable theft or other misuse by persons other than the Data Processors.
The Data Controller & Data Processors will keep a register of
the location of all removable devices used for the storage and processing of personal data;
each occasion when the data on each device were accessed or modified and by whom.
Hong Kong Watch’s removable storage devices shall not be used for the storage of any data which are unrelated to the Hong Kong Watch’s processing of personal data.
9. Duration of Storage
We will not keep your personal information for longer than is necessary for the purposes for which we collect it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority).
When it is no longer necessary to retain your data, we will delete the personal information that we hold about you from our systems.
10. Your Rights And How To Contact Us
As noted above, you have the right to withdraw consent or object to our processing of your data. You also have the right to seek information on which of your personal information we hold and you can, in certain circumstances, implement your rights to erasure, rectification or restriction of our processing.
Find about more about your rights here.
If you have comments, questions or requests regarding the processing of your personal data, please contact info@hongkongwatch.org or write to us at Hong Kong Watch, Office 7, 35-37 Ludgate Hill, London, EC4M 7JN.
11. Data Breach
In the event of any data breach coming to the attention of the Data Controller the Trustees will immediately notify the Information Commission’s Office.
In the event that full details of the nature and consequences of the data breach are not immediately accessible (e.g.: because Data Processors do not work on every normal weekday) the Trustees will bring that to the attention of the Information Commissioner’s Office and undertake to forward the relevant information as soon as it becomes available.