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Privacy Policy

Please read following carefully :

Privacy Policy

We at Sarjan Group, (“we” or “our” or “us”) want to make sure all the personal information we have collected about you, is safe and secure whether we collect it through our website at (“our site”) or from other sources. 
This Policy set outs our commitments to you, in compliance with and beyond the Personal Data (Privacy) Ordinance (commonly known as the PDPO) and explains how we collect, store and use your personal information.
We have not appointed a Data Protection Officer to oversee our compliance with data protection laws as we are not required to do so, but our Data Protection Compliance Team has overall responsibility for data protection compliance in our organisation.
 
We are committed to respecting your privacy. This is to explain how we may use personal information we collect before, during and after your or your organisation’s membership with us. This notice explains how we comply with the law on data protection, what your rights are and for the purposes of data protection we will be the controller of any of your personal information.
 

PERSONAL INFORMATION WE MAY COLLECT FROM YOU

When you sign up for membership with us, you may provide us with or we may obtain personal information about you, such as information regarding :
- Yours and your family’s personal contact details that allows us to contact you directly such as name, title, email addresses and telephone numbers, date of birth, gender, and relevant proofs in this regards.
- Personal Identification proofs including Identification cards issued by government authorities.
- Membership details including start and end date.
- Records of your interactions with us such as telephone conversations, emails and other correspondence and your instructions to us.
- Any payment details you provide so that we can receive payments from you and details of the financial transactions with you.
- Use of and movements through our online portal, passwords, personal identification numbers, IP addresses, user names and other IT system identifying information.
- CCTV footage and other information obtained through electronic means.
- Records of your attendance at any events or competitions hosted by us.
- Images in video and/or photographic form and voice recordings.
- Your marketing preferences so that we know whether and how we should contact you.

SPECIAL CATEGORIES OF PERSONAL INFORMATION

We may also collect, store and use the following “special categories” of more sensitive personal information regarding you like :
- your race or ethnicity and religious beliefs
- information about your health, including any medical condition, health and sickness records, medical records and health professional information
- biometric information about you, for example fingerprints, retina scans.
 
We may not collect all of the above types of special category personal information about you. In relation to the special category personal data that we do process we do so on the basis that the processing is necessary for reasons of substantial public interest, on a lawful basis it is necessary for the establishment, exercise or defence of legal claims; or it is necessary for.

In the table below, we refer to these as the “special category reasons for processing of your personal data”. 

Criminal Records

We may also collect criminal records information from you. It is unlikely that we will collect criminal records information from you in the normal course of your membership and if it does become necessary, we will bring it to your attention. For criminal records history, we process it on the basis of legal obligations or based on your explicit consent.

 
USES MADE OF THE INFORMATION

The table below describes the main purposes for which we process your personal information, the categories of your information involved and our lawful basis for being able to do this.

Purpose

Personal information used

Lawful basis

All Members

 

 

To administer any membership account(s) you have with us and managing our relationship with you, [including arranging for any insurance] and dealing with payments and any support, service or product enquiries made by you
 

All contact and membership details, transaction and payment information, records of your interactions with us, and marketing preferences.
 

This is necessary to enable us to properly manage and administer your membership contract with us.
 

To arrange and manage any contracts for the provision of any merchandise, products and/or services.
 

All contact and membership details. Transaction and payment information.
 

This is necessary to enable us to properly administer and perform any contract for the provision of [merchandise/products/services].
 

To send you information which is included within your membership benefits package, including newsletters, details about advanced ticket information, events and partner offers
 

All contact and membership details
 

This is necessary to enable us to properly manage and administer your membership contract with us.
 

To send you other marketing information we think you might find useful or which you have requested from us, including our newsletters, information about Membership, events, participation products and information about our commercial partners
 

All contact and membership details and marketing preferences
 

Where you have given us your explicit consent to do so.
 

To answer your queries or complaints

Contact details and records of your interactions with us
 

We have a legitimate interest to provide complaint handling services to you in case there are any issues with your membership.
 

Retention of records
 

All the personal information we collect
 

We have a legitimate interest in retaining records whilst they may be required in relation to complaints or claims. We need to retain records in order to properly administer and manage your membership and in some cases, we may have legal or regulatory obligations to retain records. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above For criminal records history we process it on the basis of legal obligations or based on your explicit consent.
 

The security of our IT systems
 

Your usage of our IT systems and online portals.
 

We have a legitimate interest to ensure that our IT systems are secure.
 

To conduct data analytics studies to better understand event attendance and trends within the sport
 

Records of your attendance at any events or courses
 

We have a legitimate interest in doing so to ensure that our membership is targeted and relevant.
 

For the purposes of promoting our events and membership packages
 

Images in video and/or photographic form.
 

Where you have given us your explicit consent to do so.
 

To comply with health and safety requirements
 

Records of attendance
 

We have a legal obligation and a legitimate interest to provide you and other members of our organisation with a safe environment in which to participate in our events.
 

To use information about your physical or mental health (including any injuries) or disability status, to ensure your health and safety and to assess your fitness to participate, to provide appropriate adjustments to our events and courses
 

Health and medical information
 

We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above
 

For the purposes of equal opportunities monitoring
 

Name, title, date of birth, gender, information about your race or ethnicity, health and medical information
 

We have a legitimate interest to promote a sports environment that is inclusive, fair and accessible. We process special category personal data on the basis of the “special category reasons for processing of your personal data” referred to in section 2 above
 

 
For some of your personal information you will have a legal, contractual or other requirement or obligation for you to provide us with your personal information. If you do not provide us with the requested personal information we may not be able to admit you as a member or we may not be able to properly perform our contract with you or comply with legal obligations and we may have to terminate your position as a member. For other personal information you may not be under an obligation to provide it to us, but if you do not provide it then we may not be able to properly perform our contract with you. Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in the "Contacting us" section below. Please note however that the withdrawal of your consent will not affect any use of the data made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide  member benefits to you.
 

DIRECT MARKETING

Email, post and SMS marketing: from time to time, we may contact you by email, post or SMS with information about products and services we believe you may be interested in.
 

DISCLOSURE OF YOUR PERSONAL INFORMATION

- Any party approved by you.
- Other service providers: for example, email marketing specialists, payment processors, data analysis CCTV contractors, promotional advisors, contractors or suppliers and IT services (including CRM, website, video- and teleconference services);
- Our supply chain partners & sub-contractors, such as couriers, import/export agents, shippers,
- Our Commercial Partners, Sponsors and associates.
- The Government or our regulators: where we are required to do so by law or to assist with their investigations or initiatives.
- Police, law enforcement and security services: to assist with the investigation and prevention of crime and the protection of national security. We do not disclose personal information to anyone else except as set out above.
 

HOW LONG DO WE KEEP PERSONAL INFORMATION FOR?

The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long-term basis: for example, personal information that we need to retain for legal purposes will normally be retained in accordance with usual commercial practice and regulatory requirements. Generally, where there is no legal requirement we retain all physical and electronic records for a period of 6 years after your last contact with us. Exceptions to this rule are: o Information that may be relevant to personal injury claims, or discrimination claims may be retained until the limitation period for those types of claims has expired. For personal injury or discrimination claims this can be an extended period as the limitation period might not start to run until a long time after you have worked for us. It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your phone number or email address.

 
CONTACTING US

In the event of any query or complaint in connection with the information we hold about you, please email ilovesarjan@gmail.com

 
 
LINKING WITH THIRD PARTY SITES

Our Site may, from time to time, contain links to and from the websites of our commercial partners, other regional bodies, advertisers, volunteering platform and clubs. If you follow a link to any of these websites, please note that these websites have their own privacy policies and they will be a data controller of your personal information. We do not accept any responsibility or liability for these policies and you should check these policies before you submit any personal information to these websites.
In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.

 
SECURITY

We employ a variety of technical and organisational measures to keep your personal information safe and to prevent unauthorised access to, or use, or disclosure of it. Unfortunately, no information transmission over the Internet is guaranteed 100% secure nor is any storage of information always 100% secure, but we do take all appropriate steps to protect the security of your personal information.

 
To learn more about The Personal Data (Privacy) Ordinance please visit Hong Kong Government website
https://www.pcpd.org.hk/english/data_privacy_law/ordinance_at_a_Glance/ordinance.html