Uplifters

Uplifters Limited and Uplifters Singapore Limited (collectively “Uplifters”) treat the protection of privacy in relation to personal data very seriously. All personal data collected by Uplifters shall be treated with respect and we are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and the Personal Data Protection Act 2012 of Singapore (as applicable) (“PDPA”). We may from time to time update this policy (“Privacy Policy”) and all information will be governed by our most recent Privacy Policy as available on our website.

By using or accessing the Website, signing up for any products and services offered by us, or by interacting with us in any manner (including as a client, service provider, donor, volunteer or employee), you acknowledge that you accept the practices and policies in this Privacy Policy and agree and consent to Uplifters, as well as our respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your personal data, and disclosing such personal data to Uplifters’ authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. 

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your personal data, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use or disclose your personal data. Further, this policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your personal data.

Remember that your use of the Website and services provided by Uplifters is at all times subject to the Terms, which incorporates this Privacy Policy. Any terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

Collection of Personal Data

From time to time, it is necessary for data subjects to supply Uplifters with personal data in connection with: 

• the use of the Website; 
• registration, enrolment in a course and establishment of a user account, or the use or continuation of provision of educational services, products and facilities;
• our relationship with you as your current, future or former employer or volunteer organisation; or 
• your provision of services to us (or your position as a representative of a company which provides services to us). 

Failure to supply such personal data may result in Uplifters being unable to: 

• register or enrol you in our courses, or establish a user account for you;
• commence or continue the provision of educational services, products and facilities to you; or 
• employ you or permit you to continue volunteering with us.

You may voluntarily choose to share additional personal data on the Uplifters’ website/online learning platform including through chatbots and on Uplifters’ social media on third-party platforms, for example:

• In your Uplifters’ account profile;
• When participating in a course, forum or other interactive experience on the Uplifters’ website and Uplifters’ chatbots or pages on social media platforms such as Facebook;
• In the course of applying for a job or volunteering role with us.

Types of Personal Data Collected

Uplifters directly collects personal data relating to members of the public who use Uplifters’ services or the Website or donate to Uplifters when you:

• Sign up for an Uplifters course (on your own behalf or on behalf of another individual) and create an Uplifters user profile;
• Enrol and participate in Uplifters’ online courses;
• Purchase a product or service on your own behalf or on behalf of another individual;
• Send email messages, chatbot or Facebook chat messages to Uplifters (including messages to learner support);
• Participate in public forums and other interactive experiences on the Uplifters website/online learning platform and social media platforms or in person;
• Donate to Uplifters;
• Make an enquiry, complaint or data access or correction request.

“Personal Data” is defined in the Hong Kong Personal Data (Privacy) Ordinance as data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable; and is defined in the PDPA as any data, whether true or not, about an individual who can be identified (a) from that data or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time. Examples of personal data you may provide to us include (depending on the nature of your interaction with us) full name, personal details, such as identification or passport number, nationality, age, date of birth, gender, marital status and number of children, contact details including telephone numbers, email and residential address, payment details such as credit card information or bank account details, employment details (including income) and history, other personal information such as financial habits and situation, plans for the future and well-being level.

We will always try to collect your personal data directly from you. However, there may be instances where we will need to collect your information from other persons or entities, including, for example, if your employer registers you for an Uplifters course. Where we obtain your information from a third party, such as your employer, we may ask them to provide you with a copy of this Privacy Policy to ensure you know we are processing your information and the reasons why.

If you provide us with any personal data relating to a third party (e.g. information on your spouse, children, parents, and/or employees), you represent and warrant to us that the collection, use and/or disclosure of that personal data to us, as well as the further processing of that personal data by us for the purposes set out herein, is lawful, and you have obtained the consent of the third party to provide us with their personal data for the respective purposes.

We may collect personal data relating to our employees, officers, volunteers including personal particulars, Hong Kong or Singapore identification card number, passport number, education and qualifications, employment history, salary and allowances, bank account details, job applications, terms and conditions of service, rank and post, training records, appraisal reports, promotion board assessments, conduct and discipline, awards, benefits, medical records, leave, retirement and pension, professional qualifications, Mandatory Provident Fund and provident fund account details.

We may collect personal data relating to or in connection with your provision of services to us or your position as a representative of a provider of services to us including full name and contact details.

Uplifters also indirectly collects usage information about your visit to the Uplifters website and use of the e-learning platform as described in the ‘Cookies and Tracking Technologies’ section below.

Cookies and Tracking Technologies

We collect non-specific information on visitors’ and registered users’ activities on the Website by third-party web beacons and cookies from vendors including Google, via means of web analytics tools such as Google Analytics on most parts of the Website, which may include information such as where the visitor or registered user has come from (e.g. referring domains, search engines, marketing campaigns), the type of browser or operating system used to access the Website, pages viewed, date and time of access, the site path of the visitor, what content visitors are clicking on, which courses visitors are interested in and sign up for/participate in. You can find out more about Google Analytics (http://www.google.com/analytics/) on its website. We do not collect any personal data (e.g. name, address, email address) using the web analytics but we do collect IP addresses. Uplifters does not link any web analytics information to an individual. Uplifters uses this information to ensure that the Website is providing the best possible user experience and providing relevant services. Most web browsers automatically accept cookies but you can disable this function by changing your browser settings if you wish. However, if you do so you may not be able to take full advantage of the Website.

Uplifters may track and collect information from emails that we send you, for example, whether you opened the email or clicked on any links in the email.

We may share overall visitor trends and other generic information collected on the Website with third parties but we will not disclose any personal details or personally identifiable information without your consent.

The Website may contain links to websites operated by third parties. We have no control over the content of the linked websites or how the operators of those websites deal with your personal data. We encourage you to review the privacy policies applicable to those third-party websites to understand how your personal data may be used by those third-party websites.

Purposes for which your Personal Data may be Collected, Used and Disclosed

Uplifters generally collects, uses and disclosures your personal data for the following purposes, to:

• Operate and improve the Website – including creating and improving features that support the Uplifters’ community and enable Website use at scale. This also includes personalising the Website, so your learning experience is tailored to your interests and needs;
• Create, administer, provide and teach courses – including creating and improving the delivery of online courses and programmes on the Website. This also includes personalising courses, so your learning experience is tailored to your interests and needs, and assessing your attendance/performance and awarding certificates;
• Offer and improve products and services – including enabling you to navigate the Website, to enrol and participate in courses and programmes on the Website, to learn effectively on such courses and programmes, and to purchase or obtain products and services on the Website, as applicable;
• Develop and maintain the security of the Website – including tracking Website outages and creating software solutions, detecting contraventions of the Terms of Service, and monitoring uses, misuses, and potential misuses of the Website;
• Communicate with you – including answering your course/programme and Website questions, notifying you of courses/programmes and Website/e-learning platform technical issues;
• Conduct or research studies for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services, or issue invitations for participation in programmes/activities;

• If you are an existing or prospective participant of our courses, events, services and/or programmes or you have submitted any applications to us – assessment of applications, assessment of qualifications, issue of certificates, monitoring of your progress, processing of applications for reimbursement of fees, assessment of nominations, dissemination of awards and verification of assessments;

• If you are a prospective employee or volunteer – Perform a range of employment-related and volunteer-related purposes, such as appointments, integrity checking, background checks, postings and transfers, offer/renewal/extension of agreements, monitoring of your progress, tracking the duration you have volunteered or worked for, training and career development, revision of terms or conditions of service, promotion, conduct and discipline, legal assistance, benefits, continuation in or removal from office;
• In respect of donations – Collect, process and administer donations;
• Enable us to operate our services efficiently and sustainably;
• If required by applicable law, comply with a competent authority’s directions or an order by the courts; and
• Recruit, administer and service various schemes, and deal with complaints and enquiries or requests for personal data and information.

Disclosure of Personal Data

We will take reasonable steps to protect your personal data against unauthorised disclosure.  Subject to the provisions of applicable law, your personal data may be disclosed by us, for the purposes listed herein (where applicable), to the following entities or parties, whether they are located in Hong Kong, Singapore or elsewhere:

• any Group Company;[1]
• third parties appointed by us and/or any Group Company to provide services to, or on behalf of, us and/or any Group Company (including payroll and payment providers, insurers, bankers, telecommunication and information technology companies, contractors, trainers, travel agents, corporate secretarial providers, couriers, security services and medical practitioners);
• existing or prospective partners or collaborators (including speakers, tutors, lecturers and volunteers) in our courses, events and programmes;
• external banks, credit card companies and their respective service providers;
• auditors, lawyers and other professional advisors of us and/or any Group Company;
• relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
• education or training institutions and examination bodies; and/or
• any other party whom you authorise us to disclose your personal data to.

Direct Marketing (applicable only if you have agreed to receive marketing content)

Uplifters requires consent (which can include an indication of non-objection) in order for us to use your personal data for direct marketing, including name, contact details, nationality, occupation, gender, health and family status to provide you with marketing communications relating to personal development services, member activities, donations and contributions for charitable and/or non-profit-making purposes (including by email, SMS, chatbot or other instant messengers on social media). Such consent if given can subsequently be withdrawn without charge by emailing our Data Protection Officer at [email protected].

We will not sell your personal data to anyone. We require your consent before providing any of your personal data to the community or educational partners for their direct marketing. Such consent if given can subsequently be withdrawn without charge by emailing our Data Protection Officer at [email protected].

Storage of Personal Data and Security

All personal data collected is stored securely to prevent any unauthorized or accidental access, disclosure, processing or erasure. Uplifters implements appropriate physical, electronic and managerial measures to safeguard and secure personal data including password protection and limiting physical access.

Uplifters takes all practicable steps to ensure that personal data is not kept longer than necessary and in compliance with applicable statutory requirements relating to the retention of personal data.

Even though we take steps to secure your personal data, you should be aware that no system is impenetrable and no information provided over the Internet is totally secure. Accordingly, we cannot and do not guarantee the security of information that you transmit or receive over the Internet. You should not send us any credit or debit card numbers or comparable confidential details via email – such details should only be provided via a secured payment gateway.

You should take precautions not to share, provide or facilitate unauthorised use of your Uplifters account profile and/or username and/or password. If in the unlikely event unauthorised access or transactions have been discovered, you should notify Uplifters immediately.

Data Access, Correction and Withdrawal Requests  

Data access, correction or withdrawal requests must be made in writing by email. Requests should be addressed to our Data Protection Officer at [email protected].

Uplifters may require you to provide identity proof such as your Hong Kong Identity Card, Singapore NRIC or other identification document (as applicable) and impose a reasonable charge to cover the costs of processing the data access request.  We will provide you with a written estimate of the fee for a data access request and inform you in writing if there is any increase to the fee.  We will not charge you for the correction of personal data or the withdrawal of consent.  If we are unable to comply with an access or correction request within 30 days of your request, we will within that time inform you in writing of the time by which we will respond.

You may withdraw your consent given for any or all purposes set out in this Privacy Policy by contacting our Data Protection Officer in writing. If you withdraw your consent to any or all use of your personal data, depending on the nature of your request, we may not be in a position to administer any contractual relationship in place or to provide products or services to you, which in turn may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings.  Our legal rights and remedies in such event are expressly reserved.

Accuracy of Personal Data

You should ensure that all personal data submitted to us is complete, accurate, true and correct. If there is a change to your personal particulars such as your residential/mailing address, email address or telephone number, please promptly update us. This ensures that you will continue to receive communications from us without disruption or delay. Failure on your part to do so may result in our inability to provide you with the products and services you have requested, or processing any requests and applications you may have made to us.

Enquiries

Any enquiries regarding personal data policies and practices should be addressed to our Data Protection Officer at [email protected].

Marie Kretz Di Meglio

Uplifters CEO