A-TEAM EDVENTURES LIMITED and its operating divisions (“ATE”)
We take data privacy seriously and are very conscious of and respect your privacy. Accordingly, we follow relevant best practices and applicable legal requirements. Your personal data is only used in accordance with our Data Policy set out below. By joining a programme or proceeding to use our recreational services, becoming our Club member, or otherwise dealing with ATE, you thereby accept it and agree it will apply.
1. Security – Data we collect is kept secure, under strict access controls. We require those persons handling such data, (including staff and third party contractors) to only use it for the specific, agreed purposes. We require them to meet strict duties of confidentiality and strictly to comply with this Policy and applicable laws. We treat data security seriously.
2. Reasons for needing your data – we need such data to effectively operate the schools and other programmes and our recreational, club and other services offered (including kayak, surfing and other outdoor pursuits and instruction). It is particularly needed for programme planning, delivery and safety purposes (eg medical, health, parent contact details and other information for proper risk management and safety/emergencies). It is also used to provide participants (and parents) communications, updates and special offers.
Failure to provide us such data will mean we cannot operate such programmes and/or provide such services.
3. Purposes for which your personal data may be used will vary, (depending on the Progaramme or recreational services being provided) and will include the following:
• to plan, manage and operate and provide a safer and better informed delivery of school and other programmes and recreational services
• to contact and keep in touch with participants (and parents) to promote events, promotions and other benefits.
• to build, operate, update, maintain and improve/refine our databases
• to respond to any enquiry, order, booking or other request received from your email
• to meet our obligations to or under any legal or governmental body or requirement
• other related purposes, from time to time featured on our website (www:ateamedventures.com)
We don’t sell (or otherwise earn a return from sharing) your data.
4. Opt out – Anyone no longer wishing to be included in our database, may (at no cost) request removal of their details (by writing to the address below or email request to info@ ateamedventures.com). Such requests are processed fast, as ATE strives to avoid sending unwanted communications. We actively work against spamming.
5. We may transfer your personal data to:
• school, emergency, medical, police and other relevant authorities, in case of medical need or emergency
• different divisions of the ATE Group and subsidiaries and affiliates (but only for so long as it remains an ATE Group member)
• our selected service providers (eg. For programme delivery, database management and e-mail circulation, accounting, operational, administrative and similar functions, but only essential data required for provision of that service/function). All such providers are carefully preselected, made subject to strict confidentiality requirements and are required to uphold our Data Policy and the law
• any legal, regulatory or governmental body or pursuant to any of their requirements that apply to us
• any prospective acquirer, successor, transferee of or participant in relation to all or part of our business
• a supplier (or other person) for fulfillment of a booking/order/etc made (eg. For travel or accommodation)
• any other body or person who is under legally binding duties of confidentiality
Unless you have provided specific written consent, we won’t transfer your personal data to third parties for marketing purposes
6. We pledge to safeguard your personal data and ensure it is maintained confidentially and under high standards of security. In doing this we will require compliance by our staff, our contractors and other relevant persons with these standards.
7. Your duties For your part, please do remember you need to:
• (for recreational service users only) promptly update us of changes in your contact details, to enable prompt updating of our records
• safeguard against unauthorized or other mis-use of your email services and
• act reasonably at and meet applicable conditions and requirements we set for activities, events and other ATE activities and for programmes.
8. We retain your personal data only for as long as the purpose for its collection continues. For Programmes, participant records are used for programme planning and during delivery and within 90 days thereafter all versions and copies are deleted, save one hard copy can be retained, but strictly for record purposes (in case of any future claim or liability issue) for a period of 3 years, or until the end or the relevant limitation period, if longer.
For recreational users, we will remove your relevant data after realising it is no longer current (eg. receipts of “Unknown recipient” autogenerated email replies) or promptly after cessation of any ATE membership, or promptly upon receipt of your “Unsubscribe” request.
10. Policy review We keep this (and our other) policies under review. Changes when made, will appear on our website and be notified by e-mail or other alert. This policy does not reduce or limit your rights under the applicable Hong Kong law.
11. Data access, correction, etc. rights – You have the right to request:
• if we hold data about you, and (on payment of a reasonable fee) to receive a copy
• a data correction
• to be informed of the kind of data we hold and of our data policies and practices
Such requests should be made in writing to our Data Protection Officer, (at the address below).
We hope you find our Data Policy to be clear and fair, but please contact our Data Protection Officer (at the address below) if you have questions.