Privacy Policy
for EU Users.

PRIVACY STUFF FOR CONTINENTALS.

GGHK Limited (“GGHK”, “we”, “us” or “our”) is committed to protecting and respecting the privacy of those viewing or using our website www.gghk2022.com (“Website”) and using our applications or APIs (collectively, the “Apps”). The protection of your personal information is very important to us, and we understand our responsibilities to handle your personal information with care, to keep it secure and to comply with legal requirements.

If you visit, interact with us, or use our Website or our Apps through any channel, register to attend our events or programmes, download our applications, enter lucky draws or competitions, or sign up for our e-newsletter, we may collect and process certain personal information about you. The processing of your personal information, including personal data, complies with applicable data protection laws, including the EU General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”).

The purpose of this privacy policy (“Policy”) is to provide a clear explanation of when, why and how we collect and use your personal information. We have written this to be as user friendly as possible, and have labelled sections to make it easy for you to find the information that may be most relevant to you and to allow you to click on a topic to find out more. This Policy should be read together with our Cookies Policy.

Please read this Policy carefully. This Policy is intended to articulate the types of personal data  we may collect, what your data may be used for, what the legal bases for those collections and uses are, and how we protect it. This Policy is not intended to override the terms of any contract that you may have with us (for example, the terms and conditions you agreed if you intend to attend one of our events or programmes) or any rights you might have under data protection laws applicable to you.

We may make changes to this Policy from time to time to keep it up to date or to comply with legal requirements or changes in the way we operate our business. We will notify you about significant changes through our Website. We encourage you to regularly check and review this Policy so that you will always know what information we collect, how we use it, and who we share it with.

This Policy is effective from March 2020.

 

  • WHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL INFORMATION? 

GGHK will be the data controller and as such is responsible for looking after your personal information. Our Data Privacy Officer may be contacted by emailing hello@gghk2022.com.

GGHK is a company with charitable status incorporated in Hong Kong with company number 2523311 set up to organise the event known as the Gay Games which is to be held in Hong Kong in November 2022. Our registered office in Hong Kong is Suite 701, 7/F, The L Plaza, 367-375 Queen’s Road Central, Hong Kong.  The personal information you submit to us in one country may be transferred, used, processed, stored and accessed worldwide by GGHK and our representatives in one or more countries. For details, please see section 5 below.

 

  • WHAT PERSONAL INFORMATION DO WE COLLECT? 

We may collect certain information from you when you use our Website and Apps. This includes:

  1. Contact details and basic user information including your name and preferred name, age, email address, telephone number, country of residence, travel history, past and intended Gay Games attendance information;
  2. Your marketing preferences including interests and market list assignments, marketing objections, preferred language, website or app data;
  3. Usage information including how you use our Website or applications such as clicks and which pages have been shown to you, referring webpage address;
  4. Device data and log information including IP addresses, device ID and type, and details about your use of our website, app, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information; and
  5. Cookies and tracking technologies including technologies cookies and web beacons and advertising IDs (more information about use of cookies can be found in our Cookies Policy).

We will permit you to provide the following special categories of personal data on a voluntary and optional basis on the basis of your consent:

  1. Health data;
  2. Sexual orientation; 
  3. Gender identity; and
  4. Religion.
  • HOW DO WE COLLECT THIS INFORMATION

Your personal information is collected by us directly, for example, when you use our Website and Apps, register for our events or programmes, enter lucky draws or competitions, sign up for our e-newsletter, download our applications, or when you interact with us by contacting us for enquiries or providing feedback. You are under no obligation to provide the personal information when we seek to directly collect it from you. However, if you do not provide us with certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your enquiries.

We may receive information about you indirectly from other sources and combine such information with information we collect through our Website and Apps where this is necessary to help manage our relationship with you. These other sources may include third party software applications, advertising technologies, and social media platforms such as Facebook, Instagram, Twitter, WeChat, YouTube and Weibo.

If you provide us with information about other individuals, you must tell those individuals and let them know where they can find a copy of this Privacy Policy.

  • FOR WHAT PURPOSES DO WE USE YOUR PERSONAL INFORMATION?

We use your personal information for the following purposes:

  1. To create customer profiles, maintain customer records and to communicate with you, fulfil your requests and respond to your enquiries, bookings, purchases, and feedback;
  2. To send you important notices or personalised messages;
  3. To administer the operation of our Website and Apps, to allow you to use the services and functions of our Website, to conduct website maintenance, to troubleshoot problems, and to continually improve your Website experience and improve our products and services;
  4. To provide services in connection with registration for our events and programmes;
  5. To identify you for entry into lucky draws or any other promotional activities or events;
  6. To facilitate lucky draws, promotional activities or events and notify you of the results of the lucky draws, promotional activities or events, announce winners and arrange for the subsequent presentation or redemption of prizes;
  7. To send you marketing materials, news and information which we think will be of interest to you such as our latest promotional activities and upcoming events;
  8. To assist with identification of attendees at our events, and to determine appropriate services;
  9. To monitor, evaluate and analyse trends, data, usage and activities in connection with our Website, applications, and services;
  10. To administer and operate our applications and other digital services in support of our users;
  11. To keep internal records, decision making and facilitate internal purposes such as auditing, data analysis, and research to improve our products and services, in addition, such internal records will be used to maintain opt-in and opt-out lists;
  12. To detect, investigate and prevent fraud and other illegal activities and protect our rights and property; and
  13. To use your personal information for purposes associated with our legal or regulatory obligations.

We also use your personal information to develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them. We may also recommend content to you based on information we have collected about you and your viewing habits. This may amount to profiling in respect of which more information is provided at Section 8 of this Policy.

We are required to establish a legal basis in order to use your personal information for the purposes set out above. We will make sure that we only use your personal information for the purposes set out above and in Appendix 1 where we are satisfied that:

  1. our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to fulfil obligations under the contract signed between you and us);
  2. you have provided your consent;
  3. it is necessary to comply with a legal obligation; or
  4. our use of your personal information is necessary to support the ‘legitimate interests’ that we have as a business (for example, to improve our products and services, to provide help or support in connection with our Website and Apps, to ensure that they operate efficiently and securely, and to carry out analytics across our datasets), provided it is always carried out in a way that is proportionate, and that respects your privacy rights.
  •  WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We may share your personal information with our affiliates and representatives. We may also share your personal information with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal information. These third parties may include:

  • Our partners, such as venue proprietors, hotels, restaurants, airlines, retailers, travel agents, government departments and public bodies and other companies involved in providing services to you or fulfilling your requests;
  • Service providers, who provide administrative, marketing and research, distribution, data processing and management, advertising delivery, computer system, web development, payment gateway and other functions on our behalf to help us operate our business, such as sending postal mail and e-mails, help manage our IT and back office systems, analysing data, providing marketing and targeted advertising services assistance, providing search results and links (including paid listings and links). If you share your data through our Website or Apps with a third party account such as Facebook, Twitter or Instagram, your personal information will be managed respectively by one of those third parties. Please review the third party’s privacy policy, as their data processing will not be covered by this Policy;
  • Event sponsors or authorised managers, agents or contractors, who facilitate the event or programmes registrations, lucky draws, presentation, redemption or delivery (as appropriate) of prizes in connection with the associated events or activities organised or promoted by us including the Federation of Gay Games (FGG) and Fusesport;
  • Government or non-government authorities and/or regulators as required by law or an event venue;
  • Other third parties, for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public, or as necessary to serve our legitimate business interests; and
  • Professional advisors (including our lawyers and auditors). 

Our Website may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your personal data. You should check the privacy policies of third party websites before you submit any personal data to them.

 

  • DIRECT MARKETING

We may use your personal information to send you direct marketing communications about our products and services or our related services including our latest e-newsletter and upcoming events and offers. This may be in the form of email, post, SMS, telephone or targeted online advertisements or in-app notifications. We limit direct marketing to a reasonable and proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.

From the effective date of this Policy onwards, where you register for our events, programmes or offers, sign-up for our e-newsletter or enter a lucky draw and have elected to receive direct marketing information by email or SMS, then for the purposes of the GDPR and where required under relevant privacy laws, we will ask you for your consent for our processing of your personal information for direct marketing purposes.

The above statement does not apply if you have previously provided us with your personal information and opted-in to direct marketing in accordance with relevant laws. In these cases our continued processing of your personal information is based on our legitimate interests as further detailed in Appendix 1.

You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out links in electronic communications (such as emails), or by contacting us using the details set out in Section 12 below.

 

  • INTERNATIONAL TRANSFERS 

We may transfer your personal information to GGHK affiliates and representatives or service providers that are located outside of Hong Kong and the EU. We must comply with specific rules when we transfer Personal Data (as defined in the GDPR) from inside the European Economic Area (“EEA”) to outside the EEA. When we do this, we will use appropriate safeguards, where necessary, to protect any Personal Data being transferred. 

We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and is undertaken in accordance with the applicable rules governing such transfers.

You have the right to ask us for more information about the safeguards we have put in place. Contact us as set out in Section 12 if you would like further information or to request a copy where the safeguard is documented (which may be redacted to ensure confidentiality).

 

  • PROFILING 

‘Automated decision making’ refers to a decision which is taken through the automated processing of your personal information alone. This means processing using, for example, software code or an algorithm, which does not involve human intervention. As profiling uses automated processing, it is sometimes connected with automated decision making. Though not all profiling results in automated decision making, there is a possibility that it can.

We may use profiling to ensure that marketing materials are tailored to your preferences and to what we think you will be interested in. This does not have any significant effect (legal or otherwise) on you. In certain circumstances it may be possible to infer certain information about you from the result of profiling, which may include special categories of data. We will not however conduct profiling based on your special categories of data unless we have obtained your explicit consent to do so.

Please note that you have certain rights in respect of automated decision making, including profiling where that decision has legal or similarly significant effects on you. You may find more information in Section 10.

 

  • HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

We will retain your personal information for as long as is reasonably necessary for the purposes listed in Section 4 above. When we no longer need to use your personal data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.  In some circumstances we may retain your personal information for longer periods of time. Such circumstances may include but are not limited to where we are required to do so to meet legal, regulatory, tax or accounting requirements.

In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal information or dealings.

 

  • WHAT ARE YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION?

Subject to applicable laws and regulations, you may have a number of rights in relation to your personal information. For example, under GDPR, you may request access to your data, rectification of any mistakes in our records, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any automated decision making and profiling or the basis for international transfers. You also have the right to lodge a complaint with your national supervisory authority (further details of which are set out in Section 12 below).

If you are in the EEA, you have the following rights:

  1. Access: you can ask us to provide details of what personal information (if any) we process about you, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, how you can make a complaint, where we got your data from, you can also ask us to provide a copy of it;
  2. Rectification: you can ask us to rectify inaccurate personal information; 
  3. Erasure: you can ask us to erase your personal information in certain circumstances (for example if it is no longer needed for the purposes for which it was collected or you have withdrawn your consent if the data processing was based on consent) absent an overriding legitimate interest;
  4. Restriction: you can ask us to restrict (i.e. keep but not use) your personal information in certain circumstances (for example where its accuracy is contested or where it ceases to be useful for the purposes we are using it for);
  5. Portability: in certain circumstances you can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it ‘ported’ directly to another data controller;
  6. Objection: you can object to any processing of your personal information which has our ‘legitimate interests’ as its lawful basis if you believe your fundamental rights and freedoms outweigh our legitimate interests; and
  7. Automated Decision Making: you can ask for certain automated decisions to be reconsidered by us using human intervention.
  8. Withdrawal of Consent: if you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. This includes cases where you with to opt out from marketing messages your receive from us.

Please contact us as set out in Section 12 if you do wish to exercise these rights.

  • HOW DO WE PROTECT YOUR PERSONAL INFORMATION?

We endeavour to protect us and you (including your data and personal information that we hold) from unauthorised access, alteration, disclosure or destruction. We have implemented technical and organisational security measures to safeguard your personal information and data.

In particular:

  1. we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems;
  2. we use encrypted password protection where appropriate; and
  3. we restrict access to personal information to employees and contractors who need access to the relevant personal information in order for them to process it for us and who are subject to strict contractual confidentiality obligations.

We endeavour to take all reasonable steps to protect your personal information, but cannot guarantee the security of the data you disclose online due to the inherent security risks of providing information over the Internet.

 

  • CONTACT AND COMPLAINTS

For enquiries, you may contact our data privacy officer at:

Full name of legal entity: GGHK Limited

Name or title of data privacy officer: Lisa Lam, General Counsel

Email address: hello@gghk2022.com

Postal address: Suite 701, 7/F, The L Plaza, 367-375 Queen’s Road Central, Hong Kong

If you are in the EEA, you also have a right to lodge a complaint with your national data protection supervisory authority at any time if you believe that we have not complied with applicable data protection laws. Please click here for a list of national data protection authorities in the EEA countries. 

 

APPENDIX 1 – LAWFUL BASES FOR PROCESSING

No.

Purpose for processing

Lawful basis

1.

To create customer profiles, maintain customer records and to communicate with you, fulfil your requests and respond to your enquiries, bookings and feedback.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK.

GGHK considers that it has a legitimate interest in ensuring your requests and feedback are attended to and to maintain an accurate record of your data.

2.

To send you important notices or personalised messages.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK.

GGHK considers that it has a legitimate interest in ensuring that all customers receive the best possible experience, helping us to preserve our business operations, and ensuring that you are provided with information relevant to you.

3.

To administrate the operation of our Website and Apps, to allow you to use the services and functions of our Website and Apps, to conduct website and application maintenance, trouble shoot problems and to continually improve your Website and Apps experience and improve our products and services.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK.

GGHK considers that it has a legitimate interest in ensuring that all customers receive the best possible experience and improving our products and services offering in order to preserve our business operations.

4.

To maintain opt-out and opt-in lists (including responding to customer requests to opt-out of direct marketing).

This processing is necessary for the purpose of a legal obligation to which GGHK is subject in order to not provide direct marketing materials to individuals which have opted-out of, or opted-in to, receiving such communications.

5.

To provide services in connection with bookings or registration with our events and programmes.

This processing is necessary to perform the contract between you and GGHK.

6.

To identify you for entry into lucky draw or any other promotional activities or events.

This processing is necessary to perform the contract between you and GGHK.

GGHK may also in certain situations have a legitimate interest to ensure that we are providing our customers with the opportunity to engage with us and participate in our activities and events.

7.

To facilitate lucky draws, promotional activities or events and notify you of the results of the lucky draws, promotional activities or events, announce winners and arrange for the subsequent presentation or redemption of prizes.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK.

GGHK considers that it has a legitimate interest in administrating the lucky draws, promotional activities or events and notifying winners to the lucky draw and allowing winners to claim their prizes.

8.

To send you marketing materials, news and information which we think will be of interest to you such as our latest promotional activities and upcoming events.

GGHK considers that it has a legitimate interest in ensuring that our existing customers are kept up to date with information about our products and services, as this helps us to preserve our business operations.

For new customers, however, and where required by applicable law, we will obtain your consent before sending you such information, and therefore, will rely upon such consent as our lawful basis for processing.

9.

To assist with identification of visitors, and to determine appropriate services.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK. 

GGHK considers that it has a legitimate interest in facilitating requests from you and in providing you with relevant appropriate services.

GGHK may also in certain situations also have a legal obligation to respond to and comply with your requests.

10.

To monitor, evaluate and analyse trends, data, usage and activities in connection with our Website and Apps.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK.

GGHK considers that it has a legitimate interest in reviewing our Website and Apps, including how customers use our Website and services, in order to ensure that we are providing our customers with what they need, helping us to preserve and grow our business operations.

11.

To administer and operate our applications and other digital services in support of our users.

This administration and operation is necessary for the purpose of the legitimate interests pursued by GGHK.

12.

To keep internal records, decision making and facilitate internal purposes such as auditing, data analysis, and research to improve our products and services.

This processing is necessary for the purpose of the legitimate interests pursued by GGHK.

GGHK considers that it has a legitimate interest in continually improving our services in order to preserve and grow our business operations, and ensuring that you are provided with information relevant to you.

13.

To detect, investigate and prevent fraud and other illegal activities and protect our rights and property.

GGHK considers that it has a legal obligation to ensure its business operates in accordance with applicable laws and regulations.

14.

To use your personal information for purposes associated with our legal or regulatory obligations.

GGHK considers that it has a legal obligation to ensure its business operates in accordance with the applicable laws and regulations.

15.

To develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them.

GGHK considers that it has a legitimate interest in ensuring that you receive information about our products and services (and those of our partners) which may be of interest to you, this also helps us to preserve and grow our business operations.

GAY GAMES 11 HONG KONG 2022

#GGHK #UNITYINDIVERSITY