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  • cs@cookiesmiles.com.hk

Privacy Policy

Cookie Smiles Privacy Policy


This is the Privacy Policy of Cookie Smiles Limited, its Board, committees and affiliates (hereafter referred to as “The Company“). The Company respects personal data privacy and is committed to fully implementing and complying with the data protection principles under the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Ordinance“).


Our privacy principles are:


  • The Company only collects personal data which we believe to be relevant and required to conduct our business and provide our services.
  • The Company will use your personal data only for the purpose for which the data is collected or for a directly related purpose, unless consent for a new purpose is obtained from you.
  • The Company endeavours to keep your personal data accurate and up-to-date.
  • The Company will not transfer or disclose your personal data to any entity that is not a party as detailed in this Privacy Policy without your consent unless it is required by law or it was previously notified to you.
  • The Company endeavours and has implemented various measures to safeguard and secure the personal data we collect.


Please read the following Privacy Policy to understand how The Company handles your personal data collected through various means, including its websites, application forms and other collection channels. By providing your personal data to us, you are consenting to this Privacy Policy and the collection, use, access, transfer, storage and processing of your personal data as described in this Privacy Policy.


We amend or update this Privacy Policy from time to time without prior notice. You are advised to visit the above website regularly for the latest version of this Policy.


  1. Kinds of Personal Data Collected and Held
  • We collect and hold the following broad categories of personal data (“Data”) depending on our engagement with you:
    • Personal information: including salutation, name, gender, marital status, religious belief, date of birth, photographs and/or videos, and identification proof or numbers;
    • Contact information: including telephone number, residential address, office address, mailing address and email address (and emergency contact or referee details where relevant);
    • Personnel records: including The Company’s personnel (including volunteers) details, job particulars, details of salary, payments, benefits, leave and training records, medical insurance records, mandatory provident schemes participation, performance appraisals/records, volunteer timesheets and disciplinary matters;
    • Donation records: including donation history and financial information but not limited to bank account details;
    • Health records: including medical history, physical or mental conditions, special needs or restrictions, birth records;
    • Sensitive records: including record of convictions, history of working with children or vulnerable adults;
    • Consultant and contractor records: including name, contact details, corporate information, business registration details and other information of any individual employed or engaged by service providers in the fields of information technology, marketing and other areas providing necessary services required by The Company;
    • Records collected on webservers or digital media: including email address, browsing preferences and IP address (whereas they constitute personal data under specific circumstances that the address can be used to identify an individual) collected for newsletter subscription, online enquiries or otherwise;
    • Other records: including enquiries, responses to our surveys or interviews, meeting notes and other operational and administrative records that contain personal data, and other information as may be set out in the relevant form or collection channel.
  • In certain situations, we may ask you to provide the Data of other individuals to us, e.g. emergency contacts or information of your family members or significant halves. By providing us with such Data, you represent to us that you have obtained those individuals’ authorisation and/or consent to the use, disclosure and transfer of their Data. We shall not be responsible for any claim whatsoever from any party in the absence of such consent.
  • At the time of collection of the Data it may be indicated whether any Data is obligatory or voluntary. If you fail to supply Data that is marked as obligatory, we may not be able to engage with you for the intended purposes or provide the relevant services fully or at all.


  1. Purposes for which the Data are Collected and Used
  • We may use the Data for the following main purposes (or any directly related purpose):
    • Personal information: for communication, administration of volunteering and donation activities including verification of identity, handling requests for services, providing educational materials for workshops or any other purposes which the employee, volunteer, service user, working partner or donor has been notified of and consented to;
    • Contact information: for communicating with you by email, mail, fax, phone or other means in respect of your use of our services and/or websites;
    • Personnel records: for recruitment and human resource management purposes, relating to such matters as employees’ appointment, employment benefits, termination, performance appraisal and discipline, volunteers’ performance/ recruitment;
    • Donation records: for processing and handling donations received;
    • Health records: for processing applications in connection with services provided to or requested by you, or services you may provide as applicable;
    • Sensitive records: for processing applications in connection with volunteering or working with vulnerable service users, such as children and vulnerable adults;
    • Consultant and contractor records: engaging, monitoring, managing and appraising relationships with consultants and contractors who are and/or engage or employ individuals to provide services to The Company;
    • Records collected on webservers or digital media: for sending newsletters to subscribers registered through websites and providing marketing and educational materials and replies to enquiries; and
    • Other records: for various purposes varying according to the nature of the records, including for administration and operation of The Company, handling enquiries from members of the public and carrying out daily business.
    • General:
  1. for communicating with you;
  2. for our daily operation and administration, such as purposes directly related to the fundraising, education, social services and operation functions;
  • for preparing statistics or carrying out research;
  1. subject to your consent, for direct marketing (see below paragraph on direct marketing);
  2. for identification and verification;
  3. for enforcing our legal rights;
  • for complying with legal or regulatory obligations including for reporting instances of crime;
  • for handling your enquiries or requests; and
  1. for any other purposes to which you may from time to time agree.
  • We will not sell or rent the Data provided to us, or knowingly or intentionally use or share the Data in ways unrelated to the purposes aforementioned.


  1. Disclosure and Transfer of Data
  • We may disclose and transfer the Data you provide to the following parties (whether local or overseas) in connection with the purposes set out above (or any directly related purpose):
    • within The Company;
    • our agents, donors, working partners, professional advisers (including lawyers and auditors), contractors, subcontractors or peer agencies;
    • third party service providers who provide administrative, financial, data processing, telecommunications, computer, payment, marketing and research or other services in connection with the operation and maintenance of our charity, or any persons under a duty of confidentiality to us;
    • any person to whom we are under an obligation to make disclosure under the requirements of law or a court order of any jurisdiction or to any government or law enforcement authorities or administrative organs as requested;
    • any person to whom we believe in good faith that disclosure is otherwise necessary or advisable including and without limitation to protect our rights or in circumstances which we consider to be related to any of the purposes for which the Data are collected; and
    • to any person when we have reason to believe that disclosing the Data to such person is necessary to identify, contact or bring or defend legal action against someone, e.g. anyone who may be infringing our rights, or when anyone else could be harmed by such activities.
  • The Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above. We will try to ensure, as far as possible and practicable, that Data sourced or transferred outside Hong Kong is protected to standards in line with the requirements of the Ordinance, subject to any other requirements and limitations of the particular jurisdiction.


  1. Data Security and Retention
  • Subject to any legal and regulatory requirements, the Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above, after which it will be destroyed.
  • In order to ensure the correct use and to maintain the accuracy of Data collected from you, as well as prevent unauthorised or accidental access, processing, erasure or other use of the Data, we have implemented various measures to safeguard and secure the Data we collect. However, we cannot guarantee that data transmission over the internet or other media is completely secure.


  1. Direct Marketing
  • We intend to use your Data for sending you marketing and promotional materials through the post, email, digital media, telephone, text/SMS messaging and other means, in relation to activities in Hong Kong or overseas such as:
    • Volunteering opportunities: promotions, workshops and events hosted or organised by The Company;
    • Donation opportunities: solicitations for donations or contributions in support of The Company; and
    • Others: other activities, events, businesses or promotions as may be carried out by The Company and notified to you (as set out in the relevant form or collection channel) from time to time.

collectively the “Marketing Activities“.

We will only use your Data for the purposes of Marketing Activities if you have consented to such use.

  • You always have control over the type of information you would like to receive from us. You can indicate your consent to our use of your Data for the purposes of the Marketing Activities, and can withdraw at any time by sending an email to us at info@cookiesmiles.com.hk or as indicated in the relevant materials.


  1. Cookies and Other Tracking Mechanisms
  • We may collect information about your computer or device, including where available your IP address, device ID, MAC address, operating system and browser type. This is statistical data which does not reveal your identity. Similarly, cookies may be left on the hard drive of your computer, mobile phone or other devices.
  • We use cookies and other tracking mechanisms mentioned above for system administration, to track information about your use of our websites and to improve your browsing and user experience. You may choose to accept or refuse cookies by adjusting the settings of your web browser. However, if you select to refuse cookies, you may not be able to fully access certain functions.
  • We may feature embedded links, “share” buttons or widgets on our websites to enable you to connect to third party sites, including social media sites. These third party sites may set cookies which can identify you as an individual when you are logged in to their services. We do not control these cookies or how these sites collect and handle your Data. You should read the relevant third-party sites for their privacy policies before submitting any Data to these sites. We have no control over and are not responsible or liable for the contents of third party sites or third party posts on our social media accounts.


  1. How to Access or Correct Your Data or Contact Us
  • You are entitled to access or correct any Data related to you held by us. If you wish to obtain a copy of any of your Data or if you believe that the Data related to you which we collect and maintain is inaccurate, please contact us at info@cookiesmiles.com.hk.
  • In accordance with the terms of the Ordinance, we may charge a reasonable fee for the processing of any data access request.


  1. Access to Data Privacy Policy
  • You may access and obtain a copy of our latest Data Privacy Policy, as amended from time to time, on our website HERE so that you are always informed of the way we collect and use your Data.
  • This Privacy Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Privacy Policy, the English version shall prevail.
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