Underground Limited respects the privacy of individuals we deal with. Underground Limited is committed to protecting your personal information in accordance with the Personal Data (Privacy) Ordinance of Hong Kong. This Privacy Policy describes what personal information we collect and hold about you, what we do with it, and how we protect your personal information. It also explains how you can access, correct or update the personal information we hold about you.
1. **What kind of personal information we collect**
We only collect personal information that we need to carry out Underground Limited’s functions and/or to provide you with one of our services. Some examples of the personal information we collect include: name and contact details (including postal addresses, email addresses and phone numbers); name and contact details of persons seeking support; employment history of persons seeking support; information regarding citizenship or permanent residency of persons seeking support; social media handles and personas; names, contact details and work experience of job applicants and volunteers; and financial information of donors and persons seeking support, including credit card numbers, bank accounts and other financial information. We sometimes also collect sensitive information, such as medical history, if you have consented (for example through submission of a form requesting the sensitive information) and the information is reasonably necessary for or directly related to one of our functions or services. When we collect and use this information, we only do so in strict accordance with the purpose for which the information was supplied, for example assessing claims for financial assistance.
2. **How we collect personal information**
Where possible, we will collect your personal information directly from you. This may include collections via: email and other written correspondence sent to and from Underground Limited about fundraising efforts and events, appeals, crisis assistance or general queries; phone conversations via Underground Limited’s Helpline; applications for crisis and financial assistance; donation forms; posts on Underground Limited’s social media channels, including Twitter, Instagram and Facebook; and job applications by prospective employees and volunteers. While we often collect personal information about you directly from you, we occasionally receive personal information from third-party sources such as third-party fundraising platforms, contractors, health professionals and persons that may be making applications for assistance on your behalf. Where this occurs and it is unclear whether you have consented to having your personal information disclosed to us, we will take reasonable steps to ensure that you are aware of the collection of personal information and the purposes for which it was collected.
3. **Online privacy issues**
We may place cookies on your computer or your mobile device to improve your experience on our website. A cookie is a small text file that may be placed on your device to store information. A cookie does not identify individuals personally, but it does recognize your browser. You can change your privacy preferences regarding the use of cookies and similar technologies through your browser. You may set your browser to accept all cookies, require your consent before a cookie is placed in your browser, block certain cookies or block all cookies. Please note that if you restrict the use of cookies on your computer, you may not be able to use the full functionality of the website. Our website and other social media channels (including Twitter, Facebook, and Instagram) may contain links to online services operated by third parties. You should be aware that when you access a third-party service, we are not responsible for the privacy practices and policies of that third party. We suggest that you review the privacy policy for each website, social media channel, and other online service that you visit, especially if you intend to disclose any personal information.
4. **How we use and disclose personal information**
We use and disclose your personal information for the primary purpose of delivering our services to you. These primary reasons can include: assessing and providing crisis support services; managing fundraising events; processing payments for sale of goods; operating a Helpline or any other telephone support services; responding to general queries; managing and resolving any legal or commercial complaints or issues; and sending direct marketing material to you regarding our fundraising activities and events (if you have opted in to receive such material). We also use personal information for directly related secondary purposes such as processing online payments, general business administration, and for improving our services to you. We may need to disclose your personal information to third parties to carry out some of our functions. This may include external support services (e.g., our legal, financial, and business advisors, information technology services providers, credit card providers, and financial institutions associated with processing your online payment). We will only disclose your personal information to other persons or organizations for the primary purpose for which we originally collected it, with your consent, or if we are required to do so by law or legal proceedings. We may also disclose your information to protect the rights, property or safety of either you, our other clients or third parties. Personal information provided by applicants, persons making applications on applicant’s behalf, or third parties will be accessed and handled by paid Underground Limited staff. From time to time, volunteers may also be engaged to assist us under the direction of Underground Limited staff. To avoid doubt all staff and volunteers are required to handle personal information in accordance with this Policy and are required to sign a confidentiality agreement.
5. **How we store and protect your personal information**
Underground Limited takes the security of your personal information seriously, taking reasonable steps to ensure that the information we hold about you is secure. We store most personal information on computer systems and databases operated by either us or our external service providers. This personal information is held on password-protected cloud-based storage services such as Dropbox. Access to these web-based services and files is restricted to authorized members of staff and volunteers. Some personal information about is recorded in hard copy files that we store securely. These hard copy files are destroyed when digitalized. We also take reasonable steps to ensure that our employees, volunteers, and service providers respect the confidentiality of the personal information that we hold about you.
6. **What if you do not provide us your personal information?**
You are free to provide or not provide us with any personal information. However, in the absence of certain personal information, we may not be able to provide you with the services or information that you may need from us.
7. **How you can access and update your personal information**
Under the Personal Data (Privacy) Ordinance, you have a right to request access to information about you held by us. However, there are some circumstances in which we are not required to give you access to your personal information. We will take reasonable steps to ensure the personal information we hold about you is accurate and up-to-date. Should you wish to access, update or correct the personal information we hold about you, please contact Underground Limited.
8. **How we handle information we no longer need**
We only retain personal information for as long as it is needed by us. We will take reasonable steps to destroy or de-identify your personal information as soon as practicable after it is no longer needed for the purpose for which it was collected. However, the law may require us to keep your personal information after your relationship with us ends. If this applies, we will continue to protect your personal information in accordance with this Personal Data (Privacy) Ordinance.
9. **How you can contact Underground Limited**
If you require further information about this Personal Data (Privacy) Ordinance want to update your information or make a complaint about the steps we have taken to protect your personal information or privacy please contact Underground Limited: by phone at +852-9486 4648; by email at contact@brg-radio.com; and by post at G/F 5-13 New St Tai Ping Shan Hong Kong (Attn: Underground Limited). We will endeavor to provide you with a response within 30 days of your request.
This policy was last updated Dec 2021.
