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Online Privacy Notice

Online Privacy Notice Template for Hong Kong

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Key Requirements PROMPT example:

Online Privacy Notice

"I need an Online Privacy Notice for my Hong Kong-based e-commerce platform that will launch in March 2025, which includes provisions for international data transfers to our warehouses in mainland China and payment processing in Singapore."

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Document background
The Online Privacy Notice is a mandatory document for organizations operating websites or online platforms that collect personal data in Hong Kong. It must comply with the Personal Data (Privacy) Ordinance (PDPO) and guidelines issued by the Privacy Commissioner for Personal Data (PCPD). The document should be prominently displayed on the website and easily accessible to users. It must detail all aspects of personal data collection and processing, including purposes, storage methods, third-party sharing, and user rights. The notice should be written in clear, understandable language while maintaining legal compliance. Regular updates are required to reflect changes in data handling practices or regulatory requirements.
Suggested Sections

1. Introduction: Overview of the organization and scope of the privacy notice

2. Definitions: Key terms used throughout the privacy notice

3. Information We Collect: Categories of personal data collected, including both active collection and automated collection (cookies, etc.)

4. How We Use Your Information: Purposes of data collection and legal bases for processing

5. How We Store and Protect Your Information: Data security measures and retention periods

6. Information Sharing and Disclosure: Third parties with whom data is shared and circumstances of sharing

7. Your Privacy Rights: Rights under the PDPO including access, correction, and deletion rights

8. Children's Privacy: Policies regarding collection of data from minors

9. Changes to This Privacy Notice: Process for updating the privacy notice and notification of changes

10. Contact Information: Details of the data protection officer or responsible party for privacy queries

Optional Sections

1. Cross-Border Data Transfers: Include when personal data is transferred outside Hong Kong

2. Direct Marketing: Include when personal data is used for direct marketing purposes, requiring specific consent provisions

3. E-commerce Information: Include for websites conducting online sales, describing transaction-related data handling

4. Social Media Integration: Include when the website includes social media features or plugins

5. Automated Decision Making: Include when using AI or automated processing that significantly affects users

6. Mobile App Privacy: Include when offering mobile applications in addition to website services

Suggested Schedules

1. Cookie Policy: Detailed information about types of cookies used and their purposes

2. Third-Party Service Providers: List of data processors and their roles in data processing

3. Technical and Security Measures: Detailed description of security protocols and safeguards

4. Data Retention Schedule: Specific retention periods for different types of personal data

Authors

Alex Denne

Head of Growth (Open Source Law) @ Genie AI | 3 x UCL-Certified in Contract Law & Drafting | 4+ Years Managing 1M+ Legal Documents | Serial Founder & Legal AI Author

Linkedin in social icon imageX social icon image
alex.den.21@genieai.co
Relevant legal definitions
Personal Data
Data Subject
Data User/Data Controller
Data Processor
Processing
Cookies
IP Address
Log Data
Device Information
User
Website
Mobile Application
Third Party
Consent
Direct Marketing
Cross-border Transfer
Sensitive Personal Data
Privacy Commissioner
PDPO
Access Request
Correction Request
Data Retention
Anonymous Data
Pseudonymized Data
Service Providers
Tracking Technologies
Browser Settings
Session
Personal Data Collection Statement
Privacy Policy
Data Protection Principles
Opt-out
Data Breach
Automated Processing
Relevant Industries

E-commerce

Financial Services

Technology

Healthcare

Education

Retail

Professional Services

Media and Entertainment

Travel and Hospitality

Manufacturing

Real Estate

Telecommunications

Non-profit Organizations

Government Services

Relevant Teams

Legal

Compliance

Information Technology

Information Security

Privacy

Digital Operations

Marketing

Risk Management

Customer Service

Data Management

Website Operations

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Chief Legal Officer

General Counsel

Privacy Manager

Compliance Officer

IT Security Manager

Chief Information Security Officer

Chief Technology Officer

Website Administrator

Digital Marketing Manager

Risk Manager

Chief Operating Officer

Chief Executive Officer

Industries
Personal Data (Privacy) Ordinance (Cap. 486): The primary legislation governing personal data protection in Hong Kong, establishing data protection principles and compliance requirements for data collection, processing, and storage
PCPD Guidance on Online Privacy Protection: Guidelines issued by the Privacy Commissioner for Personal Data specifically addressing online privacy issues, including cookie policies, online tracking, and digital data collection practices
Electronic Transactions Ordinance (Cap. 553): Legislation governing electronic communications and transactions, relevant for aspects of online data collection and electronic consent mechanisms
PCPD Guidance on Cross-border Data Transfer: Guidelines regarding the transfer of personal data outside of Hong Kong, including requirements for adequate data protection in recipient jurisdictions
PDPO Direct Marketing Provisions: Specific provisions under the PDPO regarding the use of personal data for direct marketing purposes, requiring explicit consent and opt-out mechanisms
Teams

Employer, Employee, Start Date, Job Title, Department, Location, Probationary Period, Notice Period, Salary, Overtime, Vacation Pay, Statutory Holidays, Benefits, Bonus, Expenses, Working Hours, Rest Breaks,  Leaves of Absence, Confidentiality, Intellectual Property, Non-Solicitation, Non-Competition, Code of Conduct, Termination,  Severance Pay, Governing Law, Entire Agreemen

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