AQ STRONG / AQ STRONG ACADEMY PRIVACY POLICY

Last updated: 15 November 2021

We take the privacy of our website users very seriously. Please review this document to learn how Athletic Academy Limited (“AQ Strong”, “we”, “us” and/or “our”) collects, uses, holds, discloses and/or processes your Personal Data (as defined below) under Personal Data Privacy Ordinance (Cap. 486 of the Laws of Hong Kong) (the “PDPO”) and the European General Data Protection Regulation (EU) 2016/679 (the “GDPR”). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that Personal Data held by us is accurate. 

For the purposes of the PDPO, AQ Strong is the data user (i.e. the company who is responsible for, and controls the processing of, your Personal Data).

This Privacy Policy (“Policy”) applies to you and all Individuals (as defined below) who provide AQ Strong with Personal Data or whose Personal Data is otherwise collected, used, held, processed, stored and/or disclosed by AQ Strong in connection with and/or for the purposes of its operations. 

 

This Policy supplements but does not supersede or replace any previous consent which you may have provided to AQ Strong, nor does it affect any legal rights that AQ Strong may have regarding the collection, use, processing and/or disclosure of any Personal Data. 

 

AQ Strong will regularly review this Policy and may from time to time revise it or add specific instructions, policies and terms    to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at www.aqstrong.com (the “AQ Strong Website” or “our website(s)”). Notification of any material revisions will also be published on the AQ Strong Website and, where required by the PDPO, give you the opportunity to opt out of these changes by means notified to you at that time. Otherwise, in relation to Personal Data supplied to us through the AQ Strong Website or otherwise, continued use by you of the AQ Strong Website or your continued relationship with AQ Strongshall be deemed to be your acceptance of and the consent to this Policy, as amended from time to time.

 

This Policy forms part of the terms and conditions, if any, governing your specific relationship with AQ Strong (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.   

1 / Definitions

For the purposes of this Policy: 

Individual” or “you” means a natural person, whether living or deceased and “Individuals” and “your” shall be construed accordingly; 

Personal Data” means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to AQ Strong;

Personnel” means any Individual engaged under a contract of service with AQ Strong including permanent or temporary employees as well as trainees and interns engaged by AQ Strong from time to time; and

Potential Personnel” means any Individual who has submitted an application to be engaged by AQ Strong as Personnel.

2 / Purposes for collection, use and disclosure of Personal Data

AQ Strong may, from time to time, collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary (There are some information which are mandatory for us to collect in order to provide our services to you) for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:

  1. Facilitating AQ Strong’s provision of products and services which are used by you and from time to time with newsletters, marketing or promotional materials and any other information that may be relevant to you;

  2. Communicating with you to assist you with your enquiries;

  3. Dealing with administrative matters relating to the products and/or services purchased and/or subscribed to by you;

  4. Conducting research, statistical analysis, behavioural analysis and customer satisfaction surveys;

  5. Customer profiling and analysing your purchasing preferences

  6. Customising this website and its content to your particular preferences;

  7. Improving our services;

  8. Fraud prevention and detection;

  9. Billing and order fulfilment;

  10. To notify you of any changes to this website or to our services which may affect you;

  11. Any other purposes that we notify you of at the time of obtaining consent 

(collectively known as the “Purposes”). 

3 / Collection of Personal Data

Generally, AQ Strong may collect Personal Data from you in one or more of the following ways or circumstances:

 

  1. Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you may not be able to access some parts of our websites or use our services. 

  2. Information collected automatically: Some information is collected automatically, such as an IP address (We use your IP address to determine your location in order to provide the most relevant content to you) and device type, when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.

  3. Information from third parties: The majority of information that we collect is collected directly from you. Some data may be collected from other sources, such as information that is available in the public domain or trusted third parties in order to conduct background checks as part of your relationship with us. We use this information to supplement the Personal Data that we have collected from you.

 

Where your Personal Data is collected from third parties, we will only use such Personal Data where you have provided your consent to the third party which would also cover our processing of your Personal Data or where AQ Strong has a legitimate interest to use the Personal Data in order to evaluate the suitability of your relationship with us.

4 / Personal data we may collect about you

The Personal Data we collect from you may include your full name, contact information, passport or other identification, telephone number(s), residential address, email address, biometric data and other personal information required by government agencies, product and service selections, and other data that may identify you.   

We collect Personal Data about you at several different points, including but not limited to the following:

 

  • when we correspond with you as a customer or prospective customer;

  • when you visit our websites or use any of our platform(s);

  • when you send us feedback or contact us for any reason; 

  • when you post material on our website(s) or platform(s);

  • when you use our software or services;

  • when you register as an end-user of our services and an account is created for you;

  • when you decide to participate in a survey;

  • When you voluntarily provide us with your information through our landing pages

 

We may monitor your use of this website through the use of cookies and similar tracking devices. For example, we may monitoring how many times you visit, which pages you go to, traffic data, location data and the originating domain name of a user’s internet service provider. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually. Please see further the section on Use of cookies below.

We seek to protect the information we share by imposing contractual privacy and security safeguards on the recipient of the information. Whenever redirected outside of AQ Strong, we encourage you to read the provider’s relevant privacy policy in order to have a better understanding on how your data is being processed.

5 / Marketing and opting out

Unless you have asked us not to do so, we may contact you, and we may share your Personal Data with organisations who are our business partners who may contact you by mail, telephone, SMS, text/picture/video message, fax, email about our products, services, promotions, special offers, charitable causes which may be of interest to you. 

If you prefer not to receive any direct marketing communications from us, you can opt out at any time. See further “Access to and correction of Personal Data” below.

6 / Processing of Personal Data

Where we collect Personal data, we will only process it:

 

  1. To perform a contract with you, or

  2. Where we have a legitimate interest to protect the Personal Data which is not overridden by your rights, or 

  3. In accordance with a legal obligation, or

  4. Where we have your consent.

 

Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our services to you or respond to your other requests; for job applicants, we would not be able to evaluate your suitability against our employment opportunities.

7 / Disclosure of Personal Data

There may be occasions where we may need to share your Personal Data with third parties. AQ Strong will disclose your Personal Data only in the following circumstances:

  1. to other companies within our group; 

  2. to AQ Strong’s third party service providers or agents;

  3. to AQ Strong’s auditors and professional advisors;

  4. to regulators, law enforcement bodies, government agencies, courts or any other third party to whom disclosure is permitted or required by any applicable law or regulation;

  5. to our business partners in accordance with the Marketing and opting out section above; and 

  6. to other parties where we have your consent.

8 / Sharing Information Outside AQ Strong

AQ Strong may share the Personal Data with external parties that are performing tasks on our behalf (including data processors and sub-contractors) and with other companies, organisations, government bodies, and individuals outside AQ Strong where we have a legitimate legal reason for doing so or where we have been instructed to share the Personal Data on behalf of our clients.

9 / Consent

Unless otherwise authorised under the PDPO, GDPR or any other applicable law, AQ Strong will not collect, hold, use, disclose or process your Personal Data without your knowledge and consent. AQ Strong will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data.

 

AQ Strong may obtain your consent by any of the following means:

  1. via express provisions in a contract, application form and/or registration form to be signed with or submitted to AQ Strong;

  2. via notifications on AQ Strong Website, our website(s), platform(s) or applications;

  3. In so far as any Purpose(s) are intrinsic to the relationship or provision of services, AQ Strong reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to AQ Strong’s collection, use or disclosure of your Personal Data for such purposes.

 

If you:

  • voluntarily provide Personal Data to AQ Strong for any specified purpose;

  • use or access AQ Strong Website, our website(s), platform(s) or applications;

  • enter AQ Strong’s premises or use any of the facilities thereon; and/or

  • attend or participate in events or programmes organised by AQ Strong,

you will be deemed to have agreed and consented to AQ Strong collecting, using and/or disclosing your Personal Data in the manner and for the Purposes set forth in this Privacy Policy.

 

If you provide AQ Strong with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, you represent to AQ Strong that that the other person has appointed you to act on his/her behalf and you have obtained the consent of the relevant third party for AQ Strong to collect, use or disclose such Personal Data for the Purposes including but not limited to:-

  • you can give consent on his/her behalf to the processing of his or her Personal Data; 

  • you can receive on his/her behalf any data protection notices; 

  • you can give consent to the transfer of his/her Personal Data abroad; and 

  • you can give consent to the processing of his or her [insert category or categories of sensitive Personal Data.

10 / Request to Withdraw Consent

You have the right to withdraw your consent to the collection, use, retention, disclosure and/or process of your Personal Data in the possession of AQ Strong by submitting your request in writing to Athletic Coordinator staff at any time. 

 

We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, hold, use,    disclose and/or process your Personal Data in the manner stated in your request.

 

Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing business relationship.

11 / Cookies

We may place and access certain cookies (a cookie is a small piece of data that is stored on your computer or other electronic device) and other online tracking devices such as [specify, eg web beacons, action tags, Local Shared Objects, single-pixel gifs (collectively referred to as “Cookies”) on your computer and/or any electronic device used to access the AQ Strong Website, our website(s), platform(s) and application(s) to:-

  • recognise you whenever you visit this website (this speeds up your access to the site as you do not have to log on each time) 

  • obtain information about your preferences, online movements and use of the internet 

  • carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitor/customer requirements and interests 

  • target our marketing and advertising campaigns and those of our partners more effectively [by providing interest-based advertisements that are personalised to your interests 

  • make your online experience more efficient and enjoyable.

We use Cookies to improve your experience using the AQ Strong Website, our website(s), platform(s) and application(s) and to improve our services. The information we obtain from our use of Cookies may not usually contain your Personal Data. Although we may obtain information about your computer or other electronic device such as your IP address, your browser and/or other internet log information, this may not usually identify you personally. In certain circumstances we may collect Personal Data about you – but only where you voluntarily provide it or where you purchase goods or services from us. We will take all reasonable steps to ensure that your privacy is protected and respected at all times. 

In most cases we will ask for your consent in order to use Cookies on this website. If you visit our website(s) when your browser is set to accept cookies, we will interpret this as an indication that you consent to our use of Cookies and other similar technologies as described in this Privacy Policy. If you change your mind in the future about letting us use cookies, you may disable the use of Cookies on your internet browser when accessing the AQ Strong Website, our website(s), platform(s) and application(s). However, disabling the use of cookies may result in the loss of functionality, restrict your use of the website and/or delay or affect the way of operation of  the AQ Strong website, our website(s), platform(s) and application(s).

12 / Third-party cookies

We work  with  third-party  suppliers  who  may  also  set  cookies  on  our  website,  for  example  Facebook,  Twitter, YouTube  and  Adobe  Flashplayer which  we  use  to  display  video  content.  These  third-party  suppliers  are responsible for the cookies they set on our site. If you want further information please go to the website for the relevant third party.

13 / Security of Personal Data

AQ Strong will make reasonable security arrangements and/or take all practicable steps to ensure the security of the Personal Data and to prevent and avoid unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal, erasure or similar risks to Personal Data in its possession. This includes physical, technical and procedural security methods, where appropriate, to ensure that the Personal Data may only be accessed by authorised personnel. 

 

Whilst we will use all reasonable efforts to safeguard your Personal Data, you acknowledge that the use of the internet or platforms is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal data which are transferred from you or to you via the internet. 

AQ Strong is not responsible in any way for the security and/or management of Personal Data shared by you with third party websites accessible via links on AQ Strong website. 

14 / Third party websites

Our website(s) or platform(s) or application(s) may, from time to time, contain links to and from the websites of our partner networks 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 do not accept any responsibility for them. Please check these policies before you submit any Personal Data to these websites.

15 / Accuracy of Personal Data

Information voluntarily provided by you to AQ Strong shall be deemed complete and accurate.

 

AQ Strong will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you to AQ Strong is complete and accurate. 

 

AQ Strong will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying AQ Strong, from time to time, of any applicable changes to your Personal Data.  Please refer to “Right of Correction/Rectification” below.

 

AQ Strong shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to AQ Strong is complete and accurate.

16 / Access to and correction of Personal Data 

In general, the rights afforded to individuals are:

 

a) Right to Access

The right to be informed of and request access to the Personal Data that we process about you. This will enable you to check what Personal Data we are processing and whether the processing is lawful.

 If you wish to exercise this right you should:

  • put your request in writing and send it to Athletic Coordinator staff at info@aqstrong.com

  • provide us with enough information to identify you (eg account number, username, registration details)

  • specify  the  personal  data  you  want  access  to,  including  any  account  or  reference  numbers  where applicable.

We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within 30 days after receiving your access request, we will inform you in writing via email within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under any other applicable laws).

 

b) Right of Correction/Rectification

The right to request that we amend or update your Personal Data where it is inaccurate or incomplete. Kindly note that while we shall make a reasonable effort to ensure that the Personal Data we collect is accurate and complete, you are responsible for ensuring the accuracy of the Personal Data that you provide to us directly.

 If you wish to exercise this right you should:

  • put your request in writing and send it to Athletic Coordinator staff at info@aqstrong.com

  • provide us with enough information to identify you (eg account number, username, registration details) 

  • specify the information that is incorrect and what it should be replaced with.

We will respond to your correction request as soon as reasonably possible. Should we not be able to perform the correction request within 30 days after receiving your request, we will inform you in writing via email on the time by which we will be able to perform your correction request. If we are unable to perform a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPO or under any other applicable laws).

 

c) Right to Withdrawn Consent

You have right to withdraw your consent at any time, where consent is the legal basis of the processing of your Personal Data. Kindly note that depending on the nature and scope of your request, we may not be in a position to continue performing our obligations in the course of or in connection with the services to you.

 

For individuals covered by the GDPR, they also have the following rights (as available and subject to any applicable law):

 

d) Right to Erasure

The right to request that we temporarily or permanently stop processing all or some of your Personal Data.

 

e) Right to Object

The right to object to your Personal Data being processed by us for direct marketing purposes, or to, at any time, object to us processing your Personal Data on grounds relating to your particular situation

 

f) Right to Data Portability

The right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service.

 

g) Right not to be subject to Automated Decision-making

The right to not be subject to a decision based solely on automated decision-making where the decision would have a legal effect on you or produce a similarly significant effect.

 

If we send you electronic marketing messages (i.e. newsletters) based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection at no cost. The electronic marketing messages you receive from AQ Strong will also include an “unsubscribe” option within the message itself to enable you to manage your Personal Data. Please note that if you opt-out of receiving direct marketing materials, we may still send you non-promotional messages, such as receipts or information about the services we are providing to you.

 

Additionally, you have the right at any time to lodge a complaint with your local Data Protection Authority if you are unhappy with the way in which we are using your Personal Data.

 

In order to enable you to exercise these rights with ease and to record your preferences in relation to how AQ Strong uses your Personal Data, you may email us at info@aqstrong.com or contact +852 6763 2813.

17 / Retention of Data

The length of time that we keep your Personal Data depends on what it is and whether we have an ongoing business need to retain it.

 

We will only retain your data for as long as we have a business relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, or where we are required by law to retain it.

 

Upon the expiry of time relating to any business needs or legal requirements to retain your Personal Data we will ensure that your Personal Data is deleted or anonymised.

18 / Overseas Transfer

In the provision of our services, the Personal Data we collect may be transferred to and processed by third parties in other countries outside Hong Kong for the Purposes. In all such instances, AQ Strong shall ensure that the transfer of your Personal Data is carried out in accordance with any applicable laws and that appropriate safeguards (e.g. contractual, technical and organizational measures) are put in place before such transfer takes place.

19 / Making a complaint

You are welcome to contact us if you have any complaint or grievance about how we are handling any Personal Data in our control or possession.

 

To make a complaint you can:

  1. contact our Athletic Coordinator staff at info@aqstrong.com;

  2. contact us by telephone during our normal office hours (9:00am to 6:00 pm) at +852 6763 2813; or

  3. visit us in person at our Hong Kong office during our normal operational hours which are updated on our website (8:00am to 9:00pm).

20 / Miscellaneous

If any provision of this Policy shall be held to be illegal, void, invalid or unenforceable under the laws of any jurisdiction, the legality, validity and enforceability of the remainder of this Policy in that jurisdiction shall not be affected, and the legality, validity and enforceability of the whole of this Policy in any other jurisdiction shall not be affected.

 

Nothing in this Policy shall be construed as AQ Strong providing an indemnity to any customer in relation to any Personal Data or use thereof. AQ Strong expressly excludes liability or any losses which the customer may suffer on account of AQ Strong’s collection, storage or use of Personal Data in accordance with this Policy. In any event, AQ Strong expressly excludes any liability to the customer which are in the nature of indirect or consequential losses, special losses, loss of profits, loss of contracts, loss of reputation or goodwill, or other tangential or intangible losses that a customer may suffer on account of a breach of this Policy by AQ Strong or any of its agents or service providers.