Customer Privacy Notice Template for Hong Kong

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Key Requirements PROMPT example:

Customer Privacy Notice

"I need a Customer Privacy Notice for my Hong Kong-based fintech startup that will launch in March 2025, with specific focus on mobile app data collection and cross-border data transfers to our servers in Singapore."

Document background
A Customer Privacy Notice is a mandatory document for organizations operating in Hong Kong that collect, process, or handle personal data of customers. This document is required under the Personal Data (Privacy) Ordinance (PDPO) and must be provided to customers before or at the time of data collection. The notice serves multiple purposes: it ensures compliance with Hong Kong's data protection laws, provides transparency to customers about their data rights, and protects the organization by clearly documenting its data handling practices. The document should be regularly reviewed and updated to reflect changes in data processing activities, regulatory requirements, or organizational practices. It's particularly crucial given Hong Kong's increasing focus on data protection enforcement and the potential penalties for non-compliance with privacy regulations.
Suggested Sections

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

2. Types of Personal Data We Collect: Comprehensive list of personal data categories collected from customers

3. How We Collect Your Personal Data: Methods and sources of personal data collection

4. Purposes of Data Collection and Use: Detailed explanation of why personal data is collected and how it will be used

5. Legal Basis for Processing: Explanation of the legal grounds for collecting and processing personal data

6. Disclosure and Transfer of Personal Data: Information about sharing data with third parties and service providers

7. Data Retention: How long personal data is kept and criteria for determining retention periods

8. Data Security: Measures taken to protect personal data

9. Your Rights: Explanation of data subject rights under the PDPO including access, correction, and deletion

10. Direct Marketing: How personal data is used for marketing and how to opt-out

11. Contact Information: How to contact the organization regarding privacy matters

12. Changes to This Privacy Notice: How changes will be communicated and handled

Optional Sections

1. Cookies and Tracking Technologies: Required if the organization operates websites or apps that use cookies or similar technologies

2. International Data Transfers: Required if personal data is transferred outside of Hong Kong

3. Children's Privacy: Required if services may be provided to or data collected from minors

4. Automated Decision Making: Required if the organization uses automated processing to make decisions about customers

5. Special Categories of Personal Data: Required if collecting sensitive personal data such as health information

6. Industry-Specific Disclosures: Required for regulated industries like financial services or healthcare

Suggested Schedules

1. Schedule 1: Categories of Personal Data: Detailed list of all types of personal data collected, organized by category

2. Schedule 2: Third Party Recipients: List of categories of third parties with whom personal data is shared

3. Schedule 3: Cookie Policy: Detailed information about cookies and other tracking technologies used

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

5. Appendix A: Data Subject Request Form: Standard form for submitting data access or correction requests

6. Appendix B: Marketing Preferences Form: Form for managing marketing preferences and opt-outs

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

Relevant legal definitions
Relevant Industries

Financial Services

Retail

Healthcare

Technology

E-commerce

Insurance

Telecommunications

Education

Professional Services

Travel and Hospitality

Real Estate

Manufacturing

Relevant Teams

Legal

Compliance

Risk Management

Information Security

Data Protection

Customer Relations

Marketing

IT

Operations

Digital Services

Customer Experience

Internal Audit

Relevant Roles

Chief Privacy Officer

Data Protection Officer

Chief Compliance Officer

Legal Counsel

Privacy Manager

Compliance Manager

Risk Manager

Information Security Officer

Customer Relations Manager

Marketing Director

IT Director

Operations Manager

Digital Services Manager

Customer Experience Manager

Industries
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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