Privacy Policy for Hong Kong Harmonica Association Mobile App

Last Updated: May 19, 2025

The Hong Kong Harmonica Association (“HKHA,” “we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you use our mobile application (“App”) available on the Google Play Store. By using the App, you agree to the terms of this Privacy Policy.

1. About HKHA

HKHA is a registered charitable institution under Section 88 of the Inland Revenue Ordinance (Laws of Hong Kong Chapter 112), dedicated to promoting the art of harmonica music and related cultural exchanges in Hong Kong and nearby regions. The App supports our mission by providing access to event information, harmonica music resources, and community engagement features.

2. Information We Collect

We may collect the following types of information when you use the App:

a. Personal Data

Account Information: When you register for an account, we may collect your name, email address, phone number, and address to facilitate event registration, membership management, or workshop participation.
Event Participation: Details such as your registration for HKHA events, workshops, or competitions (e.g., Hong Kong International Chromatic Harmonica Competition).
User Content: Any data you voluntarily submit, such as feedback, comments, or music-related submissions for community features.

b. Non-Personal Data

Usage Data: Information about how you interact with the App, such as pages viewed, features used, and time spent on the App.
Device Information: Details about your device, including device type, operating system, unique device identifiers, and IP address.
Analytics Data: Aggregated data collected via third-party analytics tools (e.g., Google Analytics) to understand App performance and user behavior.

c. Optional Data

Push Notifications: If you opt-in, we may collect data to send you notifications about upcoming events, workshops, or new music content.
Location Data: If you enable location services, we may collect approximate location data to provide location-based event recommendations (optional and with your consent).

3. How We Use Your Information

We use your information to:

Provide and improve App functionality, such as event registration, music resource access, and community features.
Communicate with you about HKHA events, workshops, competitions, or membership updates.
Process registrations and payments for events or memberships (if applicable).
Send push notifications about relevant updates (if you opt-in).
Analyze App usage to enhance user experience and optimize performance.
Comply with legal obligations under Hong Kong laws, including the Personal Data (Privacy) Ordinance (PDPO).

4. How We Share Your Information

We do not sell or rent your personal data. We may share your information in the following cases:

Service Providers: With trusted third-party providers (e.g., payment processors, cloud storage, or analytics services) who assist in operating the App, subject to strict confidentiality agreements.
Event Partners: With co-organizers or sponsors of HKHA events (e.g., City Chamber Orchestra of Hong Kong) to facilitate event management, with your consent where required.
Legal Compliance: When required by law, court order, or government authority to disclose information.
Public Content: Any content you voluntarily share in public App features (e.g., community forums) may be visible to other users.

5. Data Security

We implement reasonable technical and organizational measures to protect your personal data from unauthorized access, loss, or misuse. These include:

Encryption of sensitive data during transmission (e.g., SSL/TLS).
Secure storage of data with access restricted to authorized personnel.
Regular security assessments of our systems.

However, no system is completely secure, and we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials.

6. Your Rights

Under the Personal Data (Privacy) Ordinance (PDPO), you have the right to:

Access: Request a copy of the personal data we hold about you.
Correction: Request correction of inaccurate or incomplete personal data.
Deletion: Request deletion of your personal data, subject to legal obligations.
Objection: Object to certain uses of your personal data, such as direct marketing.

To exercise these rights, contact us at info@hkharmonica.org. We will respond within 40 days, as required by the PDPO.

7. Third-Party Services

The App may include links to third-party websites or services (e.g., URBTIX for ticket purchases, Google Play Store for updates). These third parties have their own privacy policies, and we are not responsible for their practices. We encourage you to review their policies before providing personal data.

8. Children’s Privacy

The App is not intended for users under the age of 13. We do not knowingly collect personal data from children under 13. If we learn that we have collected such data, we will take steps to delete it promptly. Parents or guardians who believe their child has provided personal data should contact us at info@hkharmonica.org.

9. International Data Transfers

Your personal data may be stored or processed outside Hong Kong, such as by cloud service providers in other jurisdictions. We ensure that such transfers comply with PDPO requirements and that appropriate safeguards (e.g., contractual agreements) are in place to protect your data.

10. Retention of Data

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with legal obligations. For example:

Account data is retained while your account is active and for a reasonable period thereafter.
Event registration data is retained for the duration of the event and related administrative needs.
Analytics data is retained in aggregated, anonymized form.

11. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via the App or by email (if provided). The updated policy will be effective upon posting, with the “Last Updated” date revised.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Hong Kong Harmonica Association
Email: info@hkharmonica.org
Address: 10/F, Caltex House, 258 Hennessy Road, Hong Kong
Phone: +852 8102 6258

For complaints, you may also contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.