We respect your privacy in our Minisport sessions; and in your use of our websites and online services. We are committed to protecting your privacy through this privacy policy. The following core principles guide our decisions around data, security, and technology:

• We collect, store, process and share personal information only for the purposes of providing our Services, or as authorized by a student, parent, or school
• We do not sell, use or share personal information or content for marketing or advertising purposes, unless with consent
• We will maintain a comprehensive data security program designed to protect the types of personal information
• We will delete or de-identify personal information at the direction or request of the student, parent, or school
• We will clearly and transparently disclose our data policies and practices
• We will provide notice before any personal information is used in a materially different manner than was disclosed when the information was collected

1. Our commitment to your privacy

Minisport HK LTD (“Minisport”),  are committed to protecting the privacy of our customers. The Minisport privacy policy (herein referred to as “Privacy Policy”) applies to all personal information collected by us, or submitted to us, whether offline or online, including personal information collected or submitted through our websites (our “websites”) through our official social media pages that we administrate (our “Social Media Pages”) as well as through third-party websites and email messages that we send to you (collectively, including the social media pages, apps, emails, and third-party websites, the “sites”). By visiting the sites, you are accepting and consenting to the practices described in this privacy policy. If you disagree with parts or all of the terms of this privacy policy, please do not use the website or submit any personal information.

This Privacy Policy explains our practices regarding the collection, use, disclosure, and protection of personal information that is collected by Minisport, through our websites and our online services (collectively, our “Services”), as well as your choices regarding the collection and use of information.

Your use of the Services constitutes your agreement to the Terms of Use and to this Privacy Policy.

“You” or “your” means a User of the Services. An “Individual User” as used in these Terms may be a student, parent, coach or school administrator using the Services. Where applicable, “you” or “your” also means any other educational institution otherwise known as an “Enterprise User”, with whom the User is associated, or parent of a student and is authorized by the Enterprise User to use the Services (an “Authorized User”). The term “User(s)” as used herein will refer to all users of the Services: Individual Users, Authorized Users, and Enterprise Users. In this Privacy Policy, we use the term “Partner School” to refer to teachers, principals, school districts/boards, school administrators and any other User acting on behalf of an educational institution that is not part of the Minisport network.

2. Personal Information

What is Personal Information?

"Personal Information" is information or pieces of information that could allow you or your child to be personally identified such as:

• Name
• Child's name
• Child's age / DOB
• User name
• Postal Address
• Telephone Number
• Email Address
• Credit and debit card number
• Profile picture
• Social media account ID
• Program preferences
• IP address
• Browser and device information
• Information collected through cookies, pixel tags and other technologies
• App usage data
• Medical records (e.g. immunizations, food sensitivities)
• Emergency contact

Personal information does not include “aggregate” information. Aggregate information is data we collect about a group or category of products, services or users, from which individual user identities have been removed. In other words, information about how you use a service may be collected and combined with information about how others use the same service. Aggregate data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor the Services.

How do we collect Personal Information?

We and our service providers may collect Personal information in a variety of ways, including:

• With consent. We share Personal Information with consent and at the direction of schools, students and parents. A User may direct us to share specific information with another individual, for example, if a coach directs us to send a communication to a parent, or an Enterprise User may be able to control data sharing functionality for all User accounts within our system. Parents of students should contact their child’s school with any questions about Partner School-authorized data sharing functionality.
• With our trusted vendors and third party service providers. We may share Personal Information with certain trusted vendors, third party service providers and individuals to perform tasks on our behalf, but strictly for the purpose of carrying out their work for us, which may include payment systems, business development, software design, hosting, customer support, accounting, and other similar services. Personal Information will be shared with these third parties as reasonably needed to perform their services to us, and under reasonable confidentiality terms.
• We may share Personal Information with other companies owned by or under common ownership with Minisport. These companies will use your Personal Information in the same way as we can under this Privacy Policy.
• Aggregate Data. We will share information in an aggregated and/or anonymous form that does not reasonably identify you directly as an individual. For example, we may share aggregate data with other students, parents or Schools to display statistical data related to students in particular classes, or geographic locations. We may also use aggregate or anonymized data to study and improve our Services, user functionality, and product offerings.
• We may disclose your Personal Information as required or authorized by law or subpoena or if we have a good faith belief that disclosure is necessary to (i) comply with the law or a judicial proceeding, court order, or legal process served on us; (ii) to comply with or the lawful request of law enforcement; (iii) to enforce or apply our Terms of Service or other agreements or to protect the security or integrity of our Services; and/or (iv) to exercise or protect the rights, property, or safety of our students and their families; Minisport and its affiliates, our employees, our Users, or others.
• If Minisport or some or all of its assets are acquired or otherwise transferred to a third party in the course of a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control, bankruptcy or other corporate event, the Personal Information of our users may be transferred to or acquired by a third party, but only if such third party agrees to be subject to the same commitments set forth in this Privacy Policy with respect to user personal information. If the transaction involves the transfer of any Personal Information pertaining to a student at Minisport or a Partner school (“Student Data”) to a third party, we will provide you with notice and an opportunity to opt-out of the transfer of Student Data by terminating your account before the transfer occurs.
• To respond to your inquiries and fulfill your requests, such as to send you newsletters, information or to respond to your questions and comments.
• To send administrative information to you, for example, information regarding the sites and changes to our terms, conditions, and policies. Because this information may be important to your use of the sites, you may not opt-out of receiving these communications.
• To complete and fulfill your purchase, for example, to process your payments, have your order delivered to you, communicate with you regarding your purchase and provide you with related customer service.
• To provide you with updates and announcements concerning our products, promotions and programs and to send you invitations to participate in special programs.
• To allow you to contact and be contacted by other users through the Sites, as permitted by the applicable site.
• To permit you to participate on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials (including our social media pages).
• For our business purposes, such as analyzing and managing our businesses, market research, audits, developing new products, enhancing our sites, improving our services and products, identifying usage trends, determining the effectiveness of our promotional campaigns, tailoring the sites experience and content based on your past activities on the sites, and gauging customer satisfaction and providing customer service (including troubleshooting in connection with customer issues).
• We use information collected by browsers or your device for statistical purposes as well as to ensure that the sites function properly.
• We may use your device’s physical location to provide you with personalized location-based services and content. We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns.
• As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
• Your personal data will be processed by Minisport both within and outside Hong Kong S.A.R., primarily for the purpose of enrollment in our programmes and the use of our websites and apps, and for customer service and marketing activities. Because our central offices are located in Hong Kong, and our sessions located globally, we may share your personal data with our service providers both within and outside Hong Kong. The service providers that we share information with are only such that need access to the personal information to process the order that you have placed on the sites, such as transportation assistance, accommodation, or schools, and they will only receive the information necessary for that purpose. No service provider will receive your personal information for their own marketing purposes. Please note that the service providers may change from time to time. Minisport processes personal information in compliance with applicable privacy and data protection legislation. By using our sites, you acknowledge and consent to these potential transfers. Transfers will be made in accordance with the applicable legislation and we will take all necessary measures to ensure that third parties involved will provide an adequate level of protection. Any future hosting/processing organization that we use in relation to the sites will be required to do the same.

HOW WE USE AND SHARE STUDENT DATA

In addition to the actions described above, we may facilitate the sharing of Personal Information with third parties through the Services, though only when instructed and authorized to do so on behalf of Minisport, Partner Schools, the student, or parent. We will use personal information about students to provide the Services and permit data sharing among Users authorized to view and access the student Personal Information. Each student and his or her parents will only have access to view or submit information relative to that particular student. Neither students (nor their parents) will be able to view or otherwise access the personal information of other students, with the exception of name, email address, and profile picture. Additional information may be accessible if provided to that student account by Minisport or affiliates. We only share student data for purposes of providing the educational Services to and at the direction of the Minisport or affiliates, parents, and students.

3. Security

We use reasonable organizational, technical and administrative measures to protect personal information under our control. Unfortunately, no data transmission over the internet or data storage system can be guaranteed to be 100% secure.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem.

We care about the security of your Personal Information and we use commercially reasonable physical, administrative and technological safeguards to preserve the integrity and security of all information we collect and that we share with our service providers. Our employees and contractors are bound to uphold the provisions in this Privacy Policy. We maintain physical, electronic, and procedural safeguards that are designed to protect our Users’ personal information. We use internet security best practices to transfer Personal Information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to buildings and files. You can help protect against unauthorized access to your account limiting access to your computer and browser by signing off after you have finished accessing your account.

By using the Services, you consent to the transfer of your Personal Information to Hong Kong S.A.R., in accordance with this Privacy Policy. In addition, if you access your data from overseas some of your data may be replicated to a nearby data center. You understand that your personal information will be subject to the laws of these jurisdictions, which may be different from those of your country of residence.

4. Access, modification and choices

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes.

As part of our Services, we may use your Personal Information to communicate with you about your child’s progress at school, your account or transactions with us, or send you information about updates and changes to our Services.

When you provide an email address to invite a friend or colleague or other contact to join the Services, we will use this information to send the invitation, and we may send 1-2 reminder emails if we have not received a response. From time to time, we may also send these individuals email communications letting them know more about our Services. The recipients may unsubscribe from these emails by clicking on the “unsubscribe from this list” button within the body of the email at any time or by email to support@minisport.hk.

If at any time you wish to stop receiving marketing communications from us, the easiest way to do so would be to use the unsubscribe feature in the marketing communication you received. You may also let us know by emailing, calling or writing to us using the contact information listed below in the “contact us” section. In your request, please indicate that you wish to stop receiving marketing communications from us.

In addition, we will not disclose your Personal Information to third parties, including our subsidiaries, for the third party’s direct marketing purposes if we have received and processed a request from you that your Personal Information should not be shared with third parties for that purpose. If you would like to submit such a request, please just let us know by email support@minisport.hk. Please clearly indicate that you request that we do not disclose your Personal Information to our subsidiaries and/or other third parties for their direct marketing purposes.

Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as reasonably practicable and in no event later than 30 days after we received your request. Please also note that if you opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

COMMUNICATIONS WITH STUDENTS

We use Personal Information to facilitate the sending of communications relating to the Services to and from Minisport or affiliates, students, and parents. We send these communications only on behalf of, and at the direction of the Minisport or affiliates, students or parents. In limited circumstances, we may also send the student notifications regarding the student’s account and use of the Services, but we will never use Personal Information for advertising or marketing purposes without consent. Please note that all Users who have been authorized to have access to a student’s account, which could include a parent, student, school administrator, coach and/or other User, may be able to view activity and content associated with such student account, including the content of communications.

5. Updates and Corrections

To review, correct, update, suppress, delete or otherwise limit our use of your personal information that has been previously provided to us, please send an email to support@minisport.hk and clearly describe your request. In your request, please make clear what information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information.

We will try to comply with your request as soon as reasonably practicable. Note that despite our efforts, there may be residual information that will remain within our databases and other records, which will not be removed or changed. Further, please note that we may need to retain certain information for record-keeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such purchase or promotion).

6. Third party sites

This privacy policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which our websites contain a link. The inclusion of a link on our websites does not imply endorsement of the linked site by us or by our affiliates.

Additionally, we may provide you with access to third-party functionality that permits you to post content to your social media account(s). Please note that any information that you provide through use of this functionality is governed by the applicable third party’s privacy policy, and not by this privacy policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality.

We are also not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as facebook, apple, google, microsoft, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including any personal information you disclose to other organizations through or in connection with the apps or our social media pages.

7. Retention period

We will retain your personal information for the period necessary to fulfill the purposes outlined in this privacy policy and meet other legal and business requirements.

8. Children's privacy

We do not knowingly collect personal information through the Services from a child without parental consent. When personal information is collected, we request to obtain appropriate parental consent and authorization for a student to use the Service and for us to collect information from such student. Please contact us at support@minisport.hk if you believe we have inadvertently collected personal information from a child without proper consents so that we may delete such information as soon as possible.

9. Links to other websites

The Services and our email communications may contain links to other websites or services offered by Minisport or its affiliates. Any Personal Information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. Except as described above, we are not responsible for the content or privacy and security practices and policies of websites to which we link. Links from the Services to third parties or to other sites are provided for your convenience. We encourage you to learn about their privacy and security practices and policies before providing them with Personal Information.

10. Updates to this privacy policy

We may change this privacy policy. Any changes to this privacy policy will become effective when we post the revised privacy policy on a site. Your use of the sites following these changes means that you accept the revised privacy policy.

11. Service development

The Services are under continuous development and testing. Any Services that are software-based may contain bugs and other errors that could adversely affect the use or performance of the Services. Issues or errors of this nature may impact our ability to comply with this privacy policy.

12. Contact us

We welcome your feedback. If you have any comments or concerns about this privacy policy or would like to contact us for any reason, you may reach us at support@minisport.hk.

Updated: Oct 25, 2023