Privacy Policy

1. Introduction

The Hong Kong Jockey Club FORTIFY Health Programme (“FORTIFY”, “we”, “us”, or “our”) is committed to protecting the privacy of all participants. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our web application, WhatsApp services, and participate in programme activities.

2. Data We Collect

We collect the following categories of personal data:

• Identity data: name, email address, phone number, Hong Kong Identity Card number (for verification).
• Health data: physical assessment results (grip strength, bone density, cardiovascular fitness, body composition), DEXA scan results, and self-reported health metrics.
• Behavioural data: questionnaire responses about physical activity, nutrition, sleep, and wellbeing.
• Programme data: event bookings, attendance records, mission progress, and points earned.
• Communication data: messages exchanged with our WhatsApp chatbot, including message content and timestamps.
• Technical data: IP address, browser type, and device information for security and system administration.

3. How We Use Your Data

Your personal data is used to:

• Verify your identity and manage your programme account.
• Facilitate event bookings, attendance tracking, and health assessments.
• Provide personalised health feedback and programme recommendations.
• Enable communication through our WhatsApp chatbot service.
• Conduct health research and statistical analysis (using de-identified data).
• Send programme-related notifications and reminders.
• Ensure the safety and security of our platform.

4. WhatsApp Communication

Our programme uses WhatsApp (via Meta’s WhatsApp Business Platform) for phone verification and chatbot communication. When you interact with our WhatsApp service:

• Your phone number and message content are processed to provide the service.
• Messages are stored securely to maintain conversation context and improve service quality.
• Meta (WhatsApp’s parent company) processes message delivery in accordance with their own privacy policy.
• We do not share your message content with third parties except as required for programme operations.

5. Data Storage and Security

All personal data is stored securely using industry-standard encryption and access control measures. Data is stored on servers located in regions that provide adequate data protection standards. Access to identifiable personal data is restricted to authorised programme staff and researchers.

6. Data Retention

Your personal data will be retained for seven (7) years following the completion of the programme, after which it will be securely destroyed. Anonymised data may be retained indefinitely for research purposes.

7. Your Rights

Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate personal data.
• Request deletion of your personal data (subject to legal retention requirements).
• Withdraw from the programme at any time without penalty.

8. Third-Party Services

We use the following third-party services to operate the programme:

• Meta (WhatsApp Business Platform): for phone verification and chatbot messaging.
• Cloud hosting providers: for secure data storage and application hosting.
• AI language models: to power our programme-specific chatbot assistant for health enquiries, event booking, and programme support (no personally identifiable information is included in AI prompts).

9. Changes to This Policy

We may update this Privacy Policy from time to time. Participants will be notified of material changes. Continued use of our services after notification constitutes acceptance of the revised policy.

10. Contact Us

If you have questions or concerns about this Privacy Policy or your personal data, please contact:

HKJC FORTIFY Health Programme
Email: fortify@hkjc.org.hk