PRIVACY POLICY

www.jumpstarter.hk (the “Site”) is a website of The Alibaba Entrepreneurs Fund, an initiative of Alibaba Group, comprised of The Hong Kong Entrepreneurs Fund Limited and The Taiwan Entrepreneurs Fund Limited established under the laws of the Cayman Islands (together, “Alibaba Entrepreneurs Fund”, the “Fund”, “we”, “us”, etc.)

Throughout 2019-2020, we are organizing a series of events such as the JUMPSTARTER Contest (as defined in the JUMPSTARTER Terms and Conditions), startup showcase, business networking, student entrepreneurship education, mentor / investor hour, corporate innovation education and entrepreneurship workshop to support the career development and entrepreneurial aspirations of young people through the Alibaba ecosystem (the “JUMPSTARTER Events”).

This Privacy Policy is incorporated into the JUMPSTARTER Disclaimers (“Disclaimers”) by reference. Any terms used in this Privacy Policy will have the same meanings as those in the Disclaimers unless otherwise specified. This Privacy Policy only applies to the information collected, stored, and used from our Services by us, and does not apply to information collected through any third party services that you may access through our Services.

We recognizes the importance of privacy as well as the importance of maintaining the confidentiality of personal information. This Privacy Policy applies to all products and services provided by us and sets out how we collect, use and disclose information in relation to users of the Site. This Privacy Policy also applies to use of the Site via a mobile device, either through mobile applications or mobile-optimized websites.

1. COLLECTION OF INFORMATION

Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than is necessary for us to provide you with our services and to protect your account:

When you submit an application to participate in any of the JUMPSTARTER Events, you may provide us information such as your name, address, phone number, email, school, company name, marital status, nationality, gender, date and/or year of birth. When you submit an inquiry or application to our programs, you may also provide us content such as your proposal, resume, and comments (“User Generated Content”). If you participate in any JUMPSTARTER Events, in addition to the information mentioned above, we may also collect your live stream videos, your social media account names and profile photos, and posts or comments made by the Site’s members. Certain data we collect may be defined as personal data under applicable data protection law (“Personal Data”).

If you prefer not to provide such information, the use of our services and your participation in JUMPSTARTER Events will not be affected.

If you contact us, we may record your conversation with us and collect additional information to verify your identity.

2. USE OF PERSONAL DATA

We shall use your personal data in accordance with the personal information collection statement provided by us to you on or before the time of collection of your personal data. Such use may include: we may use your information we collect to pursue our mission and operations and to engage in the activity and related activities for which we collect it. Specifically, we collect and use your Personal Data for the following purposes:

  • verifying your identity
  • verifying your eligibility to register as a user of the Site or to participate in the JUMPSTARTER Events;
  • processing your registration as a user, providing you with a log-in ID for the Site and maintaining and managing your registration;
  • responding to your queries, feedback, claims or disputes;
  • assessing account security, detecting and preventing fraud and other security incidents
  • fulfill our obligations to you and to respond to any questions or requests from you; to contact you about material changes in our Site, terms or policies; to comply with the applicable law(s) or in good faith belief that such action is necessary to conform with the requirements of applicable law(s) or to comply with legal process served on us;
  • provide to third parties as a result of any reorganization process; and
  • if you apply for the JUMPSTARTER Events and Fintech Global Competition, we will use your Personal Data and User Generated Content you provide to find out about you and share it with service providers and other third parties we view as relevant to the program for which you are applying.

Cookies or other similar technologies may be used to provide you with advertising based upon your browsing activities and interests (see section 5. COOKIES below). Where we are required by applicable law, we will seek your consent prior to sending you communications for marketing purposes.

We may also use your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.

3. DISCLOSURE OF PERSONAL DATA

We may disclose and transfer (whether within or outside the jurisdiction of the Alibaba entity that is the controller) your Personal Data to our partners and to service providers engaged by us to assist us to provide services to you or who otherwise process Personal Data for purposes described in this Privacy Policy or notified to you when we collect your Personal Data.

These service providers must abide by our data privacy and security requirements and are only permitted to use your Personal Data in connection with the purposes specified above, and not for their own purposes.

For the purposes specified above, we may share your Personal Data with affiliated companies in the Alibaba Group and/or their designated service providers, which comprises a group of companies operating leading online and mobile marketplaces in consumer and business-to-business commerce, as well as cloud computing and other services.

When we believe it is necessary to comply with applicable laws or to exercise, establish or defend our legal rights or protect your vital interests or those of any other person, we may also disclose and transfer your Personal Data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations.

We may also disclose your Personal Data to any other person with your consent to the disclosure.

We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws.

Information you submit to the Site for publication may be made publicly available on the Site and therefore accessible by any internet user. You should exercise caution when deciding what information you submit to us for publication.

We may provide aggregated or anonymized data to third parties, but when we do so, the information we share is in a de-identified format that does not personally identify you.

4. RIGHTS REGARDING PERSONAL DATA

Under the applicable laws, you may have the rights of access to Personal Data held by us and other rights. If you are a Visitor from the European Union, please refer to section 14. VISITORS FROM THE EUROPEAN UNION below for more information.

If you have any questions regarding this Privacy Policy or if you wish to access or correct your Personal Data as a user of the Site, you may send your request to js-support@ent-fund.org.

If and to the extent permitted by applicable law, we may charge you a fee for the processing of any request you make regarding your Personal Data.

5. COOKIES

We use "cookies" to store specific information about you and track your visits to the Site, either through a compute or via a mobile device. It is not uncommon for websites to use cookies to enhance identification of their visitors.

A "cookie" is a small amount of data that is sent to your browser and stored on your computer's or mobile device’s hard drive. If you do not de-activate or erase the cookies, each time you use the same browser or mobile device to access the Site, our web servers will be notified of your visit to the Site and in turn we may have knowledge of your visit and the pattern of your usage. The cookies will enable us to remember your information so you do not have to re-enter it every time you use the Site.

In addition, we use cookies to manage the security of our Site, to gather information about usage by users; to research visiting patterns and conduct interest-based advertising; to assist our partners to track user visits to the Site and process orders; and to track progress and participation in JUMPSTARTER Events.

For these additional purposes identified above, you can determine if and how a cookie will be accepted by configuring the privacy setting of the browser you are using to access the Site or the privacy setting of your mobile device. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser's help menu for more information. If you adjust the privacy setting in the browser, your mobile device will continue collecting data unless you adjust the privacy setting of the device, and vice versa.

You have the right to decide whether to accept or reject cookies. If you choose to set your web browser controls to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com

Certain features of the Site depend on cookies. Please be aware that if you choose to block cookies, you may not be able to sign in or use those features, and preferences that are dependent on cookies may be lost.

We use two types of cookies: session cookies (which are erased once you close the browser or shut down the device) and persistent cookies (which remain even after closing the browser or shutting down the device/application and which are activated each time you visit the Site). The session cookies use encrypted data to unambiguously authenticate you. The persistent cookies do not store account numbers or passwords.

We use both first party cookies (cookies that are set by us and serve mainly to enable basic functionality on our Site, including web analytics cookies that help us understand how users use our web pages and how we can improve their use) and third party cookies (these cookies are not set by us, but by our selected partners).

In addition, we also use social media cookies. Some pages on our Site allow you to "share" content through social media such as Facebook and Twitter. Sometimes we embed videos from websites like YouTube. These websites set their own cookies on which we have no influence. To refuse their cookies, please follow the instructions on their websites. In addition, these websites have their own privacy policy, which you can find on the respective websites.

Our Site uses Google Analytics, an internet analytics service provided by Google, Inc., 1600 Amphitheater Parkway Mountain View, California, 94043, USA ("Google"). Google Analytics uses "cookies", which are text files that are stored on your computer and used to analyze the use of the Site. For example, Google's cookies allow us to tell us which pages our users are viewing, which ones are most popular, what time of day our Site are visited, if users have previously visited our Site, from which website users are redirected to our Site were and the like. The data generated by the cookies about your use of the Site will be transmitted to Google and stored by Google on servers in the United States.

We use an anonymization tool of IP addresses so that the IP addresses are truncated within the territory of the Member States of the European Union and the other members of the agreement on the European Economic Area. The non-truncated IP address are only exceptionally transmitted to Google’s servers in the US and then truncated there.

Google uses the data on behalf of the website operator to evaluate your use of the website, to compile reports on website activity for the website operators and for other website activity and internet usage services. Google may disclose this information to third parties under the terms of the law or for further processing by third parties on behalf of Google.

For more information about Google Analytics cookies, visit the Google Help pages and Privacy Policy:

Google Privacy Policy: https://policies.google.com/privacy

Google Analytics Help Center: https://developers.google.com/analytics/devguides/collection/analyticsjs/cookies-usage

The IP address that your browser will pass on to Google Analytics will not be associated with any other data stored by Google. Through your browser settings, you can block cookies; however, this can lead to problems with the use of some functionalities of our website. Through the add-on "Google Analytics Opt-out" you can through your current web browser opt-out to the use of Google Analytics from then on: http://tools.google.com/dlpage/gaoptout?hl=en.

More information can be found here: https://support.google.com/analytics/answer/6004245.

6. MINORS

The Site and their contents are not targeted to minors (those under the age of 18). Minors should only provide Personal Data with parental or guardian consent. If a minor has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact js-support@ent-fund.org to remove the information. Specifically, we do not intend to collect Personal Data from children under the ages of thirteen (13). Please contact us if you believe that we may have Personal Data from children under the ages of thirteen (13), and we will investigate promptly and remove such information upon confirmation.

7. SECURITY MEASURES

We employ commercially reasonable security methods to prevent unauthorized access to the Site, to maintain data accuracy and to ensure the correct use of the information we hold.

For registered users of the Site, some of your information can be viewed and edited through your account, which is protected by a password. We recommend that you do not divulge your password to anyone. Our personnel will never ask you for your password in an unsolicited phone call or in an unsolicited email. If you share a computer with others, you should not choose to save your log-in information (e.g., user ID and password) on that shared computer. Remember to sign out of your account and close your browser window when you have finished your session.

No data transmission over the internet or any wireless network can be guaranteed to be perfectly secure. As a result, while we try to protect the information we hold for you, we cannot guarantee the security of any information you transmit to us and you do so at your own risk.

8. YOUR RIGHT TO OPT OUT

You understand that we may use the information you provide to us to send emails and newsletters to you. If you no longer wish to receive these communications, you can do so by following the instructions to unsubscribe set forth in our communication we send to you, or contact us.

9. THE INFORMATION WE DO NOT INTEND TO COLLECT

Some Personal Data such as your mental health condition, sexual orientation, medical history, or criminal record is considered “sensitive” in some jurisdictions, and is subject to heightened regulation than the other types of Personal Data. We do not intend to collect such sensitive Personal Data from you and any such sharing of sensitive Personal Data is entirely at your own sole discretion and risk.

Do not supply Personal Data about others unless you are authorized or required to do so by applicable law or contract and you consent to the Disclaimers and this Privacy Policy on behalf of yourself and the person(s) about whom you supply Personal Data (“Data Subject”). Before supplying Personal Data about others (except as otherwise allowed by law or contract), you must make available for the Data Subject’s review, and obtain their written consent to, said Disclaimers and Privacy Policy. By submitting any Personal Data about others, you represent and warrant that you are authorized to do so and that you did all of the foregoing before submitting the information. If applicable law allows you to supply the information without doing the foregoing, you represent and warrant that you have abided by such applicable law and that it allows us to receive and disclose the information under this Policy without any further action on our part. You agree to indemnify, defend and hold us harmless against any failure by you to comply with this paragraph.

10. YOUR PARTICULAR CONSENT

You are giving us the following particular express, voluntary, and informed consent to a few activities relating to your Personal Data that is disclosed in furtherance of our mission and operations, or for a purpose directly related to such purpose:

  1. Consent to International Transfer and Disclosure of Personal Data. We are involved in programs and activities in a variety of countries. You agree that the Foundation and those with whom we share your Personal Data (“Recipients”) may disclose and transfer your Personal Data worldwide to our affiliates, sponsors and partners, and any other third party service providers for any purpose to further our mission and operations.
  2. Consent to Electronic Notice If There is a Security Breach: We will safeguard your Personal Data and prevent such information from unauthorized access, disclosure, or use. If we or a Recipient is required to provide notice of unauthorized access to or other invasion of certain security systems, you agree that we (or they) may do so when required (or voluntarily) by posting notice on our Site or sending notice to any email address we have for you, in our (or their) good faith discretion. You agree that notice to you will count as notice to others for whom you are acting, and agree to pass the notice on to them.
  3. Media Consent: You provide the following consent to the Fund, its affiliates and sub-licensees to take photos, digital images, audio and/or video footages of you, and to use your Image (defined below) in any form of media for the purpose of promoting the Fund, Venture Hours and/or Hong Kong entrepreneurship. The term “Image” refers to the full set of attributes of your personality, including but not limited to your image, voice, family name and forenames, signature and business name / logo. You grant the Fund an exclusive, worldwide, perpetual, irrevocable, unrestricted, royalty-free, assignable, transferable and fully sub-licensable license to all present and future rights, title and interest in all intellectual property (including, without limitation, any trademark, copyright, publicity, and database rights, and the right to prepare derivative works) you have in your Image, to store use, reuse, edit, modify adapt, reproduce, display, host, publish, circulate, or distribute your Image as the Fund deems appropriate in its sole and absolute discretion. You represent and warrant that you have all rights to grant such licenses to us without infringement or violation of any third party rights. The Fund is not obligated to submit any promotional and other materials to you, or your organization for approval, or to produce, distribute or utilize any of the rights granted herein. You irrevocably and unconditionally waive any and all moral and similar rights vesting in your Image to the extent legally permissible.

11. RETENTION PERIOD

We keep Personal Data for as long as we think is necessary or advisable and we reserve the right to retain it to the full extent not prohibited by law. We may discard Personal Data in our discretion, so you should retain your own records, and not rely upon our storage of any Personal Data, content, or other data.

Subject to applicable laws and regulations, you may have the right to inquire and request for a review of, request a copy of, make supplements or corrections to, discontinue collection, processing or use of, or request to delete some or all of your Personal Data at our possession. Please contact us if you have any inquiries as to what information we have concerning you, and submit your new information if your Personal Data has changed.

12. ENGLISH VERSION PREVAILS

In the event of any discrepancy between the English version and the Chinese version of these Disclaimers, the English version shall prevail.

13. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. Any changes to this Privacy Policy will be communicated by us posting an amended Privacy Policy on the Site. Once posted on the Site, the new Privacy Policy will be effective immediately. You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.

14. VISITORS FROM THE EUROPEAN UNION

This section of the Privacy Policy applies only if you use our Site or services covered by this Privacy Policy from a country that is a Member State of the European Union, and supplements the information in this Privacy Policy.

If you are in the EEA, your controller is The Hong Kong Entrepreneurs Fund Limited (incorporated in Hong Kong). For contact details, please see section 15 below “How to contact us”.

(i) Legal Basis for Data Processing

We process Personal Data for the purposes set out in this Privacy Policy, as described above. Our legal basis to process Personal Data will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect and process Personal Data about you only where it is: necessary for the performance of any contract between you and the Fund (for example, to provide you with the services you request and to identify and authenticate you so you may use the Site); necessary to comply with legal requirements (for example, to comply with applicable accounting rules and to make mandatory disclosures to law enforcement); necessary for our legitimate interests and not overridden by your rights; and/or where it is based on your consent.

If we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), this interest will normally be to operate our Site and services, manage our relationship with you and communicate with you as necessary to provide our services to you and for our legitimate commercial interest, for instance, when responding to your queries, improving our Site and our services, undertaking marketing, or for the purposes of ensuring the security of our Site and services and detecting or preventing illegal activities such as fraud. We may have other legitimate interests and if appropriate we will make clear to you at the relevant time what those legitimate interests are.

If we ask you to provide Personal Data to comply with a legal requirement or to enter into a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). In some instances, you may be required to provide us with Personal Data for processing as described above, in order for us to be able to provide you all of our services, and for you to use all the features of our Site.

We retain your Personal Data as long as we have an ongoing legitimate business need to do so for example to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws. When we have no ongoing legitimate business need to process your Personal Data, we will either delete or anonymise it or, if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion is possible.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided under section 15. HOW TO CONTACT US below.

(ii) International Transfers of Personal Data

Our business may require us to transfer your Personal Data to countries outside of the European Economic Area (“EEA”), including to countries that may not provide the same level of data protection as your home country such as the United States and China. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement appropriate measures to ensure your Personal Data will remain protected in accordance with this Privacy Policy, such as standard contractual clauses. A copy of those clauses can be obtained by contacting js-support@ent-fund.org.

(iii) Your Rights

If you are a resident of the European Economic Area, you have the following data protection rights, which you can exercise at any time by contacting us using the contact details provided under section 15. HOW TO CONTACT US below:

  • The right to access, correct, update or request deletion of your Personal Data.
  • The right to object to processing of your personal information when it is based on our legitimate interests, and separately the right to object to direct marketing.
  • The right to ask us, in some situations, to restrict processing of your personal information or request portability of your personal information.
  • The right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under section 15. HOW TO CONTACT US below.
  • If we have collected and process your personal information with your consent, then you have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

15. Contact Us

You may write to us at js-support@ent-fund.org for any privacy concerns and requests relating to these Disclaimers, this Privacy Policy, or our Site and Services.