Privacy Policy

Last updated on: Wednesday, 17 January 2024

Please refer to here for details: https://www.scmp.com/terms-conditions

This sets out the policies and practices of South China Morning Post Publishers Limited and all subsidiaries and affiliated companies of which it forms part (“SCMP GROUP” or “We”) in relation to the handling of personal data.

Statement of Notice

We respect privacy. SCMP GROUP is committed to complying with all applicable personal data privacy laws and regulations.

When we collect and process personal data, we will ensure that there is legal basis for us to do so – including but not limited to issuing a Privacy Notice and/or fulfilling any other requirements as provided under all applicable laws.

Statement of Practice

Kinds of Personal Data Collected

We collect personal data in five broad categories below (“Categories of Personal Data”):

Subscription Records which include records containing the personal information of the subscribers of our publications, job alert services and any other subscription based products or services.

Personnel Records which include job applicants and our employees’ personal information.

Event Attendee Records which include the personal information provided by the attendees of our events such as conferences, promotion or charity activities.

Other Operational Records which include the personal data of such data subjects involved in news gathering, security checks, cleaning, maintenance services, consultancy, technology, auditing, supplier, service provider, licensor, and other data subjects providing services in relation to all aspects of our operations.

Records collected on/from Web Servers which include but not limited to the email addresses, location data and other online identifiers such as IP addresses of such data subjects who visit our websites and platforms.

Main Purposes of Processing Collected Personal Data

Subscription Records are processed for the purposes of: (i) provision of subscription, job alert orders and any other subscription based products or services; (ii) billing and payment (if applicable); and (iii) conducting market research for statistical purposes.

Personnel Records are processed for the purposes of: (i) recruitment; and (ii) human resources management and employment related activities such as employment benefits, termination, performance appraisal and discipline.

Event Attendee Records are processed for the purposes of: (i) organising and managing the relevant events; and (ii) running the related competitions, prize drawings, and promotions.

Other Operational Records are processed for the purposes of facilitating the effective operation of our business such as news gathering, security, maintenance, consultancy, technology, auditing, supplier, service provider, licensor, and other data subjects providing services in relation to all aspects of our operations.

Records collected from Web Servers are kept for the purposes of: (i) providing and/or improving on the news, information and related services to you; and (ii) keeping abreast of and analysing the latest trends in the global media landscape.

Data Protection Principles

All processing of personal data shall be conducted according to the data protection principles as follows:

Personal data must be processed lawfully, fairly and transparently.
Personal data can only be collected for specific, explicit and legitimate purposes.
Personal data must be relevant and limited to what is necessary for processing.
Personal data must be accurate and kept up to date with every effort to erase or correct.
Personal data must be kept in a form such that the data subject can only be identified if it is necessary for processing.
Personal data must be processed in a manner that ensures the appropriate security.

Data Inventory

We have also kept a data inventory and data flow process to determine various aspects of our data processing including:

Business processes that use personal data.
Purposes for collecting and/or using the personal data.
Source of personal data.
Processing activities
Any data transfer, and to whom.
Any data access, correction or opt-out request

Such data inventory would facilitate SCMP GROUP in tracking its data and the related processing activities, and put us in a better position to comply with the relevant privacy and other laws and regulations.

Legal Basis of Data Processing

We ensure that there is legal basis for our processing of personal data.

Such legal basis includes: (i) legitimate business interests of SCMP GROUP in processing personal data; (ii) if required by applicable laws or regulations, seeking your specific consent to process such personal data; and/or (iii) any other relevant basis under applicable laws and regulations.

Legitimate Interests

SCMP GROUP processes personal data under the “legitimate interests” legal basis which means that the processing of the personal data is necessary for the legitimate interest pursued by SCMP GROUP except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which requires the protection of personal data.

Legitimate Interests Assessment

In each relevant situation, we assess: (i) what these legitimate interests are; (ii) whether it is necessary to process such data to attain the objective; and (iii) the relevant rights of the data subjects; and balance such rights against our interests in achieving such objective, and ensure that such rights do not override SCMP GROUP’s legitimate interests before we conclude that SCMP GROUP can process the personal data on the basis of legitimate interests.

Communicate with the Data subjects

All data subjects will be informed that we are collecting their personal data, the Categories of Personal Data concerned and the purpose of processing. This is to ensure that the data subjects are clear about our collection and processing of personal data and such collection and processing are within the data subjects’ reasonable expectations.
Please be informed that all data subjects can object to our collection and processing of their personal data at any time, in addition to their rights of requesting for accessing and/or correcting their personal data in our possession.

Data Security Mechanisms

We have also implemented appropriate mechanisms, policies and procedures to protect the confidentiality and security of the personal data that we collect and process, as we respect the privacy and related rights of the data subjects relating to such personal data by reducing the risks or potential negative impact of processing including but not limited to data minimisation, de-identification, encryption, restricted access and all other technical security methods and efforts to protect personal data. Such protection of the privacy and related rights of the data subjects would enable SCMP GROUP in processing personal data under the legitimate interest legal basis.

Having conducted the above assessment thoroughly, SCMP GROUP concludes that it is collecting and processing personal data under legitimate interest as follows:

a. Serving Customer and Operational Needs

The main purposes for processing the Categories of Personal Data have been set out above. There are legitimate interests for SCMP GROUP to process the same because all such purposes are essential to SCMP GROUP serving its customers and its operational needs as a corporation and a media organisation.

A corporation like SCMP GROUP needs employees to work for its business (and hence Personnel Records) and service providers to keep it running (and therefore Other Operational Records).

A media organisation such as SCMP GROUP needs the personal data of its newspaper subscribers, event attendees and website visitors so as to be able to have relevant and timely provision of information and/or other services (and thereby subscription and event attendee records together with records collected on web servers).

b. Inform the Public

As a news organisation – SCMP GROUP respects the public’s right to know about what is happening in our community and the world.   SCMP GROUP has a duty both under law and journalistic ethics to inform the public of such happenings (“duty to inform”).

We collect and process data from data subjects who visit our various web and media properties (“Public View Data”) in order to provide improved and better content experience to our data subjects.

These recommendations do not prohibit or restrict anyone from viewing all of the other articles or content on such websites which they can access at any time as available.

c. Market Analysis

We analyse the Public View Data to: (i) gain insightful knowledge of the reading habits, preferences or tastes of the public; and (ii) conduct market segmentation and related studies.

Such analysis is necessary because it enhances SCMP GROUP’s capability to carry out its duty to inform and contribute to the welfare of our international community as a global digital news organisation. The knowledge and study results from such analysis would enable SCMP GROUP to fulfil its duty to inform more effectively by providing more relevant and timely information, products, and services to the public.

This would benefit not just SCMP GROUP – but also the international society as a whole.   Our world is becoming more globalised and inter-connected. What is happening in one part of the world could have instant, far-reaching ramifications on others.

d. Direct Marketing

SCMP GROUP also uses personal data, including names and email addresses, for direct marketing purposes as part of its legitimate interests unless the data subject explicitly objects or such is otherwise specifically prohibited under applicable laws.

How you interact with SCMP GROUP’s products or services (such as news, media, advertising, events, etc.) may indicate your consumption preferences or inclinations.   Based on such preferences or inclinations, we use such personal data to conduct direct marketing in respect of various goods and/or services offered by SCMP GROUP, its affiliates or business partners including but not limited to:

Insurance, banking and financial products and services;
Products and services relating to airlines, hotel, health club, travel and hospitality;
Beauty, skin care, health, medical devices, biotechnology, pharmacy and wellness;
Eyewear and optical, fashion, sports, sports events, sports clubs, watches and jewellery, flower shop, stationery, toys, department stores and shopping malls;
IT, electronic goods and electrical appliances, mobile phones and accessories, telecommunications and media products and services;
Food and beverages and restaurants;
Design, automotive, education, antique and auction, arts and gallery, boat and accessories, services for children, real property, construction, furniture and household items, interior design, consular services, trade or industry associations, non-governmental organisations, government services, energy, events and exhibitions, personal announcements, pets and accessories, post and courier services, public utilities, professional services, career, security services, shopping, transportation and logistics.

We note that given the global spread of our businesses, there may be cases where our use of personal data for direct marketing is governed by the laws of certain jurisdictions (such as Hong Kong) which require the consent of the data subject(s) in this regard. Please refer to the “Consent” section immediately below for more information.

Consent

Where applicable legal requirement demands specific consent must be obtained before we can process personal data including conducting direct marketing, we will ensure that such specific consent will be obtained as follows:

the consent has to be clear, explicit and specific;
data subject is fully aware of the types of the personal data that we intend to use; and the purposes of such usage (such as improving our services to the data subject or direct marketing); and
the name/identity of the transferee (if we ever intend to transfer your data) and how the transferee shall use your personal data.

Cookies

We use cookies and other tracking technologies to collect and store your information, and to display relevant content, products, services and advertising. “Our Site” means our websites, emails, apps and other services that link to this Privacy Policy.

Cookies are data files stored on your device. Our Site places and uses cookies on your browser when you access it. We use cookies to give you a better browsing experience on our website. The information obtained helps us customize our products/services and assess the effectiveness of our online content and advertising campaigns.

Some types of data collected may include browsing behavior, device information, and interaction patterns. This information might be shared with certain classes of third parties, such as our advertising partners, to optimize ad targeting or improve your user experience. The data collected might be combined with other information to create user profiles for marketing or analytical purposes or track your online activities over time. We use this combined information to improve our products/services and tailor our offerings to better suit your preferences.

Different types of cookies and/or similar tracking technologies are used on Our Site by us, our service provider and/or advertising partners: –

Session Cookies: temporary cookies are only used during a visit to Our Site and will be deleted at the end of each visit. Session cookies are used to compile anonymous statistics about the use of Our Site.

Persistent Cookies: persistent cookies remain in your browser for a longer period of time for the purpose of compiling anonymous statistics about the use of Our Site and/or tracking and recording your preferences.

Essential Cookies: these cookies are essential for Our Site to function and cannot be disabled in our systems. They are typically activated only in response to actions you take that request services. For example, setting privacy preferences like the consent choice you have made, verifying your identity when logging in, remembering information you fill in forms across different pages, holding your items in the shopping cart online. You can configure your browser to block or receive alerts about these cookies, but certain areas of Our Site may not function properly as a result.

Performance Cookies: these cookies help us track how you use Our Site, like counting visits, traffic sources and revealing popular pages. They also show how you navigate Our Site, helping us enhance your experience and address any issues. By gathering this data, we improve Our Site performance and understand usage patterns. They assist in tailoring content based on aggregated user behavior patterns. For instance, we tailor suggestions based on your past interactions and preferences, and offer content we believe will appeal to you.

Preference Cookies: these cookies allow us to remember your preferences and selection. They enable us to retain information like text size, location, preferred payment method, what language you prefer on Our Site so we may display content in your chosen language each time you visit, what your user name and password are for quicker logins.

Marketing/Advertising Cookies: These cookies may be set through Our Site by us or our advertising partners. They may be used to build a profile of your interests and show you relevant adverts on other sites. This includes combining your activity here with data from other sites or apps to create a profile about your interests. This profile can later guide tailored ad displays across Our Site and other platforms.

Where you have consented to our use of cookies, you have the right to withdraw consent at any time but if you withdraw consent, we may not be able to provide a certain product or service to you.

If you have provided or rejected your cookies consent via scmp.com, you can manage it at any time by visiting Manage Consent Preference.

If you have provided or rejected your cookies consent via South China Morning Post mobile application, you can manage it at any time by accessing “Menu Bar – Setting – Manage Consent”.

For the users of Cosmopolitan.com.hk, HapersBAZAAR.com.hk, ELLE.com.hk, ELLEMen.com.hk, EsquireHK.com and Cosmart.hk; if you do consent to the use of non-essential cookies, you can withdraw your consent at any time by contacting us with email to members@scmp.com.

You may refuse to accept cookies and other tracking technologies by modifying the settings feature of your browser or internet security software. However, if you do so you may not be able to utilise or activate some of the features and/or functions of our website.

Please note that Our Site may contain links to third-party sites operated by our business partners. We are not responsible for the privacy practices of these external sites, and you are encouraged to review their respective privacy policies for information on data handling and retention.

To find out more about cookies, please visit www.allaboutcookies.org .

Rights of the Data subjects

SCMP GROUP respects that data subjects have the following rights about the data processing, and the data which is recorded about them:

To request for access regarding the nature of information held and to whom it has been disclosed.
To prevent processing likely to cause damage or distress.
To prevent processing for purposes of direct marketing.
To be informed about the mechanics of automated decision-making process which will significantly affect them.
Not to have significant decisions that will affect them taken solely by automated process.
To take action to rectify, block and erase including the right to be forgotten or destroy inaccurate data.
To request the supervisory authority (eg. a privacy commissioner or a data protection officer) to assess whether any provision of the relevant privacy and other laws has been violated.
To have personal data provided to them in a structured, commonly used and machine-readable format, and the right to have such data transmitted to another data controller.
To object to any automated profiling which is occurring.

Transfer of Personal Data

We will keep confidential the personal data that we hold, which may be transferred to the following parties within Hong Kong for the purposes as stated above

Delivery agents of SCMP GROUP for delivering the newspapers or other publications relating to the subscriptions or free trials;
Agents, contractors or third parties which/who provide administrative, technology or other services to SCMP GROUP for its operations;
Credit reference or debt collection agencies; and
Any affiliates of SCMP GROUP.

n the event of such transfer, SCMP GROUP shall use contractual or other means to ensure that the data transferees shall keep the transferred personal data confidential and comply with all relevant personal data privacy laws and regulations.

Regarding the situation as described under sub-clause (iv) above – If such intra-group transfer among SCMP GROUP affiliates involves cross-border data transfer, SCMP GROUP may adopt binding corporate rules for safeguarding the security of such personal data; and ensuring that all affiliates involved shall comply with the relevant privacy and other laws.

Outsourcing Arrangements

SCMP GROUP has been using internal resources to develop and maintain its IT systems. Occasionally SCMP GROUP engages third-party vendors to provide certain services relating to its IT systems. Such vendor does not have access to the personal data stored under usual circumstances.

In the exceptional case where such vendor has such access, SCMP GROUP uses reasonable measures to ensure that: (i) such vendor is contractually bound to keep such personal data confidential and adopt appropriate means to prevent any unauthorised access, use, loss, retention, modification, transfer or otherwise.

Data Retention

We implement data retention policies and records to ensure that personal data will not be kept longer than is necessary in relation to the purpose for which they were collected.

Different retention periods apply to various types of personal data that we hold, depending on the respective data collection/usage purpose and relevant legal requirements.

Data Protection Officer

We have appointed a Data Protection Officer whose responsibilities include the following:

To inform and advise SCMP GROUP and its employees of their obligations pursuant to the applicable privacy and other laws and regulations (collectively “Privacy Laws”);
To monitor SCMP GROUP’s compliance with such Privacy Laws;
To co-operate with the supervisory authority (eg. privacy commissioner or equivalent bodies); and
To act as the point of contact for the supervisory authority on issues regarding the data processing and related matters.

Data Access / Correction and Other Inquiries

You have the right to know whether SCMP GROUP holds your personal data, access the data and/or correct any inaccuracies of such data. You also have the right to make reasonable inquiries about SCMP GROUP’s personal data policies and procedures. You have the right to object to the processing of your personal data or withdraw your consent (if applicable) at any time. Please note however that if you object to the processing of your personal data, it may affect SCMP GROUP’s ability to provide the services that you required to you or may affect the quality of such services. If you withdraw your consent (if applicable), SCMP Group will stop providing such services to you which applicable laws require specific consent.

All of the above requests should be made in writing to our Data Protection Officer at dataprotection@scmp.com

Representation for Data Subjects in the European Union or in the United Kingdom

We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact.

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit:

https://prighter.com/q/16203020

A reasonable fee may be charged in light of the administrative costs that SCMP GROUP shall incur in addressing your request(s).

We keep our Privacy Notice under regular review, and reserve the right to amend it from time to time as appropriate.

This Notice was last updated on 25 January 2021.