1. Statement of Policy

The Lutheran Church – Missouri Synod (“LCMS”, “we”, “our” or “us”) values your privacy. We are committed to ensuring that all personal data we collect are handled in compliance with the Personal Data (Privacy) Ordinance. We are equally committed to ensuring that all our employees, service providers and agents also adhere to these obligations.

Please read this Privacy Policy carefully to understand how we collect, handle and process personal data. By using the Website (as defined below) or voluntarily providing any information to us, you are consenting to the collection, use, transfer, storage and processing of your personal data as described in this Privacy Policy.

If you are under the age of 18 or below the age of majority in your country, you should have consulted your parent or guardian before sharing any personal data with us and have your parent or guardian read this Privacy Policy.

This Privacy Policy was last updated in September 2025.

2. How do we collect your data?

We, or our representatives like agents, contractors or service providers, may collect your personal data in many ways, including:

• when you visit our website www.hongkongpacificschool.com (the “Website”) or contact us by email;
• when you subscribe to our update service;
• when you participate in any of our activities; and
• when you voluntarily provide any information to us or interact with us in any way.

3. Types of data we collect

The kinds of personal data we may collect include:

• identifying information, such as your name;
• contact information, such as your postal address, email address and telephone number; and
• other information that you voluntarily share about or grant us access to via third-party platforms.

4. How we will use your personal data

We collect, use and/or disclose your personal data for the following purposes:

• providing services, fulfilling requests, and communicating with you;

• addressing comments, questions, and providing customer services;

• sending marketing materials and event information, as explained in more detail in Section 5 “Direct Marketing” below;

• operating and improving the Website, services and functionalities;

• processing and managing event registrations;

• tailoring your experience with the Website and displaying relevant promotions;

• analysing and compiling personal data with data from third parties to create aggregate statistics to gain insights that help enhance our services and better understand your needs;

• complying with our legal and regulatory obligations, such as conducting fraud screening and investigation, preventing illegal and unauthorised activities, and responding to requests from law enforcement, regulatory authorities, courts, and governmental agencies; and

• processing for administrative purposes, such as accounting, auditing, system maintenance, and investigate and handle any incidents, claims or disputes, and as otherwise consented to by you.

You are not obliged to share your personal data. However, if you opt not to, we might miss out on updating you about our vision, daily operations, and exciting campaigns, and we might not be able to fulfill the other purposes as set out above.

5. Direct Marketing

With you consent, which includes an indication of no objection, we or our agents (such as our designated marketing agencies) may from time to time use your personal data (including your name and email address) to send you marketing materials in relation to information about the Hong Kong Pacific School and/or the Lutheran Church – Missouri Synod and/or Hong Kong International School and/or Hong Kong International School Association Limited and/or the dispute between The Lutheran Church – Missouri Synod and Hong Kong International School Association Limited, and our events, or other relevant activities which we think you may be interested in, as well as to request your feedback.

Marketing materials may be in various forms, including advertisements, updates or newsletters and delivered via various methods including but not limited to email.

You have a choice about whether or not you wish to receive marketing materials from us. You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. You can also contact us using the details provided in Section 13 “Contact Us”.

In relation to any third-party marketing, we will also get your express opt-in consent before we share your personal data with any third-party for marketing purposes.

6. With whom and how we might share your data?

We may share your personal data with or in the following manner:

• our agents, contractors and service providers who possess the data on our behalf to carry out any of the purposes set out in this Privacy Policy. These agents, contractors and service providers may include IT vendors, data management and analytics service providers and marketing agencies;

• our staff both within or outside Hong Kong who need the information to discharge their duties;

• regulatory bodies, courts, governmental entities, and other third-parties when we determine that such disclosure is necessary to comply with applicable laws, regulations, or legal processes, to protect the interests, rights, and/or assets of the LCMS or others, or to respond to emergencies;

• our professional advisors, such as accountants and lawyers; and

• other transferees as instructed by you or with your consent.

7. Retention and Security

We take the security and privacy of your personal data seriously. Your personal data are treated as confidential information by us. All of our employees, agents, contractors, and service providers entrusted with handling your personal data are instructed to comply with this Privacy Policy.

Your personal data will be retained only for as long as it is necessary for the purpose(s) for which it was collected.

The Website may enable you to share your actions, comments, content, and information publicly or with friends. You can also connect with us, share, and utilise third-party platforms, including those associated with us. It is important to consider your personal privacy requirements and those of others when deciding whom to connect with and what to share publicly. We cannot guarantee the privacy or security of information you opt to share publicly or with others.

8. Information you provide about others

Please ensure that you are legally authorised to share with us any information that contains personal data of another person. Consent from another person shall be obtained before you share his/her personal data with us.

9. Cookies

“Cookies” are small files created and stored on your hard drive by your internet browser software, in order to hold relevant information about the web page you are currently viewing.

We may use cookies and similar technologies to monitor and observe your of and monitor activities on the Website, as well as to improve, customise and enhance your browsing experience on the Website, and to personalise services you may receive from us.

You are able to disable cookies by changing the settings on your web browsers. However, if you disable cookies, you may not be able to use some of the functions on the Website.

10. Your Rights

Besides the rights we have mentioned above, you also have the following legal rights concerning the personal data we have about you. To exercise these rights, please contact us using the details provided in Section 13 “Contact Us”.

(a) Rights of access

You have the right to request access to the personal data we hold about you. You also have the right to be informed about how your personal data is being processed (including information on its source, if you did not provide it to us).

To ensure the security and integrity of the information, we may require you to follow a designated access procedure, which may involve steps to verify your identity.

(b) Right to correction

If the information we hold about you is incorrect, you have the right to request its correction.

There may be situations where we are unable to fulfill your access or correction request. If we are unable to comply with your request, we will provide an explanation for our inability to do so.

11. Links to Other Sites

The Website may contain links to various third-party websites or applications (“Third-Party Sites”). We do not own or control over these Third-Party Sites. Your interaction with the Third-Party Sites is subject to the privacy policies of those sites, not this Privacy Policy.

We strongly encourage you to remain alert if you if you follow any links to leave the Website, and to review the privacy policies of the Third-Party Sites.  We are not responsible for privacy practices or business conduct of the Third-Party Sites.

12. Updates to this Privacy Policy

We reserve the right to update and modify our Privacy Policy regularly to align with changes in our practices, procedures, applicable laws, or regulatory requirements. You will find the latest updated date shown in the first page of this Privacy Policy.

We recommend that you regularly review this Privacy Policy to stay informed about how we handle and use personal data related to you. If you continue to access or use the Website, or if you continue to provide us with personal data, you are indicating your acceptance of the updated Privacy Policy.

13. Contact Us

If you have any questions or comments about this Privacy Policy, or you would like to exercise your legal rights concerning your personal data, you can contact us at privacy@hongkongpacificschool.com. We endeavor to respond within 30 days.