Privacy Policy 

CLIX is a pro bono portal initiative (“CLIX Project”) developed and managed by Equal Justice Limited 平義社有限公司 (“Equal Justice”) and PILnet Hong Kong Limited. Under the CLIX Project, we have developed the CLIX website (https://www.clixhk.org) (“CLIX Website”) and CLIX portal (https://hk.probonoportal.org/login) (“CLIX Portal”) as a digital platform, which enables impact organisations and their clients with legal needs to be matched with law firms or lawyers who can assist them on a pro bono basis.  Equal Justice and PILnet Hong Kong Limited (“PILnet”) are both Hong Kong-based charitable organisations with section 88 tax exempt status. This privacy policy applies to our data protection practices in relation to the CLIX Project, CLIX Website and CLIX Portal.  

Terms Used in This Policy 

“consent” of a person means the express consent of the person given voluntarily, and does not include any consent which has been withdrawn by notice in writing served on the person to whom the consent has been given (but without prejudice to so much of that act that has been done pursuant to the consent at any time before the notice is so served). Subject to the provisions of the PDPO, a person with parental responsibility for a minor can give consent in relation to the personal data of a minor. 

“data” means any representation of information (including an expression of opinion) in any document, and includes a personal identifier. A personal identifier is an identifier that is assigned to an individual by a data user for the purpose of the operations of the user, and that uniquely identifies that individual in relation to the data user, but does not include an individual’s name used to identity that individual.  

“data processor” means a natural or legal person which processes personal data on behalf of the data user, and does not process the data for any of the person’s own purposes. 

“data user” in relation to personal data, means a person who, either alone or jointly or in common with other persons, controls the collection, holding, processing or use (including disclosure or transfer) of the data. 

“personal data” means any data relating directly or indirectly to a living individual, from which it is practicable for the identity of the individual to be directly or indirectly ascertained and in a form in which access to or processing of the data is practicable. 

“PDPO” means the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong SAR.  

“processing” in relation to personal data, includes amending, augmenting, deleting or rearranging the data, whether by automated means or otherwise. 

“we” means Equal Justice and PILnet jointly, or Equal Justice or PILnet respectively (as the case may be), and the terms “us”, “our” and “ours” shall be construed accordingly. 

“you” means you, as an individual and/or organisational user, engaging with us under the CLIX Project or via the CLIX Portal and CLIX Website, as the case may be or as the context determines, and the term “your” shall be construed accordingly.  

Principles of Data Processing 

We, Equal Justice and PILnet, as data users of your personal data provided in connection with the CLIX Project, CLIX Website and CLIX Portal, are committed to fully complying with the data protection principles under the PDPO and to processing your personal data based on the internationally recognised principles of lawfulness, fairness and transparency. 

  • We collect and process your personal data where we have given you required notifications or have obtained your consent. 

  • We will collect your personal data only for a lawful purpose directly related to a function or activity of ours, and only if the data is adequate but not excessive in relation to that purpose. 

  • We take all practicable steps to ensure that the personal data is accurate, having regard to the purpose for which the personal data is or is to be used. 

  • We take all practicable steps to ensure that the personal data is not kept longer than is necessary for the fulfilment of that purpose (including any directly-related purpose) for which the data is or is to be used. 

  • We will not use the personal data for a new purpose without your prescribed consent. 

  • We will take all practicable steps to ensure that any personal data (including data in a form in which access to or processing of the data is not practicable) is protected against unauthorised or accidental access, processing, erasure, loss or use. We also use secure transmission methods to collect and transmit your personal data on our CLIX Website and CLIX Portal.  

We implement data protection measures required by regulators in Hong Kong SAR, whilst also paying attention to the development of privacy regulations in other countries. Privacy is a global concern and we as public interest organisations pay special attention to this topic while executing projects and conducting our operations. We process personal data in a manner that ensures an appropriate level of data integrity and confidentiality. We as data users fulfil our obligation to be accountable for data processing activities as outlined by relevant laws and guidelines. 

For more information regarding the practices of data collection, use, processing and handling of your personal data arising from or in connection with your use of Equal Justice’s and PILnet’s services outside of the CLIX Project, CLIX Website and CLIX Portal, please access their privacy policies at https://www.equaljustice.org/privacy-policy and https://www.pilnet.org/privacy-policy.  

The Personal Data We Collect 

The types of personal data we collect from you via the CLIX Portal and CLIX Website may include without limitation the following:  

  • your personal information (e.g., name, email address); 

  • your work contact information (e.g., employer name, job title, email address, phone, fax); 

  • your browsing information when you visit our CLIX Portal and CLIX Website, register or sign-up on these webpages, or subscribe to or request our services thereon (e.g., browser information, IP addresses, cookies); 

  • your payment details including your credit or debit or other charge cards information or other electronic payment accounts details; 

  • your feedback, suggestions, comments, inputs and other observations in connection with your engagement with us, your access and use of our pro bono services, your engagement with the CLIX Portal and any related pro bono services you received via the CLIX Portal (collectively “Feedback”);   

Certain personal data may be required from you in order to enable us to provide specific CLIX Project-related services, or enable certain functions of the CLIX Portal and CLIX Website available to you. If you fail to supply such personal data, we may not be able to deliver to you such services or functions. 

Personal Data Provided by You 

Where you provide us with personal data collected by you from individuals directly, you hereby warrant and confirm that you have duly notified the individuals, and collected and disclosed such personal data with us in full compliance with your obligations under the PDPO. 

Purposes for Which Your Personal Data Is Collected, Used and Transferred by Us 

We collect and use (including disclose or transfer) your personal data for one or more of the following purposes: 

  • supply of legal assistance services, offerings or facilities via the CLIX Website and CLIX Portal under the CLIX Project which we may offer to you, or you may require from us, from time to time;  

  • our operation, development and maintenance of the CLIX Portal and CLIX Website via the Internet or other telecommunications channels; 

  • our opening, updating and maintenance of your user accounts or profiles on the CLIX Portal and CLIX Website;  

  • our verification of your identity in connection with your use of the CLIX Portal and CLIX Website;  

  • our assessment of, management of and allocation to you of any available or published pro bono opportunities on the CLIX Portal, or our assessment of, management of and allocation to you of any available pro bono opportunities which we have received;  

  • allowing us, other law firms or their legal advisors participating in the CLIX Project to run conflict checks for compliance purposes;  

  • our processing of your or third-parties’ donations and funds received, or our provision of donations, fundraising and other payment-related services / facilities to you, or our provision of information to you in connection with our donations, fundraising and other payment-related services or facilities via or on the CLIX Portal or the CLIX Website;  

  • provision of education, training, support, social work and related ancillary services to you;  

  • communicating with you, including contacting you or responding to you regarding your enquiries or complaints;  

  • compiling and analysing your digital footprints and browsing information to improve your browsing experience and to enhance, improve and design our CLIX Portal and CLIX Website’s interfaces, process, layout and offerings;  

  • conducting policy research and/or compiling and analysing your Feedback from time to time to improve our CLIX Portal and related service offerings and your user experience, and to better understand your experiences, preferences and use of the CLIX Portal and CLIX Website;  

  • compiling, reviewing and analysing your Feedback to inform our future allocation of future pro bono opportunities to you or third parties, or to inform our decision making or internal deliberation, which may produce adverse or legal effect concerning you or similarly significantly affecting you, including the termination or suspension of your CLIX Portal’s user account, or cancelling or suspending your participation in, or registration of, interest in future pro bono opportunities or initiatives offered by us under the CLIX Project; 

  • compiling aggregated, de-identified and anonymised user and trend data to compile reports and statistics for reporting purposes and for use of the same in training materials from time to time;   

  • with your consent, sending you updates on and promoting our pro bono or charitable opportunities or initiatives, or other such opportunities or initiatives submitted via the CLIX Portal or CLIX Website to seek your contributions. Please see further details in the “Direct Marketing” section below;  

  • making disclosures when required by law, regulation or court order of any jurisdiction and/or as requested by any government, regulatory or law enforcement authority or administrative organisation, whether within or outside Hong Kong SAR;  

  • establishing legal claims or defences, obtaining legal advice and/or exercising, defending and/or protecting our rights and interests;  

  • any other incidental or associated purposes relating to the above, or any other purposes which you may agree from time to time; and  

Classes of Recipients of Your Personal Data 

To facilitate the purposes specified under the “Purposes for Which Your Personal Data Is Collected, Used and Transferred by Us” section above, we may provide your personal data to the following classes of persons, whether within or outside Hong Kong SAR:  

  • our contractors, agents or third-party service providers who provide us with administrative, conference and training, website hosting and storage, telecommunications, data processing, research, distribution, computer, payment or other services to support our operation of the CLIX Project, CLIX Portal and CLIX Website;  

  • our collaborative partners participating in and supporting the CLIX Project, including research or academic institutions, non-profit organisations and law firms or legal advisers providing pro bono services;  

  • any government, regulatory or law enforcement authority or administrative organisation;  

  • any person who owes a duty of confidentiality to us, including our legal advisers, accountants, auditors and other professional advisers;  

  • our insurance providers 

  • our donors 

  • our third-party marketing and related software companies, e.g., emails, MailChimp newsletter software. 

Direct Marketing 

We may use your personal data to contact you (including your email address) in order send you updates on and promoting our own pro bono or charitable opportunities or initiatives, or other such opportunities or initiatives submitted via the CLIX Portal or CLIX Website to seek your contributions in relation to the CLIX Project, CLIX Portal and CLIX Website, which may constitute “direct marketing”. We may not so use your personal data unless we have received your consent and/or indication of no objection for such use. You may opt-out from receiving such direct marketing materials by email to hello@clixhk.org, or by using the unsubscribe option available in our promotional emails. 

Data Transfers Outside Hong Kong  

We will host the CLIX Portal and store your personal data provided to us via the CLIX Portal within Hong Kong SAR, utilising the secure third-party cloud services provided by Amazon Web Services. We may also host and transfer your personal data in a cloud services provider outside Hong Kong SAR for the purposes of hosting and/or supporting the CLIX Website and/or Portal.   

Period for Storing Your Personal Data 

We will take all practicable steps to ensure that your personal data is not retained for longer than is necessary for the fulfilment of the purpose for which the data is used.  

Your Rights Based on This Policy 

You can approach us and ask whether we hold personal data of which you are the data subject, and ask for a copy of such data if we do hold such data. Within 40 days, subject to the provisions of the PDPO, we will either comply with such requests or inform you that we do not hold such data. If you are provided with the data and you then find that the data is inaccurate, you have the right to request that we make the necessary correction to the data. Within 40 days, subject to the provisions of the PDPO, we will correct the data and give you a copy of the corrected data, or we will let you know why we are unable to correct the data.  

Any data access and correction requests or queries about our data protection practices may be directed to:  

Equal Justice 

         Data Protection Officer, Equal Justice Limited 

Address: 21F Chun Wo Commercial Centre, 23-29 Wing Wo Street, Central, Hong Kong SAR 

Email: hello@equaljustice.org 

PILnet 

Data Protection Officer, PILnet Hong Kong Limited 

Address: 23/F Chun Wo Commercial Centre, 23-29 Wing Wo Street, Central, Hong Kong SAR 

Email: dataprotection@pilnet.org  

Updates and Changes 

From time to time, we may add to, change, update or modify this privacy policy. If we change the privacy policy in a way that affects how your data will be used or the permissions you grant to us, we will notify you and ask you to review the new policy. We may not notify you of changes that do not affect how your data will be used or the permission you grant us. We ask that you review this policy from time to time to ensure that you continue to agree with all its terms and changes made to such terms, and your continued provision of personal data (if any) to us after such changes will constitute your agreement to the new terms unless your explicit consent or indication of no objection is specifically required under law. 

Other Websites 

We may provide, on the CLIX Portal or CLIX Website, links to other third-party websites. If you choose to visit or use other websites, we are not responsible for their data protection and security practices, contents or policies. It is your responsibility to review the applicable policies or contents to confirm that you understand and agree with them. If you do not agree with such policies or contents, please refrain from accessing to or using such third-party websites.  

Last Updated May 2023