The Hong Kong Club (the "Club") has a strong commitment to provide quality service to our Members, their spouses and their guests. The Club is further committed to protecting the privacy of personal data the Club collects from its Members, their spouse and other non-members (such as guests, visitors and Member applicants) in connection with their use of our facilities or services.

If you are one of these persons, to ensure you can make informed decisions and feel confident about supplying personal data relating to you when using our facilities or services, we provide this privacy policy statement outlining our data collection practices and the choices you have concerning how the data is being collected and used. The Club has a separate privacy policy that applies to the employees and job applicants of the Club.

Please read this privacy policy statement carefully before submitting any Data to us. The term “Data” refers to any personal information that can be used to identify you as an individual. It can include, among other things, your name, contact number, address, age, gender, identification document details, personal financial information and spouse and family information.

We limit the collection, use and retention of the Data to the specific information we need for legitimate purposes to carry out the Club's business and operations, including the provision of services, facilities and products to its Members and/or their spouse, enforcing the Club's rules and policies and maintaining the Member's and/or his/her spouse's membership/registration with the Club. We may also collect, use and retain Data for the purposes of processing an applicant's application to become a Member of the Club or processing an enquiry made by a non-member to the Club regarding its facilities, services and products. We take appropriate steps to protect Data collected against unauthorised access, disclosure or alteration, and to keep such Data up to date.

We may need to make changes to this data privacy policy statement from time to time. All changes will be included in the latest data privacy policy statement published by the Club. Any changes to our data privacy policy statement will become effective upon publishing of the revised statement.

This privacy policy statement contains numerous general and technical details about the steps we take to respect your privacy concerns. We have organised the privacy policy statement by major processes and areas so that you can review the information of most interest to you.

1.         Data we collect and how we use it

2.         Internal Controls

3.         How we store and transmit Data

4.         How we track Member's and their spouse's usage on our website

5.         Special Offers and Promotions and Opt-Out

6.         How long will Data be retained for?

7.         Data access and correction requests

8.         Notifications in the event of breach

9.         Careers

10.       Other Sites

11.       Children’s Privacy

12.       Legal Disclaimer

13.       Enquiries



We collect and use such Data to administer our business, and to offer various related products or services that may be of interest to you.

Browsing our website

When you browse our website, we do not collect Data unless you voluntarily and knowingly provide it to us, for example by accessing our website from a link in an e-mail that we send to you or where you have a membership account with the Club and you log-in to your account.

Using the Club facilities

The Data that you provide to us for using our facilities or acquiring our products is for the purpose of providing you with such facilities and related services and products. At times, we may make certain Data available to strategic business partners such as mail houses and e-mail service providers for the sole purpose of mailing and dissemination of promotional materials of the Club only. Data will not be shared with third parties for their own marketing purposes.

The Club conducts CCTV monitoring to maintain the security of the premises and to prevent and investigate crime. CCTVs will be positioned and operated subject always to the principle not to unnecessarily intrude the privacy of the relevant individuals

Making a purchase from the Club

When making certain purchases from the Club such as Take Away Wines, you will be asked to complete a form that includes your name, membership number and contact information.

Octopus Card

If Members and/or their spouse apply to register their Octopus Card with the Club for access to the Club's premises, they will be required to provide certain Data as part of the Octopus Card registration application process. We do not own any of the Data supplied to Octopus Cards Limited in connection with the Octopus Card application process. Members and/or their spouse can refer to Octopus Cards Limited’s privacy policy statement posted on their website to understand how the information they supply will be used. Octopus Cards Limited is the issuer of the Octopus Card, and all terms and conditions of being a cardholder are dictated by Octopus Cards Limited.

Fraudulent e-mails

Please note that the Club will never send you an e-mail requesting your password, credit card number or passport, personal identity card or Hong Kong ID. If you receive any suspicious e-mails that looks like it is from the Club, but asks you for your credit card number or passport, personal identity card or social security number, it is a fraudulent e-mail, or “phishing”. We recommend that you do not reply to the e-mail or click onto any links or pop-up messages and report to the local authorities which handle fraudulent e-mails. If you believe “phishers” have gained access to your personal or financial information, we recommend that you also change your password(s), alert your credit card service provider and bank and review credit card and bank and Club account statements to check for unauthorised charges.

Unsecure communication

It is important to note that all e-mail communication is not secure. There is a risk inherent in the use of e-mail. Please be aware of this when requesting information or sending forms to us by e-mail, for example, from the “Contact Us” section of our website. We recommend that you do not include any sensitive information including credit card details when using e-mail or using any public computers/public WIFI. Our e-mail responses to you may not include any sensitive or confidential information. Please bear in mind that no security system or system of transmitting information over the Internet is guaranteed to be secure.



The Club trains its employees and staff on the importance of Data privacy and protection. Our privacy policy is updated as required to reflect any changes in applicable laws and developments in best practice procedures. Further, we limit the number of individuals within the Club with access to Data to those directly involved in the process of providing quality service and products to you.



Hongkong & Shanghai Hotels Ltd

Your Data may be shared with Hongkong & Shanghai Hotels Ltd who manages our operations. We have policies and procedures to limit access to Data to authorised personnel only.

Our ASPEN and RESPAK Reservation System

We store Member and his/her spouse's information and reservation details in our ASPEN and RESPAK Reservation System. The system is a secure database stored on a dedicated server located in the Club Building hosted by the Club. The stored database includes Data such as the Member's name, address, phone number(s), employment details and Bank information. We may also store other information such as the Member's spouse's information and the Member's and the Member's spouse's usage history of the Club's facilities.

Our server resides behind firewalls to protect the Data collected from you against unauthorised or accidental access. Because laws applicable to personal information vary by country, we may put in place additional measures that vary depending on the applicable legal requirements.

In our Club marketing database

We maintain a database of Member's and his/her spouse's information which is used for marketing, promotion and internal Club research. You will receive marketing and promotional materials if you have already given your express and specific consent in some data collection forms. You may elect to unsubscribe from receiving future e-mail promotions at any time.

Secure transmission and storage of data

We treat all Data that you provide to us as confidential information. To prevent Data from unauthorised access or leakage, we have adopted and regularly monitor our group’s security and data privacy policies and procedures.

Data transmission across international borders

Our operations involves the transfer of your Data to third parties, agents or service providers that may be located in countries outside of Hong Kong for the purposes mentioned in this Policy. Although the data protection and other laws of these various countries may not be as comprehensive as those in Hong Kong, the Club will take appropriate steps to ensure that your Data is protected and handled as described in this privacy policy statement. Therefore, in addition to the implementation of the present Policy, the Club will implement, where necessary appropriate measures, including contractual clauses, to secure the transfer of your Data to recipients located in a country with a level of protection different from Hong Kong.

Disclosure of information to third parties

The Club may release your Data to a third party, agent and/or service provider of the Club, for the purpose for which the Data was collected or to comply with a legal requirement. We use the services of third party agents, such as e-mail service providers for the purpose of mailing materials to our Members and their spouses. We will take steps to prohibit these parties from using Data for any purpose other than for the purpose specified in their respective contracts. We do not permit the sale of Data to entities for any use unrelated to our operations or use of Data by third parties for their own purposes.

The third parties may be located in countries outside of Hong Kong. Although the data protection and other laws of these various countries may not be as comprehensive as those in Hong Kong, the Club will take appropriate steps to ensure that your Data is protected and handled as described in this privacy policy statement. The Club will implement, where necessary appropriate measures, including contractual clauses, to secure the transfer of your Data to the third party service providers located in a country with a level of protection different from the one existing in the country in which your Data is collected.




Our website only uses “cookie” technology as a tracking tool. For Members, their spouse or any guests on our website, cookies identify your browser, rather than you and cannot be used by themselves to disclose your individual identity. Cookies enable us to track the number of page visits from the same computer or browser to be aggregated for statistical purposes.

Cookies do not corrupt or damage your computer, programs, or computer files.

The purpose for which cookies - other than those which are either exclusively intended to enable or facilitate communication by electronic means or strictly necessary for the provision of an online communication service at your express request - are used on our website is set forth in a banner appearing the first time you land on our website. By continuing to browse on the website, you consent to their use.

You may set your browser to block Cookies, although doing so will affect your ability to perform certain transactions, use certain functionality, and access certain content on our website. Procedures for managing your settings may differ depending on your browser. Please consult the instructions for your particular browser on how to do this. From commonly used browsers, please click the links below:

Microsoft Windows Explorer:

Google Chrome:

Mozilla Firefox:

Apple Safari:

If you do not use any of the browsers listed above, choose the "Help" function, followed by "Cookies" to find out where your cookie folder is stored.

Pixel Tags

Our third-party service providers may use pixel tags (also known as “clear gifs”, “beacon gifs” etc.), tracking links and/or similar technology to:

  • Determine your ability to receive HTML-based e-mail messages. Our e-mail service provider includes a pixel tag, which they refer to as a “coded sensor” in all of the HTML-based messages sent on our behalf. The sensor activates when the e-mail message is opened and flags the e-mail address of the user as one that is capable of receiving HTML-based e-mail messages. This capability helps our service provider to send the e-mail in a format you can read. The sensor does not collect or use any other information. If you cannot receive HTML, you will not receive a functioning sensor;
  • Know how many users open an e-mail and allow our service provider to compile aggregated statistics about an e-mail campaign for us.



With your consent, we may send you information about the Club, including special offers presented by the Club and other promotions by post and/or e-mail. It is however our intention to only send you mail and e-mail communications that you may want to receive. When you opt-in or do not opt-out from receiving promotional material in a form in which we collected Data from you, we will periodically contact you via post and/or e-mail and provide information about special offers and promotions that may be of interest to you. We typically use third party e-mail service providers to send e-mails. We will take reasonable steps to prohibit these service providers from using your e-mail address for any purpose other than to send e-mails related to our group operations or any directly related purpose. Data will not be shared with third parties for their own marketing purposes.

We provide you the ability to unsubscribe from all marketing communications. Every time you receive an e-mail, you will be provided with the choice to opt-out of future e-mails by following the instructions provided in the e-mail. You may also opt-out of receiving promotional materials by updating your Membership account on the website, or sending a letter or e-mail to:

Membership Secretary

The Hong Kong Club

1 Jackson Road


Hong Kong




Your Data will be stored for the period of time required or permitted by law in Hong Kong. However, information that is stored on your membership account may be edited and deleted by users of such service at any time.

Data may be stored by the Club as long as required for the business purpose for which these Data are processed.



You have the right to request access to and correction of your Data held by the Club.  If you wish to do so for legitimate purposes, please send a letter to:

The Membership Secretary

The Hong Kong Club

1 Jackson Road

Central, Hong Kong


In order to protect your Data, we will require that you prove your identity to us in relation to your request to access your Data, which may consist of a copy of a government-issued identification, your signature and correspondence address so we can check them against our records and satisfy ourselves as to your identity. The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Data.



In the unlikely event of a Data breach, we are prepared to follow any laws and regulations which would require us to notify you of the disclosure of private information.



Our careers websites at invite individuals that wish to be considered for potential employment to provide their curriculum vitae for consideration. We will not use the information you provide for any purpose other than to determine your qualifications for potential employment at the Club and process your application for employment.



The Club is only responsible for the privacy policy statement and content of its website.



Our website and ASPEN and RESPAK Reservation Systems are not intended for children and minors and we do not knowingly solicit or collect Data from children and minors.



This privacy policy statement complies with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region as well as applicable local laws.

We may need to disclose Data when required by relevant law or court order, or as requested by other government or law enforcement authorities. This also applies when we have reason to believe that disclosing the Data is necessary to identify, investigate, protect, contact or bring legal action against someone who may be causing interference with our Members, guests, visitors, associates, rights or properties (including this site), or to others, whether intentionally or otherwise, or when anyone else could be harmed by such activities.



If, after reviewing this privacy policy statement you have any privacy questions or concerns, please send an e-mail to or send a letter to:

The Membership Secretary

The Hong Kong Club

1 Jackson Road

Central, Hong Kong