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.
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.
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
10. Other Sites
11. Children’s Privacy
12. Legal Disclaimer
DATA WE COLLECT AND HOW WE USE IT
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.
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.
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.
HOW WE STORE AND TRANSMIT DATA
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
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.
HOW WE TRACK MEMBER'S AND THEIR SPOUSE'S USAGE ON OUR WEBSITE
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:
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.
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.
SPECIAL CLUB OFFERS AND PROMOTIONS AND OPT-OUT
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:
The Hong Kong Club
1 Jackson Road
HOW LONG WILL DATA BE RETAINED FOR?
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.
DATA ACCESS AND CORRECTION REQUESTS
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.
NOTIFICATIONS IN THE EVENT OF BREACH
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 www.thehongkongclub.hk/public/careers 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.
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.
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.
The Membership Secretary
The Hong Kong Club
1 Jackson Road
Central, Hong Kong