Personal Data Collection Statement
1.1 Poly Joy Club (“Club”) takes all reasonably practicable precautions and exercises due diligence to comply with the requirements under the Personal Data (Privacy) Ordinance (Cap.486). This Statement sets out the policies of the Club in the collection, use, sharing and protection of its members’ personal data. The Club may update or change this Statement from time to time and these changes will be posted on the Club’s website.
2. PERSONAL DATA THE CLUB COLLECTS
2.1 The Club may collect and/or request you to provide information about yourself (“your personal data”) via its website, in application forms, through other channels or by other means. The information the Club collects or requests from you may include but is not limited to:
2.1.1. personal information such as your salutation, name, date of birth and identification document(s) number(s) such as HKID Card/PRC ID Card/Passport number(s);
2.1.2. contact information such as your home and/or mobile telephone number(s), home and/or postal address(es) and email address(es);
2.1.3. business information such as company name, business title and related contact information;
2.1.4. your interests and preferences, responses to market surveys and contests conducted by the Club or on its behalf;
2.1.5. data about transactions you have entered into with and held by the Club and/or Poly Property Group Co., Limited and/or any associated company of Poly Property Group Co., Limited and/or any parent undertaking or subsidiary undertaking of Poly Property Group Co., Limited (which shall include but not limited to the Club, Poly Property Group Co., Limited and Poly Property (Hong Kong) Co., Limited) (collectively “Poly Group Companies”). In this Statement, “associated company”, “parent undertaking” and “subsidiary undertaking” shall have the meanings given by the Companies Ordinance (Cap. 622).
2.2. Your personal data collected by the Club may be used for either obligatory or voluntary purposes. If your personal data are to be used for an obligatory purpose, you MUST provide your personal data to the Club and if you fail to do so in relation to a specific service, the Club may be unable to provide that service to you. If your personal data are only to be used for a voluntary purpose, you may inform the Club not to use your personal data for that purpose and the Club will not do so. You are requested to serve your instruction in writing by post to Poly Joy Club at the address set out in 6.1 below.
3. PURPOSE FOR COLLECTION AND USE OF PERSONAL DATA
3.1. The Club may use your personal data for one or more of the following obligatory purposes:
3.1.1. to process your application to join and administer your membership of the Club;
3.1.2. to respond to, process and fulfill and otherwise handle your general enquiries and your requests for any products, benefits and/or services the Club offers whenever such enquiries and requests are submitted;
3.1.3. the operation of the Club including delivery of associated products, benefits and/or services, activities, facilities, ongoing research and program development, delivering news and information to members, and for other Club record-keeping purposes;
3.1.4. for identification and verification purposes, in connection with any of the activities, facilities, products, benefits and/or services that may be supplied to you by the Club and/or third party merchants, stores and/or providers/suppliers, other business associate or business partners of the Club and/or any of the Poly Group Companies;
3.1.5. disclosure to third parties to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any jurisdiction, whether within or outside of Hong Kong; and
3.1.6. purposes directly relating to any of the above purposes.
3.2. The Club may use your home and/or mobile telephone number(s), home and/or postal address(es) and email address(es) (collectively “contact information”) for one or more of the following voluntary purposes:
3.2.1. to administer contests and sweepstakes including but not limited to disclosing the winners of any such contests and sweepstakes; and
3.2.2. for direct marketing, promotional and member relationship management purposes.
In this connection:
(a) the Club must obtain your consent (which can include an indication of no objection) to use your contact information for direct marketing;
(b) the following classes of products, benefits and/or services and/or subjects of the Club, any of the other Poly Group Companies and/or other businesses may be marketed:
(i) products, benefits and/or services offered by the Club and/or any of the other Poly Group Companies in relation but not limited to property, shopping mall, clubhouse, hotel, catering, supermarket, carpark, cleaning and security services;
(ii) reward, loyalty or privilege programmes offered by the Club, third party business partners of the Club and/or any of the other Poly Group Companies which are in the business of providing the classes of products, services or subjects set out in 3.2.2(b) (iii)-(xi) below (“Club’s Partners”);
(iii) travel and accommodation services, and air and non-air transportation services including but not limited to hotel transfers, car rentals, limousine and taxi services, bus, train and cruise services;
(iv) travel and leisure services, including but not limited to holiday package products and services offered by travel agents, tickets to theme parks and other attractions;
(v) financial, insurance, credit card, banking, foreign exchange, and other related services and products;
(vi) telecommunication, internet and mobile communication services;
(vii) food, wine and beverage and related services;
(viii) consumer electronics, computers and peripherals, printed matter including books, newspaper subscriptions and magazine subscriptions, audio visual titles, computer software and games, mobile telephones and peripherals, toys, furniture, home furnishings, home appliances, housewares and tools, stationery, sporting equipment, fashion and apparel, watches and jewelry, suitcases and bags, food and consumables, beauty products and cosmetics, gift, flowers and hampers, health and beauty services, included but not limited to medical check-ups and spa packages, and vouchers, coupons and gift cards;
(ix) professional and consulting services;
(x) tickets for concerts, exhibitions, films, theatricals, sporting and special events; and
(xi) real estate purchases or rentals.
If you agree to the use of your contact information for the above mentioned direct marketing purposes and the provision of your personal data to the parties mentioned in 3.4 below for their use, please indicate your consent by ticking the box in the Poly Joy Club Membership Application Form (on line or in paper material) when applying for membership.
3.3. The Club may provide your personal data to the Club’s agents for marketing its products, services and/or subjects listed in 3.2.2(b) above on the Club’s behalf, both in and outside Hong Kong.
3.4. The Club may also provide your personal data to any of the other Poly Group Companies and the Club’s Partners for their use in marketing their own products, services and/or subjects as listed in 3.2.2(b) above, and the Club must obtain your written consent (which can include an indication of no objection) for such purpose.
3.5. If you do not want the Club to use or provide to other parties your personal data for direct marketing as described herein above, you may opt-out, without charge, by:
3.5.1. leaving the box in the Poly Joy Club Membership Application Form (on line or in paper material) blank to indicate you do not consent when applying for membership; or
3.5.2. serving your ‘opt-out’ request in writing by post to Poly Joy Club at the address set out in 6.1. below.
3.6. Except as provided in “5. Disclosure and Transfer of Personal Data” below, the Club will not knowingly use or share your personal data in ways unrelated to the aforementioned purposes without your prior consent.
4. ACCESS TO AND CORRECTION OF PERSONAL DATA
4.1. You have a right of access to and, if incorrect, to correct your personal data kept by the Club. All requests for copies of, or to correct, your personal data and all other enquiries about the handling of your personal data by the Club should be addressed in writing to Poly Joy Club at the address set out in 6.1. below.
4.2. The Club may charge a fee to process your data access and change request(s).
5. DISCLOSURE AND TRANSFER OF PERSONAL DATA
5.1 The Club may disclose/transfer your personal data to, and jointly use your personal data with (1) all of the following parties for the purposes set out in 3.1. and 3.2.1 above, and (2) if you agree that the Club may provide your personal data to other persons for their direct marketing purposes, the parties specified in 5.1.6 and 5.1.7 below for the purposes set out in 3.2.2.(b) above: –
5.1.1. any of the other Poly Group Companies;
5.1.2. any agent, contractor or third party service provider providing administrative, research, distribution, data processing, telecommunications, computer, payment or other services to the Club in connection with the operation of its programme;
5.1.3. any other business associate of the Club such as the Club’s Partners, loyalty programme operators, hotel operators, retailers, restaurants and other companies necessary for offering or providing products/customer service or fulfilling customer requests in connection with the Club’s programmes;
5.1.4. any party to whom the Club or any of the other Poly Group Companies are obliged or expected to make disclosure under any law or guidelines, regulations or other measures issued by regulatory or other authorities (including industry and self-regulatory bodies);
5.1.5. any actual or proposed assignee of the Club or participant or sub-participant or transferee of the Club’s rights in respect of you;
5.1.6. provided you have agreed to the use of your personal data for direct marketing, our agents to market the products, services and subjects specified in 3.2.2.(b) above;
5.1.7. provided you have agreed to the Club’s providing your personal data to them, to any of the other Poly Group Companies and the Club’s Partners to market the products, services and subjects specified in 3.2.2.(b) above; and
5.1.8. any other parties if transfer of your personal data to them is reasonably necessary or expedient to procure or fulfill your requests for products, benefits and/or services.
6.1. All enquiries regarding the Club’s compliance with its obligations under the Personal Data (Privacy) Ordinance (Cap. 486), opt-out requests or consents in relation to the use of your personal data for direct marketing and requests for access to data or correction of your personal data should be made in writing to:
Poly Joy Club
Room 2501, 25/F, Admiralty Centre, Tower 1, 18 Harcourt Road, Hong Kong.
Personal Data Privacy Officer
6.2. If there is any inconsistency between the English and Chinese versions of this Statement, the English version shall prevail.