Privacy Policy Statement

1.  YOUR PERSONAL DATA PRIVACY

Poly Joy Club (“we” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy Statement (this “Statement”) explains our personal data privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Statement applies to the personal data held by us from time to time, including the data of members of Poly Joy Club, applicants for membership of Poly Job Club and users of our website (the “Website”), whether Poly Joy Club members or not. This Statement may from time to time be revised or otherwise changed where we deem necessary.

If there is any inconsistency between the English and Chinese versions of this Statement, the English version shall prevail.

Throughout this Statement, the meaning of the term “personal data” is as defined in the Ordinance.

2. KINDS OF PERSONAL DATA HELD BY US

When you apply or request for Poly Joy Club membership, membership benefits, services, products or other arrangements, or when you use the Website or other facilities provided by us, we may collect and hold your personal data. Kinds of personal data collected and held by us may include your name, identity card/passport number and other identification information, your home and/or mobile telephone number, home and/or postal address, email address and other contact information, your interests and preferences, and information relating to your mobile device.

You are not obliged to supply the data, but if you do not, we may be unable to process your application or request, and some functionality or features of the Website may not be available.

If you are under the age of 18, you must ask your parent or guardian before providing any personal data to us.

3.  MAIN PURPOSES FOR WHICH PERSONAL DATA HELD BY US MAY BE USED
The main purposes for which we may use your personal data from time to time include the following:

3.1 follow up on and handle comments, inquiries and complaints received by us from or against you;
3.2 follow up and process your applications, registrations or subscriptions;
3.3 administer, maintain and manage Poly Joy Club, its memberships and the Website and other services, arrangements and facilities provided by us;
3.4 monitor use of membership benefits, the Website and other services, arrangements and facilities, and understand users’ needs to help further development;
3.5 conduct surveys, research and analyses, and compile aggregate statistics about users to analyze usage of membership benefits, the Website and other services, arrangements and facilities;
3.6 operate internal control, resolve disputes, troubleshoot problems and enforce terms of use;
3.7 contact and communicate with you;
3.8 verify identity and maintain contact lists for communications;
3.9 design, provide and market Poly Joy Club, our activities, facilities, services, benefits and/or products, and that of the Poly Property (Hong Kong) Co., Limited and any of its subsidiaries, associated and/or related companies;
3.10 promote, improve and/or further the provision of Poly Joy Club membership, our activities, facilities, services, benefits and/or products, and that of the Poly Property (Hong Kong) Co., Limited and any of its subsidiaries, associated and/or related companies;
3.11 offer or deliver information that users may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;
3.12 recruitment and other human resources related purposes;
3.13 communicate with our investors and/or potential investors, and that of Poly Property (Hong Kong) Co., Limited and any of its subsidiaries, associated and/or related companies;
3.14 comply with any law or court order binding on us, comply with any guidelines or codes of practice issued by regulatory or other authorities or governmental or law enforcement agencies with which we are required or reasonably expected to comply, and comply with any internal policies and measures relating to these compliance matters; and
3.15 any other purpose(s) which has been agreed by or notified to you.

4. DISCLOSURE AND TRANSFER OF PERSONAL DATA
We will take all reasonably practicable steps to keep your personal data confidential but we
may disclose, transfer and exchange your personal data to and with other persons in or
outside of Hong Kong, including the following:

4.1.any agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services or support to us with respect to the operation of our business;
4.2.the Poly Property (Hong Kong) Co., Limited and any of its subsidiaries, associated and/or related companies;
4.3.any third party merchants or stores or providers/suppliers which provide activities, facilities, products, benefits and/or services to any members of Poly Joy Club, and
4.4.any person to whom we are under an obligation to make disclosure under the requirement of any law or court order binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities or governmental or law enforcement agencies with which we are required or reasonably expected to comply.

Please refer to our Personal Information Collection Statement for further details on the use,
disclosure and transfer of personal data.

5.  USE OF ‘COOKIES’
When you use the Website, cookies will be stored in your computer. Cookies are small text
files that are automatically created and stored on the web browser in your computer which
can be retrieved by the Website. Cookies will collect and store information about your
preferences, navigation pattern, login name, etc. We use cookies to track users’ visits to the
Website to provide better user experience and customized services. We will not use cookies
to collect any personal data from you. Most web browsers automatically accept cookies. You
can disable the cookies on your web browser, but if you do, certain functionality or features
of the Website may not be available.

6. LINKS TO OTHER WEBSITES
This Statement only applies to the Website. If you click on any advertisement or hyperlink
linking to other website(s), the protection of your personal data privacy and your exposure to
cookies on the other website(s) are not our responsibility. You are advised to refer to the
privacy policy and practices of the relevant website.

7. WEB LOGS
When a user visits the home page of the Website, the visit will be counted and included in
the total number of visits to the Website for statistical purpose. This information does not
identify you as an individual. No personal data will be collected.

8. SECURITY 
We will take all reasonably practicable steps to keep your personal data protected against
unauthorized or accidental access, processing, erasure, loss or use. Our protective measures
may include providing training to the employees who handle personal data, restricting access to personal data and deploying encryption and other technology available in the market.

9. USE OF PERSONAL DATA IN LEGAL PROCEEDINGS
If it becomes necessary that we have to take action against you for any reason whatsoever
including but not limited to recovering from you any money you owe us, you expressly agree
that we can use your personal data in identifying and taking legal action against you.

10. YOUR RIGHT TO ACCESS AND CORRECT YOUR PERSONAL DATA
You may at any time request access to and correct personal data relating to you on our
records. Please send your data access requests and data correction requests to us at the
address below marking your communication “Confidential”. We may ask you to provide
further information to enable us to verify that you have the right to make the relevant
request. We may charge you a reasonable fee for handling a data access request.

11. PERSONAL DATA PRIVACY OFFICER
Please send your data access requests, data correction requests and other requests and
enquiries about our policies and practices with respect to personal data to our Personal Data
Privacy Officer as follows:

Poly Joy Club
Address: Room 2501, 25/F, Admiralty Centre, Tower 1, 18 Harcourt Road, Hong Kong.
Attention to: Personal Data Privacy Officer
(Marked Confidential)

12. RETENTION OF DATA
We will only keep your personal data for as long as necessary to fulfill the purposes for which
the data was collected unless otherwise required or permitted by the Personal Data (Privacy)
Ordinance. An example is we may retain the personal data to satisfy any applicable statutory
or contractual obligations. Personal data which is no longer necessary will be destroyed.