Personal Information Collection Statement
Your Personal Data
- The Henderson Club (the "Club") is offered and operated by Henderson Club Limited ("HCL"). This Statement applies to the personal data from time to time provided by or for you in relation to the Club membership and other personal data compiled by HCL starting from your application for Club membership or admission as a Club member (as applicable) and throughout the continuation of your Club membership (collectively, "Your Personal Data"). This Statement sets out the purposes for which Your Personal Data may be used and other matters relating to the Personal Data (Privacy) Ordinance, Cap. 486 ("Privacy Ordinance").
- You are required to provide personal data to enable HCL to process your application for Club membership or admission as a Club member (as applicable) and handle matters relating to the Club membership. If you fail to provide personal data, HCL may be unable to process your application or admission and to offer or continue to offer to you the Club membership or any of the facilities, services, products, benefits and privileges (including any reward program) of the Club (collectively, "Membership Benefits").
Use of Your Personal Data
- HCL may use Your Personal Data for one or more of the following purposes from time to time:
- (a) consider and assess your application for Club membership and process your admission as a Club member as appropriate;
- (b) handle and administer any matters in relation to your Club membership and communicate with you on such matters. These matters may include verifying personal data or other information about you, providing and maintaining your Club membership, providing Membership Benefits to you, and investigating and handling any enquiries or complaints from or against you;
- (c) administer, maintain and manage the Club and Club membership generally, including improving Membership Benefits and Club member experience;
- (d) design, arrange, procure and provide Membership Benefits of any type and nature;
- (e) process your request or application for Membership Benefits;
- (f) conduct surveys, research and analysis in connection with the Club, Club membership and Membership Benefits, whether relating to you or to Club members generally;
- (g) marketing any services, products and facilities provided by HCL, Henderson Land Development Company Limited or any of its subsidiaries and associated companies ( Henderson Land Development Company Limited and all of its subsidiaries and associated companies collectively, "Henderson Land Group" or "Henderson Land Group Members") or any other person (whether or not a Henderson Land Group Member) who has made any co-branding or cooperative arrangement with HCL (each, an "HCL Partner"), please see further details in "Use of Your Personal Data in direct marketing" section below);
- (h) calculate any amount payable by you or by HCL, and collect or recover any amount payable by you;
- (i) comply with any obligations or requirements for using or disclosing personal data that are imposed on HCL or any Henderson Land Group Members by any law or regulations, or by any governmental agency, regulatory authority or law enforcement agency, or by any court or judicial body, whether in or outside of Hong Kong existing currently or in the future;
- (j) comply with any policies and measures for using or disclosing personal data implemented by HCL or Henderson Land Group for prevention or detection of money laundering, terrorist financing or other unlawful activities or suspicious activities;
- (k) match or compare Your Personal Data with any other data relating to you to produce or verify data which may be used for taking adverse action against you;
- (l) enable actual or potential assignees of the Club business, or actual or potential purchasers or assignees of HCL or its business, in each case to evaluate the assignment or purchase in question;
- (m) any other purpose agreed by you; and
- (n) purposes relating to any or all of the above.
Disclosure or Transfer of Your Personal Data
- HCL will keep Your Personal Data confidential but may disclose or transfer Your Personal Data to one or more of the following classes of persons from time to time for the purposes set out in paragraph 3 above, and Your Personal Data may be transferred in or outside of Hong Kong:
- (a) any of the Henderson Land Group Members and HCL Partners for purposes relating to the Club, Membership Benefits or your Club membership;
- (b) agents, contractors, sub-contractors or service providers (including their employees, directors, officers, agents, contractors, service providers and professional advisers) who provide services or support to HCL in connection with the Club business or the business or operations of HCL. These services or support may include banking services, insurance services, computer, information technology, data processing or storage, telecommunications services, mailing and logistic and administrative services. These agents, contractors, sub-contractors or service providers may or may not be Henderson Land Group Members;
- (c) persons who owe a duty of confidentiality to HCL. These persons may include accountants, auditors, legal advisers and other professional advisers of HCL;
- (d) persons to whom HCL or any Henderson Land Group Member is under any obligations or requirements to disclose personal data by any law or regulations, or by any governmental agency, regulatory authority or law enforcement agency, or by any court or judicial body;
- (e) persons to whom HCL is required to disclose personal data by any policies and measures implemented by it or Henderson Land Group for prevention or detection of money laundering, terrorist financing or other unlawful activities or suspicious activities;
- (f) for marketing purposes, (i) Henderson Land Group Members, (ii) HCL Partners (and the names of these HCL Partners can be found in the request or application form or information leaflet relating to the relevant Membership Benefits) and (iii) service providers engaged by HCL (and these service providers may include printing, advertising, market research, marketing, telemarketing and direct sales agencies and mailing agencies); and
- (g) actual or potential assignees of the Club business, or actual or potential purchasers or assignees of HCL or its business.
Use of Your Personal Data in Direct Marketing
- HCL intends to use Your Personal Data in direct marketing and HCL requires your consent for this purpose. Please note the following:
- (a) Types of personal data to be used
- HCL may use the following types of Your Personal Data that is held by HCL from time to time in direct marketing:
- your name, month of birth, address, telephone number and email address;
- your financial background;
- pattern and behaviour relating to your use of Membership Benefits or your purchase or consumption of products and services (including products and services portfolio information and spending habits); and
- your demographic data.
- (b) Class of products, services and subjects to be marketed
- HCL may market one or more of the following classes of products, services and subjects:
- consumer goods and services, including food and beverages, fine dining, clothing and apparel, fashion and accessories, foot-ware, lifestyle and leisure products, amenities and entertainment, travelling services, sports goods, toys and children goods, beauty and personal care, healthcare, dental and medical services and products, groceries, supermarkets, delicatessen and convenient stores, books and magazines, home furnishing, electrical appliances, audio and video products, optical products, and jewellery, watches and other luxurious goods;
- real estate properties or property developments offered by any Henderson Land Group Member singly or jointly with any other developer or person;
- financial, investment, banking, insurance, credit cards and related products and services; and
- donations or contributions for charitable or non-profit making purposes and related events or activities.
- (c) Providers of products, services and subjects to be marketed
- The above products, services and subjects may be provided by one or more of the following classes of persons:
- any Henderson Land Group Members; and
- any HCL Partners (and the names of these HCL Partners can be found in the request or application form or information leaflet relating to the relevant Membership Benefits). HCL Partners may include retail merchants, service providers, real estate developers, financial institutions, charitable bodies and non-profit making organisations.
Access or Correction of Your Personal Data
- You have the right to make data access request and data correction request to HCL about Your Personal Data. You also have the right to withdraw or give consent for use of Your Personal Data in direct marketing from time to time. Please send your data access and data correction requests or your choice relating to direct marketing to the attention of "Personal Data Privacy Officer of Henderson Club" either by post (to 71/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong) or by email (to firstname.lastname@example.org).
- HCL has the right to charge a reasonable fee for the processing of any data access request.
Version effective date : December 2016
Note : In case of discrepancies between the English and Chinese versions of this Statement, the English version shall prevail.