Your Personal Data Privacy
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 Henderson Club, applicants for membership of Henderson Club and users of our website (the “Website”), whether Henderson 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.
Kinds of Personal Data Held By Us
When you apply or request for Henderson 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 and other identification information, your mobile number, 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 13, you must ask your parent or guardian before providing any personal data to us.
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:
- follow up on and handle comments, inquiries and complaints received by us from or against you;
- follow up and process your applications, registrations or subscriptions;
- administer, maintain and manage Henderson Club and the Website and other services, arrangements and facilities provided by us;
- monitor use of membership benefits, the Website and other services, arrangements and facilities, and understand users’ needs to help further development;
- 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;
- contact and communicate with you;
- verify identity and maintain contact lists for communications;
- design, provide and market Henderson Club, our facilities, services and/or products, and that of the Henderson Land Group and any of its subsidiaries, associated and/or related companies;
- promote, improve and/or further the provision of Henderson Club membership, our facilities, services and/or products, and that of the Henderson Land Group and any of its subsidiaries, associated and/or related companies;
- offer or deliver information that users may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;
- recruitment and other human resources related purposes;
- communicate with our investors and/or potential investors, and that of the Henderson Land Group and any of its subsidiaries, associated and/or related companies;
- 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
- any other purpose(s) which has been agreed by or notified to you.
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:
- 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;
- the Henderson Land Group and any of its subsidiaries, associated and/or related companies; and
- 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.
Use of ‘Cookies’
Links to Other Websites
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.
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.
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.
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.
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:
Henderson Club Limited
Personal Data Privacy Officer
Address: 71/F. Two International Finance Centre, 8 Finance Street, Central, Hong Kong.
Attention to: Henderson Club
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.