Personal Data Collection Statement
1. GENERAL
1.1 This statement sets out the policies of WLAB in the collection, use, sharing and protection of members’ personal information. WLAB may update or change this statement from time to time and these changes will be posted on WLAB’s website.
2. PERSONAL DATA WLAB COLLECTS
2.1 WLAB may collect and/or request you to provide information about yourself via its website, in application forms or through other channels. The information WLAB collects or requests from you may include but is not limited to:
2.1.1. personal information such as your salutation, name and date of birth;
2.1.2. contact information such as your mobile telephone number(s), mailing address(es) and email address(es);
2.1.3. business information such as company name, business title and related contact information;
2.1.4. responses to market surveys and contests conducted by WLAB or on its behalf;
2.2. Personal data collected by WLAB may be used for either obligatory or voluntary purposes. If personal data are to be used for an obligatory purpose, you MUST provide your personal data to WLAB and if you fail to do so with a specific service, WLAB may be unable to provide that service in full. If personal data are only to be used for a voluntary purpose, you may tell WLAB not to use the personal data for that purpose and WLAB will not do so.
3. PURPOSE FOR COLLECTION AND USE OF PERSONAL DATA
Obligatory Purposes
3.1. WLAB may use 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, WLAB;
3.1.2. to respond, to, process and fulfil and otherwise handle your general enquiries and your requests for any products or services WLAB offers, however, such enquiries and requests are submitted;
3.1.3. the operation of WLAB including delivery of associated benefits and services, 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 services or products that may be supplied to you;
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.
Voluntary Purposes
3.2. WLAB may use your email address, postal address or telephone number (collectively in this statement, “contact data”) for one or more of the following voluntary purposes:
3.2.1. to administer contests and sweepstakes, including but not limited to disclosing the winner of any such contest; and
3.2.2. for direct marketing, promotional and member relationship management purposes.
In this connection:
(a) WLAB must obtain your consent (which can include an indication of no objection) to use your contact data for direct marketing;
(b) the following classes of products, services and subjects of WLAB, The DO, Wheelock Group Companies and other businesses may be marketed:
(i) products and services offered by WLAB, The DO and other Wheelock Group Companies in relation to property, shopping mall, travel, food and beverage, hotel and catering services;
(ii) reward, loyalty or privilege programs offered by third-party business partners of WLAB who are in the business of providing the classes of products, services and subjects set out in paragraphs 3.2.2(b) (iii)-(xi) below (“WLAB’s Partners”);
(iii) air travel and accommodation services and non-air transportation services such as hotel transfers, car rentals, limousine and taxi services, bus operators, train operators and cruise operators;
(iv) financial, insurance, credit card, banking, foreign exchange, and other related services and products;
(v) telecommunication, internet and mobile communication services;
(vi) food, wine and beverages and related services;
(vii) 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;
(viii) consumer electronics, computers and peripherals, printed matter including books, newspaper subscriptions and magazine subscriptions, audiovisual titles, computer software and games, mobile telephones and peripherals, toys, furniture, home furnishings, home appliances, houseware and tools, stationery, sporting equipment, fashion and apparel, watches and jewellery, 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 consent to the use of your contact data for these marketing purposes and the provision of your data to the persons mentioned in paragraph 3.4. below, please leave the opt-out box in the Application Form unchecked when applying to become a member.
3.3. WLAB may provide your contact data to WLAB’s partners for marketing its products, services and subjects listed in paragraph 3.2.2(b) above on WLAB’s behalf, both in and outside Hong Kong.
3.4. By agreeing to WLAB’s Terms and Conditions you agree that WLAB might provide your contact data to The DO, other Wheelock Group Companies and WLAB’s Partners for their use in marketing their own products, services and subjects as listed in paragraph 3.2.2(b).
3.5. If you do not want WLAB to use or provide to other persons your data for direct marketing as described above, you may opt-out anytime by:
3.5.1. following the “opt-out” instructions contained in these marketing communications; or
3.5.2. sending your “opt-out” instructions to WLAB via post to the address set out under paragraph 6.1.
3.6. Except as provided below under “5. Disclosure and Transfer of Personal Data”, WLAB 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 information about you held by WLAB. All requests for copies of, or to correct, your personal data and all other enquiries about the handling of your personal data by WLAB should be addressed in writing to WLAB at the address set out under paragraph 6.1. below.
4.2. WLAB may charge a reasonable fee to process data access request(s).
5. USE OF COOKIES
5.1 We use cookies across our websites to improve their performance and enhance User’s online experience. Session cookies are used to enable User to move around the site and use essential functions on our websites, such as maintaining log-in details for the session such that the need to transfer information across the internet may be reduced. We will not collect any personal data from the User when the cookies are being used.
6. DISCLOSURE AND TRANSFER OF PERSONAL DATA
6.1 WLAB 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 paragraphs 3.1. and 3.2.1 above, and (2) if you agree that WLAB may provide your personal data to other persons for their direct marketing purposes, the parties specified in paragraph 5.1.6 and 5.1.7 for the purposes set out in paragraph 3.2.2. (b) above: –
6.1.1. Any The DO and other Wheelock Group Company;
6.1.2. Any agent, contractor or third-party service provider providing administrative, research, distribution, data processing, telecommunications, computer, payment or other services to WLAB in connection with the operation of its program;
6.1.3. Any other business associates of WLAB such as WLAB’s Partners, loyalty program operators, hotel operators, retailers, restaurants and other companies necessary for offering or providing customer service or fulfilling customer requests in connection with WLAB’s programs;
6.1.4. Any person to whom WLAB, The DO or other Wheelock Group Companies are obliged or expected to disclose under any law or guidelines, regulations or other measures issued by regulatory or other authorities (including industry and self-regulatory bodies);
6.1.5. Any actual or proposed assignee of WLAB or participant or affiliated-participant or transferee of WLAB’s rights in respect of you;6.1.6. Provided you have agreed to the use of your personal data for direct marketing, our partners to market the products, services and subjects specified in paragraph 3.2.2. (b);
6.1.7. Provided you have agreed to WLAB’s Terms and Conditions you automatically provide your personal data to them, to other Wheelock Group Companies and WLAB’s Partners to market the products, services and subjects specified in paragraph 3.2.2(b);
6.1.8. And any other parties if the transfer of your personal data to any other parties is reasonably necessary or expedient for procuring or performing the services requested by you, then those other parties.
7. PRIVACY POLICY CONTACT DETAILS
7.1. All enquiries regarding WLAB’s compliance with its obligations under the Personal Data (Privacy) Ordinance (Cap. 486), opt-out requests or consents with the use of personal data for direct marketing and requests for access to data or correction of data should be made in writing to:
WLAB
Area A, 1/F, Block A-D,
Tung Kin Factory Building
No. 196-198, Tsat Tsz Mui Road,
Quarry Bay, Hong Kong SAR
7.2. If there is any inconsistency or conflict between the English and Chinese versions of this statement, the English version shall prevail.
[June 2021]