Customer Data (Privacy) Policy

Sino Club Limited ("Sino Club", "we", "our") operates a membership-based loyalty programme for the Sino Group ("Club") and collects personal data (including but not limited to your name, email address, telephone number and residential/correspondence address) provided by you (whether as a user of our website, a participant in our functions and activities, an applicant for Club membership or a Club member, collectively known as the "customers") via various means, including our website, mobile application, social media platforms, questionnaires, Club application forms and registration forms for our functions and activities, including classes, competitions and lucky draws.


Collection of customers' personal data

The collection of any personal data will be subject to this Customer Data (Privacy) Policy and any separate Personal Information Collection Statement ("PICS") provided on or before data collection. Personal data is stored securely in our system and we will take all practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose (including any directly related purpose) for which the data is or is to be used. Only trained, authorized staff shall have access to the data, and we do not release personal data to third parties except as set out in this Customer Data (Privacy) Policy and any separate PICS.

We do not collect any personal data from customers during their browsing of our websites. When customers visit our websites we record their visit only as a 'hit' and do not collect any personal data from them. We will however make a record of their visit including but not limited to their Domain Name Server address, part of their e-mail address, browser type, access time and the pages visited. We use such information only for preparing general statistics on the usage of our websites.

If customers apply to become a member of the Club or sign up for our functions or activities, the customers are required to supply all the personal data and other information requested in the relevant form in order to enable Sino Club to consider his/her application or participate in the Club activities. The provision of personal data is voluntary, however, failure to do so may result in Sino Club being unable to process the application or allow participation in the Club activities (as the case may be).

Upon the acceptance of the application, copies of required documents provided by the club members at the time of application shall be retained by Sino Club for verification and audit purposes.


Use of customers’ personal data

Sino Club will use your personal data for specific purposes identified in the PICS provided to you on or before your personal data is collected. The purposes of collecting personal data also include:

1. Identifying you and verifying your identity;
2. Processing membership applications for the Club;
3. Communicating with you in respect of your use of Club services, products, mobile application and/or website;
4. Daily operation and administration of the Club, including but not limited to account creation and maintenance, processing and provision of benefits and services;
5. Monitoring and analysing usage of Club services, products, mobile application and/or website to help the further development and improvement of Club services, products, mobile application and/or website;
6. Research and development in relation to customer behavior;
7. Information management and database administration;
8. With your consent, marketing products, services and other subjects to you (please refer to Direct Marketing section below);
9. Identifying, contacting or bringing legal action against someone who may be violating these terms or may be causing injury to or interference with (either intentionally or unintentionally) our rights or property, other users, or anyone else that could be harmed by such activities;
10. Complying with disclosure requirements under applicable law;
11. Any other purpose directly relating to the above purposes.


Cookies and other Tracking Mechanisms

In order for us to provide customers with customizable and personalized services, we use 'cookies' to store and sometimes track information about customers who have visited or logged-in to our website. The information collected by means of 'cookies' includes but not limited to customers' login name and his or her navigation pattern. This is done without customers being aware that it is occurring. Generally, we use 'cookies' to estimate our audience size; to track customers' progress and number of entries in our promotional activities; to assist us in tracking visits and to measure customers' traffic patterns. Personal Information collected by means of 'cookies' will not be disclosed to any third parties except to those parties within our Group.

If you interact with any social media platforms under the Sino Group, Sino Group can interact with you, for examples, sending messages to you on the platforms and following the rules of the social media platforms. We are not responsible for how the social media operators collect, handle and use your Personal Information and what third parties post on our social media platforms.


Accuracy of Information

Customers may be requested to provide certain personal data to Sino Club for specific services. If customers fail to provide or update accurate information as requested for each specific service, the provision of such service by Sino Club may be affected.


Retention of Information

Sino Club will retain customers’ personal data for a period no longer than necessary for the fulfillment of the purposes for which the data is or is to be used. If customers have subscribed to Sino Club services, their personal data will be retained for a reasonable period after termination of their subscription for verification and audit purposes. The above is subject to any legal, statutory, regulatory or accounting requirements.


Third Party Merchants and/or Websites

Sino Club may have online stores or some services and/or products which are hosted in the Sino Club website but are operated by third party merchants. If customers provide their personal data to any third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that such collection of personal data is beyond the control of Sino Club and customers should review the respective privacy policies of third party merchants.

Sino Club website may from time to time contain links to other third party websites that are independent from Sino Club website. We have no control or management over the contents of such third party websites or their privacy policies or compliance with the law. Customers should be fully aware that the provisions of such links do not constitute an endorsement, approval, or any form of association by or with Sino Club and/or Sino Group. We have no control over the personal data submitted by customers, if any, to third party websites. This Customer Data (Privacy) Policy only applies to the Sino Club website. Customers should review the respective privacy policies of third party websites.


Transfer of customers' personal data

Sino Club will keep the personal data and information relating to the customers confidential but we may disclose, transfer (whether within or outside the Hong Kong Special Administrative Region) and/or exchange any such data and information to or with any and all of the following persons or entities for the purposes set out in the above:

1. any member of the Sino Group (which includes Sino Club Limited, Sino Real Estate Agency Limited, Sino Estates Management Limited, Sino Security Services Limited, Best Result Environmental Services Limited, Sino Parking Services Limited, The Royal Pacific Hotel & Towers, City Garden Hotel, Hong Kong Gold Coast Hotel, Island Pacific Hotel, The Pottinger Hong Kong, The Olympian Hong Kong, Sino Administration Services Limited, and their respective holding companies, subsidiaries or associated and/or related companies);
2. any firm, company, corporation, body or organisation providing club services, including providing privileges, benefits and other advantages to club members ("Relevant Person");
3. any agent, contractor or third party service provider who provides administrative, management, computer, technology outsourcing, cloud services, payment processing, data processing, marketing and research, distribution, telecommunications, accounting, auditing and other services to the Sino Club or any member of the Group in connection with the operation of our business and the provision of our facilities, services and/or products to the customers; or
4. government, law enforcement, regulatory or other authorities.


Direct marketing

Sino Club intends to use your name, residential/correspondence address, contact number and/or email address collected from you for direct marketing purpose with your consent (which includes an indication of no objection), which is required before doing so. We may use your personal data for direct marketing in accordance with the PICS provided to you on or before collection of your personal data. You may withdraw your direct marketing consent any time:

1. following the unsubscribe instructions or hyperlink in the marketing communication;
2. following the unsubscribe instructions in the mobile application or website; or
3. contacting us at the address stated at “Contact Us” below to tell us that you no longer wish to receive marketing communications through any channel.


Changes to this policy

Sino Club reserves the right to review, edit or otherwise change this policy at its sole discretion without prior notice, which will be effective immediately upon being posted on our website (unless your express consent is required). Customers are advised to check our website on a regular basis for any updates.


Security

We will take appropriate measures to safeguard data security. However, no data transmission over the internet can be guaranteed to be 100% secure. Accordingly, despite our effort to protect your personal information, we cannot guarantee or warrant the security of any information you transmit to us, or to or from our online products or services. You transmit all such information at your own risk. However, once we receive your transmission, we use our best endeavours to ensure its security on our own systems.

Customers are responsible for protecting their account password against unauthorized access. Customers are advised to sign out from their account when finished with online account activities, particularly when using a shared computer.


Contact us

Each customer has the right to request access to and correction of any of his/her personal data established to be inaccurate. Sino Club has the right to charge a reasonable fee for the processing of any data access request. Any data access request or data correction request may be made in writing to the Personal Data Privacy Officer of Sino Club (Address: 11-12/F, West Wing, Tsim Sha Tsui Centre, Salisbury Road, Tsim Sha Tsui, Kowloon). Sino Club will comply with any such request unless it may or is required to refuse to do so under the applicable laws and regulations.

If a customer wishes to opt out of receiving promotional message from Sino Club, please inform us via the following channels:

1. Email to Personal Data Privacy Officer at info@sinoclub.com
2. Request in writing and send to: Personal Data Privacy Officer, 11-12/F, West Wing, Tsim Sha Tsui Centre, Salisbury Road, Tsim Sha Tsui, Kowloon, Hong Kong.


Governing Version

If there is any inconsistency or conflict between the English and Chinese versions of this Customer Data (Privacy) Policy, the English version shall prevail.