Privacy Policy

1. Pledge
Hong Kong Golf & Tennis Academy (“HKGTA”) pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region.

2. Collection of Information
You may be invited to provide to HKGTA your personal data on the HKGTA’s website(s) or through other media on a voluntary basis for different purposes at different times. If you are under the age of 18, you should obtain consent from your parent or guardian before you provide HKGTA with your personal data.

3. Use of Cookies, Log Files and other Tracking Mechanisms
When you browse the website(s) or mobile application(s) of HKGTA, cookies will be stored in your computers, mobile phones or other devices for internal navigation and programming only. In addition, the servers of HKGTA will only collect data relating to your visits (including but not limited to your Internet Protocol (‘IP”) address, domain name, browser type and access time) but will not collect your personal data.
We use cookies and other tracking mechanisms described below to track information about your use of HKGTA’s website(s) or mobile application(s). We may combine this information with other personal information we collect from you. Cookies are alphanumeric identifiers that we transfer to your computers, mobile phones or other devices through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate HKGTA’s website(s) or mobile application(s), while others are used to enable a faster log-in process, or to allow us to store and track information about your interests and preferences at HKGTA’s website(s) or mobile application(s). You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functionality of the website(s) or mobile application(s) of HKGTA and this may impact your user experience. We may also engage third parties to track and analyse non-personally identifiable data from the website(s) or mobile application(s). We use the data collected by such third parties to help us administer and improve the quality of HKGTA’s website(s) or mobile application(s) and to analyse Site usage. Such third parties may combine the information that we provide about you with other information that they have collected. This Privacy Policy does not cover such third parties’ use of the data.

4. Kinds of Information Collected
For the different purposes in the course of conducting HKGTA’s business, you may be required to provide to HKGTA your personal data, which may include your name, gender, nationality, e-mail address, mailing address, contact number, patron number, age group, marital status, family status, educational level, occupation, identification document number, household income group, consumption pattern, credit card information, username, etc. Details of personal data and information to be collected will be set out in the relevant Personal Information Collection Statement (“PICS”) provided to you upon collection of such data and information.

5. Main Purposes and Uses of Information Collected
HKGTA may use your personal data for
(A) Purposes relating to its daily operation of your patron account, administration of your patron accounts and records, marketing analysis, research and development, advertising, marketing, public relations;
(B) Direct marketing (including cross-marketing) of (i) services and products offered by HKGTA or at HKGTA’s premises, (ii) in relation to charity (which includes solicitation of donation for the purpose of relief of poverty, advancement of education, advancement of religion and other charitable purposes) and (iii) provisions by HKGTA, New World Group, HKGTA Business Partners or HKGTA Service Providers (as defined in clause 8 below) of goods, facilities, and/or services in respect of properties development and management, consumer products, jewelleries, hospitality and/or transportation (collectively, the “Classes of Marketing Items”);
(C) Communicating our news and information;
(D) Identification for provision of goods, services and benefits offered by HKGTA or at HKGTA’s premises;
(E) Information and database administration;
(F) Collection or recovery of any debt owed by you to HKGTA;
(G) Matters relating to a transfer of the business of or any shares in HKGTA or a change in the shareholding of HKGTA or an amalgamation of HKGTA with another body; and
(H) Complying with any statutory or regulatory requirements.

6. Accuracy of Information
You may be requested to provide to HKGTA certain personal data (particularly relating to your contact information) for specific services. If you fail to provide or update accurate information as requested for each specific service, the provision of such services by HKGTA may be affected. If you wish to correct or update your personal data held by HKGTA, please write to the Personal Privacy Officer of HKGTA at the address shown below.

7. Retention of Information
HKGTA will retain your personal data for a period no longer than necessary for the fulfilment of the purposes for which they are or are to be used. In general, personal data of a subscriber or patron of HKGTA will be retained for a period of not more than six years after termination of subscription or membership for verification, taxation and audit purposes.

8. Transfer and Disclosure of Information
For the purposes mentioned in clause 5 above, HKGTA may share your personal data with or transfer the same to: Hong Kong Golf & Tennis Academy Charity Foundation Limited, New World Property Management Company Limited and their respective holding companies, associated companies, fellow subsidiaries and/or subsidiaries who provide the Classes of Marketing Items (collectively, “New World Group”); The business associates and partners of HKGTA who provide the Classes of Marketing Items (collectively “HKGTA Business Partners”)
Agents, contractors, suppliers and service providers engaged by HKGTA to assist with providing you HKGTA’s services (including data processing service providers, mail processing service providers and information technology service providers) (collectively, “HKGTA Service Providers”); The extent that is permissible by law.

9. Direct Marketing and Opt-Out Direct Marketing
HKGTA cannot use your personal data for direct marketing purposes without your consent. By providing your personal data and consent to the use of your personal data for direct marketing purposes in the manner as prescribed in the Personal Information Collection Statement (PICS) provided to you when we collect your personal data, you have given consent to the use of your personal data for direct marketing purposes as set out in the PICS. You may withdraw your consent any time by writing to the Personal Data Privacy Officer of HKGTA at the address shown in paragraph 19 below.
HKGTA respects your right to opt-out from direct marketing. If you do not wish to receive any marketing information, from HKGTA or any of the company within New World Group or HKGTA Business Partners, or do not wish HKGTA to provide your contact details to any such company, please write to the Personal data Privacy Officer of HKGTA at the address shown in paragraph 19 below. After receipt of your opt-out request, HKGTA will include you on HKGTA’s opt-out list and notify any such company to cease to use your contact details in direct marketing.

10. Third Party Merchants
HKGTA may have online stores, online booking system or some services and/or products which are hosted in the website(s) or mobile application(s) of HKGTA but are operated by third party merchants. If you provide your personal data to the third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that your personal data is beyond the control of HKGTA and thus is outside the scope of protection afforded by HKGTA. You should read the respective privacy policies of other website(s) or mobile application(s) before you submit any personal data to the third parties.

11. Third Party Websites
The website(s) or mobile application(s) of HKGTA may from time to time contain linkages to other website(s) or mobile application(s). HKGTA has no control over your personal data submitted by you, if any, to other websites. This Privacy Policy Statement only applies to the website(s) or mobile application(s) of HKGTA. You should read the respective privacy policies of other website(s) or mobile application(s).

12. HKGTA Service Providers
HKGTA may provide your personal data to HKGTA Service Providers as mentioned in paragraph 8 above. In these cases, HKGTA Service Providers are required to use your personal data consistent with the agreements HKGTA enters into with them as well as this Privacy Policy Statement.

13. Security of Information
The physical records of your personal data will be stored in secured places with restricted access. The electronic records of your personal data will be stored in the servers of HKGTA located in secured places and protected by adequate IT security measures (e.g. encryption for transmission of sensitive data through the Internet in appropriate cases). Only authorized personnel of HKGTA (who have been trained to handle your personal data properly and bound by a duty of confidentiality) will have access to these records and servers on a “need-to-know” and “need-to-use” basis.

14. Exclusion
HKGTA may disclose your personal data as required by law, by any government departments, regulatory authorities, enforcement agencies and courts of competent jurisdiction where the disclosure is permitted under any applicable exemption provisions in the Personal Data (Privacy) Ordinance. HKGTA excludes all liability for disclosure of your personal data in this manner.

15. Use in Legal Proceedings etc.
If it becomes necessary for HKGTA to take action against you for recovering from you the debt you owe to HKGTA, you agree that your personal data can be used by HKGTA in identifying and taking legal action against you.

16. Access and Correction of Information and Withdrawal of Consent
You have the right to request in writing to the Personal Data Privacy Officer of HKGTA: For access to your personal data held by HKGTA (if any); Require HKGTA to correct your personal data that is inaccurate (if any); and
Withdraw your consent to the use of your personal data (such withdrawal may, however, affect our services to you).
All such requests will be handled promptly in accordance with the requirements of the Personal Data (Privacy) Ordinance. HKGTA may charge a reasonable fee for processing your data access request.

17. Change of Privacy Policy
This Privacy Policy Statement may from time to time be updated, revised and changed. Any change, update or modification will be effective immediately upon being posted on website(s) or mobile application(s) of HKGTA. You are advised to check it on a regular basis.

18. Change of Control
If the ownership of certain business of HKGTA changes, HKGTA may need to transfer your personal data to the new owner of such business so the new owner may continue to operate the business subject to the condition that the new owner shall make use of your personal data in accordance with this Privacy Policy Statement. You will be notified of such transfer and you may decide to withdraw your consent to the use of your personal data.

19. Enquiries and Requests
If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by HKGTA, please contact the Personal Data Privacy Officer of HKGTA at:
Hong Kong Golf & Tennis Academy
1711, 17th Floor, New World Tower One 18 Queen’s Road Central Hong Kong
Attention: Personal Data Privacy Officer (Marked Confidential)