The Club's Commitment to Protect Your Privacy
Collection of Personal Data
From time to time and for the purpose of carrying on the Club's businesses and operations, including the provision of services and facilities to you, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data") such as, but not limited to, the following:
- Your name;
- Contact details such as email address, mailing and residential address, telephone number, and fax number;
- Membership number and details (such as transactions conducted using your membership account);
- Information for verification of identity, including identification type and identification number and other related information;
- Billing information such as your credit card number, bank account information and billing address;
- Demographic information such as age, gender, birthday, nationality, marital status, preferences, educational background and employment history;
- Details of transactions conducted using your account.
Supply of Personal Data to the Club is non-obligatory, but failure to do so may result in the Club being unable to process your application(s) or to provide facilities and services to you.
Occasionally, you may need to provide Personal Data about other individuals to the Club (e.g. spouse or children or guests). In that event, you are required to have first obtained the authorisation of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to the Club's possible use, disclosure and transfer of their Personal Data, for the purposes you would want to achieve from the Club. If necessary, the Club may require you to provide to the Club any supporting documents which may be necessary to prove such authorisation. You should also advise them that the Club can be contacted for further information.
Use of Personal Data
Your Personal Data may be used for the following purposes:
- Providing facilities, goods, services and support or performing transactions and administration work related to the following operations of the Club:
a) the Club's core operations of membership; and/or
b) clubhouses, catering, hospitality, conferences and entertainment;
- Processing of your application to subscribe to the Club's services and facilities as set out in paragraph 1;
- Conducting assessments and checks regarding eligibility for membership, facilities or services;
- Verifying your identity;
- Monitoring access to the Club's premises;
- Matching your Personal Data with other data collected (by the Club or third parties) for other purposes, in relation to, the provision of facilities, goods and services to you and/or the performance of any transactions and administration work related to the Club's operations;
- Marketing and advertising of any facilities, goods and services to you by the Club and Club Entities (as defined below), such as sending you offers and promotions (please see further details in "Direct Marketing" below);
- Maintaining and developing the Club's business systems and infrastructure, including testing and upgrading of these systems;
- Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, of the Club to comply with, or in connection with:
a) any law, regulation, judgment, court order, sanctions regime, within or outside the People's Republic of China ("PRC") existing currently and in the future;
b) any guidelines, guidance, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside the PRC; or
c) any of the Club's rules or bye-laws relating to the Club's core operations.
- Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the Club and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
- Prevention, detection or investigation of crime; and/or
- Facilitating communications between you and the Club.
The Club may also use from time to time aggregate non-identifying information about its customers to better design and improve the Club's facilities, goods and services that it offers. This information will not identify any individual in particular.
The Club intends to use your Personal Data for direct marketing carried out by the Club, The Hong Kong Jockey Club ("HKJC") or an associated company or subsidiary of the HKJC (together referred to as the "Club Entities" or individually referred to as a "Club Entity") (or by an agent on behalf of the Club or a Club Entity), and for such purposes your Personal Data held by the Club may be provided to other Club Entities for their use for direct marketing. The intended kinds of Personal Data to be used and the intended classes of marketing subjects are specified below. However, the Club may not so use or provide your Personal Data unless exempted or permitted by applicable laws or regulations or the Club has received your consent.
For the above direct marketing use, the Club intends to:
- use your name, contact details and demographic information; and
- market or promote the following classes of facilities, goods, services, support and related events and activities offered or arranged by the Club or a Club Entity or their respective business partners:
b) clubhouses, catering, hospitality, conferences and entertainment;
c) affinity cards, smart or stored value cards issued by or co-branded with the Club; and/or
d) Charitable or Non-Profit Making causes or events.
You can always opt-out free-of-charge by contacting the Club's Data Privacy Compliance Officer if you no longer wish any of your Personal Data to be used in any of the described direct marketing purposes.
Disclosure of Personal Data
Personal Data supplied to the Club will be kept confidential. However, the Club may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, provide such Personal Data to the following parties:
- any Club Entities for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above), and to the Club's business partners for direct marketing use as described in "Direct Marketing" above;
- any person or company who is acting for or on behalf of the Club, or jointly with the Club, in respect of the purpose or a directly related purpose for which the data was provided;
- any other person or company who is under a duty of confidentiality to the Club and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
- the Club's agents, contractors, suppliers and any third party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to the Club in connection with the operations of its business;
- government and regulatory authorities, investigative bodies and law enforcement agencies and other organisations, as required or authorised by law;
- any financial institutions, including banks, necessary to establish and support the payment of any services and facilities provided to you; and
- your authorised representatives or your legal advisers when requested by you to do so.
The Club may also disclose your Personal Data to third parties: (i) when required by law, by court order or in response to a search warrant or other legally valid inquiry; or (ii) pursuant to the Club's good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defences, to obtain legal advice, to exercise and defend the Club's legal rights or to protect the life, body or property of any individual. This also applies when the Club has reason to believe that disclosing the Personal Data is necessary to identify, contact or bring legal action against someone who may be causing interference with the Club's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by activities causing such interference.
The Club may also transfer any information it holds about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Club or as part of a corporate reorganisation or other change in corporate control. The Personal Data that the Club collects or obtains may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. By submitting Personal Data to the Club or using any of the Club's services and facilities, you understand and consent to such transfer.
Links to Third Party Websites
By using the Club's website ("Website") and mobile apps, you agree that the Club can store and access cookies, IP addresses and use other methods in order to collect website usage data and improve your on-line experience.
Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the website owners.
All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.
Commitment to Data Security
The Club is committed to protecting the security of your Personal Data. It uses a variety of physical, technological and organisational measures to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.
Access to and Correction of Personal Data
You are entitled to request access to Personal Data held by the Club about you and to correct such data. The Club may charge a reasonable fee for the processing of such data access request.
You may direct your request in writing to:
- Membership Administration Department
No. 68 Jinbao Street, Dongcheng District
Beijing, 100005, P.R.C.
This notice is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.