Personal Information Processing Rules

Personal Information Processing Rules (Members)

Beijing Hong Kong Jockey Club Clubhouse is operated and managed by Beijing Hong Kong Jockey Club Clubhouse Limited, a company incorporated under the laws of the People’s Republic of China (“the PRC”, for the purpose of the Rules only, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan), with its registered address at No. 68 Jinbao Street, Dongcheng District, Beijing (“the Club”, “we”, “us” or “our”). The Club is committed to ensuring the confidentiality and security of the personal information managed by the Club. This Personal Information Processing Rules (“the Processing Rules” or “the Rules”) are intended to help you understand how the Club may collect and use your information, your options for managing your information and privacy and the Club’s resolve to protect your information and privacy.

The Processing Rules apply to the websites, applications and other online channels of the Club and the facilities, goods and services offered offline by the Club. Meanwhile, we may amend and update the Rules from time to time in accordance with the requirements of applicable laws and regulations or changes in our business.

Latest update version: November 3rd, 2021

If you have any questions, comments or suggestions, please contact the Club via the contact details set out in Article 11 below.

The Processing Rules will help you understand the following:

1. How we collect and use your personal information
2. How we share, transfer, and publicly disclose your personal information
3. How we protect your personal information
4. Your rights
5. How we process personal information of minors
6. Retention of personal information
7. Cross-border transmission
8. Special instructions on links to third party websites
9. Cookies policy
10. Updates of the Processing Rules
11. How to contact us
12. Interpretation

The Club empathises with the importance you attach to your personal information and will make every effort to protect its security and reliability. The Club is committed to maintaining your trust in us and abiding by the following principles in protecting your personal information: parity of power and responsibility, explicitly setting out the purposes, consent based, data minimisation, ensuring safety, subject participation, and openness and transparency, etc. At the same time, the Club promises that, we will protect your information by taking measures in line with widely recognised security standards within the industry.

Please read and understand the Processing Rules carefully before registering as a member of, using in any manner the services or facilities of, and/or purchasing goods from the Club. If you register as a member or purchase or use any facilities, goods or services of the Club, it means that you fully understand the Rules and agree that the Club may collect, store, use, process, transmit, provide, publicise, and/or delete your personal information in accordance with the Rules. If you do not agree to any part of the Rules, please do not provide your personal information to, purchase goods from, or use the services and facilities of the Club.


1. How we collect and use your personal information
1.1 Information necessary for providing facilities, goods and services to you
1.1.1 To process your application for the Club’s membership (including evaluation and approval of the membership application and qualification to use certain facilities, goods and/or services) and any follow-up administrative or membership affairs work, the Club may collect and use your name, gender, date of birth, nationality, marital information (including marriage certificate and marital status), length of residence in the PRC, employment background (such as incumbency certificate, name of employer, income, length of employment, company address, telephone number, professional qualifications, and related information), contact information (such as email address, mailing address and home address, telephone number and facsimile number, etc.), education background, photo, relations with other Club members, data used to verify the identity (including the types of identity, identity certificates - such as passport, ID card, home-visit certificate, Taiwan Compatriot Pass, Hong Kong, Macau and Taiwan ID card, work visa - and other relevant information), social service information, information on any adverse personal record, personal credit reports, income or tax payment certificate, and other supplemental information (“Membership Information”);
1.1.2 In addition, you may provide the Club with the personal information of other persons (such as that of your spouse, children or guests) for the purposes under Article 1.1.1 above, including their names and genders, dates of birth, nationalities, lengths of residence in the PRC, employment information (such as names of employers, incomes, lengths of employment, company addresses, telephone numbers, etc.), contact information (such as email addresses, mailing addresses and residential addresses, telephone numbers and facsimile numbers), photos, information used to verify their identities (including the types of identity, identity certificates - such as birth certificate, passport, ID card, home-visit certificate, Taiwan Compatriot Pass, Hong Kong, Macau and Taiwan ID card - and other relevant information), marriage information (including marriage certificate and marital status) and other supplemental information. In such case, you are required to obtain the authorisation of the relevant persons before you use or disclose their personal information to the Club. Upon the request of the Club, you agree to provide the Club with any necessary supporting documents to evidence such authorisation. You agree to procure such persons’ access to the Rules and to inform them that they may contact the Club for more information;
1.1.3 When you make a payment or when the Club processes your payments, advanced payment, advanced deposits or outstanding payment obligations, the Club may collect and use financial information (e.g. bank account or credit card information, billing information, invoice information and payment records) provided by you;
1.1.4 When you place an order for our goods or when the Club makes delivery arrangements, the Club may collect and use buyer’s information (e.g. member’s name, membership number, ID card, phone number), name of consignee, delivery address, postal code, phone number of consignee, etc. provided by you;
1.1.5 In order to operate and maintain facilities, goods, services, and systems of the Club and to maintain records of visitors and their use of the facilities and services of the Club, the Club may collect and use your Membership Information (e.g. member's name, membership number, and contact information) and records on your use of the Club’s facilities;
1.1.6 In order to manage and provide you with on-site connectivity services at the Club (such as Wi-Fi, television, library amenities, and entertainment system), the Club may collect and use your Membership Information (including member's name, membership number, mobile phone number), guest room number, MAC address, URL, website addresses, and IP addresses);
1.1.7 When you use the website or mobile applications of the Club, the Club may collect and use information on your device (including the brand, model, operating system, configuration, unique equipment identifier, network service provider information, app display language and other information on the device environment), geographical location, browsing history, clicks on our website/applications, routine operations and diagnostic data, and service log (including search records, IP addresses, browser model, telecom operator, language used, date and time of access and other online behaviour);
1.1.8 When you get in touch with our staff (including when booking, registering for or using any of the Club’s or its affiliates’ restaurants, accommodations, conferencing, shopping and entertainment facilities and related goods and services; or submitting requests, enquiries, comments, and complaints to the Club) or when you send a message to the Club, the Club may collect and use your Membership Information (including member number, name, gender, mobile phone number, email address, date of birth, nationality), social network ID, check-in/check-out date, reservation number, invoice information, the content of your message and enquiries, and any other information you may have provided;
1.1.9 When processing the insurance claims and payments, the Club may collect and use your identity documents, household registration information, medical records, payment vouchers, bank card information and billing information provided by you;
1.1.10 When you choose to complete questionnaires or responding to surveys, the Club may collect and use any other information that you may provide to the Club.
1.2 Information collected by the Club to enhance your membership experience or promote the facilities, goods or services of the Club
In order to provide you with better services, for the purposes set out in this Article 1.2, the Club may collect and process Membership Information (and information relating to your spouse and children you provide in accordance with Article 1.1.2) and other information including information given in your interviews or related reports (including employment information, personal experience and family information), data collected when you visit, participate in activities of or purchasing goods from the Club, including hobbies, shopping records, usage of special social networks, social networks ID, language, favourite goods, purchasing details, usage of clubhouse facilities, ways of using services, service preferences, and data collected when you browse our website, including behavioural data recorded using cookies or similar technologies, as described below in our Cookies policy below:1
1.2.1 The Club may, for the purpose of enhancing your experience in the clubhouse or with the Club’s services, process your personal information (such as your Membership Information, data collected when you visit the clubhouse) to enhance or improve the existing facilities, goods or systems (including testing and upgrading of these systems) or to design or develop new facilities, goods and systems.
1.2.2 The Club may conduct indirect user profiling, data analysis (such as analysing trends, usage, and other user behaviour) and commercial exploitation of big data applications by analysing your habits as reflected in the information the Club collects and manages about you (e.g. your preferences and details of your transactions using your account etc.).
1.2.3 For the purpose of providing personalised services or carrying out research analysis, to send, by telephone, correspondence, e-mail, text messages, magazine and multimedia messages, social networks and instant messaging etc., information about facilities, goods, charitable or non-profit programs and activities offered or arranged by the Club, its affiliated companies or their respective business partners, or information about similar activities organised by or involved in the Club, its affiliated companies or their respective business partners (including potential invitations to attend such activities), and to send questionnaires in order to assess the satisfaction of the services provided. If you do not want to receive such correspondences, you may unsubscribe according to the method provided in the message in question.
1.3 Information collected for the performance of relevant obligations or protection of the legal rights of the Club
The Club may collect and use your personal information if required by relevant laws and regulations, agreements, or related legal procedures in order to comply with such requirements or obligations, including the information collected and used in accordance with this Article 1 and/or any personal information or data provided by you in the course of entering into agreement between you and the Club.
1.3.1 Meeting any obligations, requirements or arrangements (whether compulsory or voluntary), or establishing, exercising or defending any legal rights of the Club, in connection with:
a) Any existing or future law, regulation, judgment, court order, sanctions regime, within or outside the PRC;
b) Any guidelines, directions, demands or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside the PRC;
c) Any of the Club’s bye-laws, policies and procedures; or
d) Any agreements between you and the Club.
1.3.2 Complying with any obligations, requirements, policies, procedures, measures or arrangements to share information and news of the Club and/or to use such information and news in other ways in accordance with relevant programmes for sanctions compliance or prevention or detection of money laundering, terrorist financing or other unlawful activities;
1.3.3 Preventing, detecting or investigating anomalies and preventing and/or remediating fraud or other potentially prohibited or illegal activities or otherwise protecting the integrity of the Club and its affiliated companies;
1.3.4 Responding or taking part in legal proceedings, including seeking professional advice.
1.4 Information collected through third parties
1.4.1

Third party code and plug-ins. The Club’s website will make use of third-party Software Development Kits (SDK).

1.4.2 Third party services. In order to confirm transaction status and provide you with after-sales services, we will collect your transaction, payment, and logistics information (including member’s name, contact information, name of consignee, phone number of consignee) from the transaction method, payment institution, and logistics company you choose for the transaction in question, or share your transaction information with the above-mentioned service providers.
1.4.3 Other sources. Where permitted by applicable laws, we may obtain additional information about you from third party service providers and/or our business partners and combine this information with the information we have about you. For example, we may obtain the results of the background check from the service provider for the purpose of assessing and verifying your membership eligibility. In that circumstance, the Club may request the third party to confirm it has obtained the personal information from a legitimate source, and only use the information within the scope of the authorisation given by you. In addition, in order to comply with domestic or foreign sanctions or laws and regulations on the prevention or detection of money laundering, terrorist financing activities or other illegal activities, the Club may collect relevant personal information from the service providers for the purpose of complying with our obligations under the aforementioned laws and regulations. We may request third parties to confirm it has obtained the personal information from a legitimate source and only use the information as permitted under relevant laws and regulations.
1 Please refer to Article 9 for the Club’s policy on the use of cookies.
2. How we share, transfer, and publicly disclose your personal information
2.1 Share
We may share your personal information with third parties such as our affiliated companies and business partners to facilitate provision of services to you. However, we will only share the personal information for purposes that are legitimate, proper, necessary, specific and clear and only to the extent necessary. Such third parties may be entities within or outside of the PRC, including:
2.1.1 Affiliated companies: for our regular operation and provision of services to you, the Club may share your personal information with our affiliated companies to facilitate your use of facilities, goods, or services of the Hong Kong Jockey Club2.
2.1.2 Financial institution or third party payment institution: when you make a payment or apply to reverse your payment, the Club may share the specific order and transaction information with the financial institutions or third party payment institutions. Where the Club deems necessary for detecting or preventing fraud, we will further share other necessary information such as IP addresses with relevant financial institutions. When the Club make an insurance claim (including public liability insurance claim), the Club shall share the ID certificate, household registration information, medical records and payment vouchers with the insurance institutions.
2.1.3 Business partners: the Club may provide goods or services to you together with business partners. Such business partners include companies that provide courier services, payment processing, order fulfilment, information technology and related infrastructure, membership services, email transmission, marketing, technical services and consulting services.
2.1.4 Sharing by means of access to third party code and plug-ins:
Name Interface Purpose of Provision and Description of Scenarios Types of Personal Information Provided Name and Contact Information of the Data Recipient
Adobe Web Java Statistical analysis of website data Customer web behaviour (e.g. Page, Clicks, visits, etc) Adobe
https://marketing.adobe.com
Device/Browser/Network info
User identity
Geo
Time/ Date
2.1.5 In addition, your personal information may also be processed by the following companies:
  a) companies sending newsletters, marketing materials and promotional information;
  b) consulting firms sending questionnaires for marketing analysis;
  c) individuals, companies, associations or professionals who provide consulting services (lawyers, accountants and auditors).
  We will agree in writing with the above companies on the purpose, duration, method of processing, types of personal information involved, protection measures, rights and obligations of both parties and will monitor their personal information processing activities.
  For companies, organizations and individuals with whom we share personal information, we will enter into appropriate data processing agreements with them, requiring them to handle personal information in accordance with our instructions and any other relevant confidentiality and security measures. In addition, we will also carry out personal information protection impact assessment, and will only start sharing personal information upon successful completion of the assessment. If you want to know more about such data recipients, please contact us through the contact information set out in Article 11 below.
2.2 Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
2.2.1 With your explicit consent;
2.2.2 In the event of a merger, division, liquidation or bankruptcy, we will require the new company or organisation that will obtain your personal information to remain bound by the Processing Rules or to otherwise obtain your consent separately.
2.3 Public disclosure
We will only publicly disclose your personal information under the following circumstances:
2.3.1 With your explicit consent;
2.3.2 As required by law: we may publicly disclose your personal information when required by law, legal procedures, litigation, or compulsory government authorities.
2 If you want to know more about our affiliated companies, please contact us via the contact information set out in Article 11 below.
3. How we protect your personal information
3.1 We are committed to protecting the security of your personal information. We will use a variety of physical, technological and organisational measures to help protect your personal information from unauthorised or accidental access, processing, deletion or other use. We also ensure that our employees receive appropriate training in relation to the protection of personal information.
3.2 The transmission of information via the internet or mobile network is not completely secure. The security measures described above do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not guarantee that our servers or network will be immune from such attacks. Although we will implement security measures to protect your personal information, we cannot guarantee security of the data transmitted via internet or mobile network. You agree that the Club shall not be liable for any loss or damage arising from risks relating to any transmission.
3.3 In order to respond to personal information security incidents, we will comply with reporting and notification obligations required by laws and regulations, the scope of the notification may include: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, remedial measures for you, etc. Where applicable, we will promptly inform you of the relevant circumstances of the incident by email, letter, telephone call, push notification, etc. If it is difficult to inform the individuals affected one by one, we will take a reasonable and effective way to publish an announcement. Meanwhile, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
4. Your rights
4.1 Access, reproduce, rectify, and delete your personal information
You have the right to access, reproduce, rectify, and delete your personal information, subject to the exceptions provided by laws and regulations. You also have the right to request the transmission of personal information, provided that it complies with the law. To exercise the aforesaid rights or require us to provide an explanation, please contact us via the contact information set out in Article 11 of the Rules.
4.2 Withdraw consent and change the scope of consent
4.2.1 We process your personal information on the basis of your consent. You can withdraw your consent at any time by contacting us via the contact information set out in Article 11 of the Rules below, whereupon you should specify the consent you would like to withdraw. Unless otherwise permitted by law, upon withdrawal of your consent, we will no longer process your personal information. This decision will not affect the personal information processing activities conducted based on your authorisation before such withdrawal.
4.2.2 By contacting us via the contact information set out in Article 11 below, you may change the scope in your consent with respect to the collection and use of the information you provide.
4.3 De-registrate your membership account
4.3.1 You may contact us via the contact information set out in Article 11 of the Rules at any time to de-registrate your membership account, and we will respond to your de-registration request within 15 working days.
4.3.2 Upon the de-registration of your membership account, we will stop providing you with goods or services based on the account, and delete or anonymise your personal information as per your request, unless otherwise provided by laws and regulations.
5. How we process personal information of minors
5.1 We attach great importance to the protection of the minors’ personal information (i.e. children under the age of 14), therefore, we have developed special rules on processing of minors’ personal information based on the Processing Rules to clarify relevant matters in relation to the protection of minors’ personal information. Please refer to our Rules on Processing Minors’ Personal Information and Instructions to Guardians for details. We have no intention to collect personal information from minors, unless upon the agreement of their parents or guardians and only if such collection is necessary for the provision of goods, services, facilities or membership to the minors (e.g., personal information of a minor is required if he or she is a holder of the Beijing Hong Kong Jockey Club Clubhouse Supplementary Card, etc.).
5.2 If you are under 14, you should only provide your personal information to us if your parent or guardian expressly consent to the provision of your personal information in accordance with the Processing Rules. Your use of the services, facilities and membership of the Club and/or your purchase of any goods from the Club shall be under the guidance and consent of your parent or guardian. If your parents or guardians subsequently withdraw the consent for you relating to the provision of your personal information to us, you should immediately cease the provision of such personal information, refrain from using the services, facilities and membership of the Club and/or cease in purchasing any goods from the Club, and notify us of such withdrawal without delay so as to allow us to take appropriate measures.
5.3 If we find that we have collected minors’ personal information without the prior consent of a verifiable parent or guardian of such minor, we will delete the relevant data in accordance with the law.
6. Retention of personal information
For the purpose of collection as set out herein and for the performance of the Club's obligations under the relevant contracts, laws and regulations, all personal information collected from you by the Club shall only be stored for a reasonable period of time, for example:
6.1 Your Membership Information collected for the purposes under Article 1.1 above (and the information of your spouse and children as provided under Article 1.1.2) will be stored for a period of seven (7) years after the termination of your membership;
6.1 Your personal information collected for the purposes stated in Article 1.1.3 and Article 1.1.9 above shall be stored for a period of thirty (30) years from the date of collection as required by applicable laws and regulations;
6.2 The personal information you provide in interviews, collected for the purposes under Article 1.2.3 above, will be stored permanently after publication.
  However, please note that under certain circumstances, we may retain your personal information for longer period of time, for instance we may be required to do so to fulfil certain legal, regulatory, tax or accounting requirements.
7. Cross-border transmission
7.1 As the Club provides facilities, goods or services to you through cross-border resources and servers, the Club may have to make cross-border transmission of your personal information in order to complete your orders, process your information or provide the relevant services. To the extent permitted by the PRC laws, the Club may, with your separate consent, transmit the collected personal information out of the PRC or share it with our affiliated companies, suppliers or business partners for processing3 . The Club will take all steps reasonably necessary to ensure that your personal information is handled securely and in accordance with the Processing Rules and applicable laws.
7.2 If cross-border transmission will be made beyond the scope as stipulated herein, we will obtain separate authorisation from you and fulfil the conditions precedent for cross-border transmission as required by relevant laws and regulations on personal information protection.
7.3 Upon the receipt of your separate consent and fulfilment of relevant conditions precedent for cross-border transmission, your personal information may be transmitted to, or subject to the access from, offshore jurisdictions of the countries or regions from which your facilities, goods or services are located. Such jurisdictions may have different data protection laws, or even fail to do so. In such cases, we shall ensure that your personal information is accorded adequate and equivalent protection within the territory of the PRC. For example, we may request a separate consent from you for cross-border transmission or carry out security measures such as de-identification of data before cross-border data transmission.
3 You may contact us at any time via the contact information set out in Article 11 hereof with respect to the names and contact information of these entities.
8. Special instructions on links to third party websites
The Club’s websites may contain links to other sites and pages which are operated by third parties. You understand and acknowledge that we have no control over and do not endorse the content of the linked websites or the way in which the operators of those websites deal with your personal information. You should review the personal information processing rules for those third party websites to understand the ways in which your personal information may be used by those third parties.
9. Cookies policy
9.1 By using our website and mobile applications, you agree that we can store and access cookies, IP addresses and use other methods in order to collect website usage data and enhance your on-line experience.
9.2 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.
9.3 We use cookies on our websites to track visitor preferences. These cookies allow the websites to remember information that changes the way the websites behave or look, such as your preferred languages. These cookies can also assist you in changing text size, font and other parts of the website that you can personalize. However, please note that we cannot control the transfer of data on electronic communication facilities (including the internet), therefore, we will not take any responsibilities for the security breaches or unauthorized disclosure or use of such data on the internet. You may refuse to accept cookies by altering the settings on your internet browser but it should be noted that if you choose not to permit cookies, some areas of the websites may not function properly.
10. Updates of the Processing Rules
You acknowledge and agree that we will post on our website at https://www.beijingclubhouse.com/zh-CN/privacystatement.aspx changes to the Processing Rules from time to time, we shall mark the latest update date of the Processing Rules and such rules shall come into effect after being publicised. Without your explicit consent, we will not mitigate your rights under the Processing Rules. For major changes to the Processing Rules, we will provide prominent notifications (including changes of certain personal information processing matters, in which circumstance we will send a notice to you by email, letter or other contact means explaining the specific changes and obtaining your separate consent (if required)). You are kindly requested to read the latest version of the Processing Rules.
11. How to contact us
If you have any questions, concerns or suggestions regarding the Processing Rules, you may contact our Data Privacy Compliance Officer. We reserve the right to charge a reasonable fee for the processing of requests for access or rectification of your personal information.
You may direct your request in writing to:
  • Data Privacy Compliance Officer
    No.68 Jinbao Street, Dongcheng District Beijing, 100005, P.R.C.
    Tel: (86 10) 5911 8888
    E-mail: membership@hkjc.com.cn
12. Interpretation
This Processing Rule is written in Chinese and may be translated into English and other languages. The Chinese version shall have the same legal validity as other translated versions. In the event of any inconsistency between the Chinese version and the translated versions of this Processing Rule, the Chinese version shall prevail.

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Personal Information Processing Rules (Non-Members)

Beijing Hong Kong Jockey Club Clubhouse is operated and managed by Beijing Hong Kong Jockey Club Clubhouse Limited, a company incorporated under the laws of the People’s Republic of China (“the PRC”, for the purpose of the Rules only, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan), with its registered address at No. 68 Jinbao Street, Dongcheng District, Beijing (“the Club”, “we”, “us” or “our”). The Club is committed to ensuring the confidentiality and security of the personal information managed by the Club. This Personal Information Processing Rules (“the Processing Rules” or “the Rules”) are intended to help you understand how the Club may collect and use your information, your options for managing your information and privacy and the Club’s resolve to protect your information and privacy.

The Processing Rules apply to the websites, applications and other online channels of the Club and the facilities, goods and services offered offline by the Club. Meanwhile, we may amend and update the Rules from time to time in accordance with the requirements of applicable laws and regulations or changes in our business.

Latest update version: November 3rd, 2021

If you have any questions, comments or suggestions, please contact the Club via the contact details set out in Article 11 below.

The Processing Rules will help you understand the following:

1. How we collect and use your personal information
2. How we share, transfer, and publicly disclose your personal information
3. How we protect your personal information
4. Your rights
5. How we process personal information of minors
6. Retention of personal information
7. Cross-border transmission
8. Special instructions on links to third party websites
9. Cookies policy
10. Updates of the Processing Rules
11. How to contact us
12. Interpretation

The Club empathises with the importance you attach to your personal information and will make every effort to protect its security and reliability. The Club is committed to maintaining your trust in us and abiding by the following principles in protecting your personal information: parity of power and responsibility, explicitly setting out the purposes, consent based, data minimisation, ensuring safety, subject participation, and openness and transparency, etc. At the same time, the Club promises that, we will protect your information by taking measures in line with widely recognised security standards within the industry.

Please read and understand the Processing Rules carefully before using in any manner the services or facilities of, and/or purchasing goods from the Club. If you purchase or use any facilities, goods or services of the Club, it means that you fully understand the Rules and agree that the Club may collect, store, use, process, transmit, provide, publicise, and/or delete your personal information in accordance with the Rules. If you do not agree to any part of the Rules, please do not provide your personal information to, purchase goods from, or use the services and facilities of the Club.


1. How we collect and use your personal information
1.1 Information necessary for providing facilities, goods and services to you
1.1.1 When you use the facilities and services of the Club, the Club may collect and use your name, gender, date of birth, nationality, marital information, contact information (such as email address, mailing address and home address, telephone number and facsimile number, etc.), data used to verify the identity (including the types of identity, ID card number and other relevant information) and other supplemental information (“Identity Information”).
1.1.2 When you make a payment or when the Club processes your payments, advanced payment, advanced deposits or outstanding payment obligations, the Club may collect and use financial information (e.g. bank account or credit card information, billing information, invoice information and payment records) provided by you;
1.1.3 When you place an order for our goods or when the Club makes delivery arrangements, the Club may collect and use buyer’s information, name of consignee, delivery address, postal code, phone number of consignee provided by you;
1.1.4 In order to operate and maintain facilities, goods, services, and systems of the Club and to maintain records of visitors and their use of the facilities and services of the Club, the Club may collect and use your Identity Information (including name and contact information) and records on your use of the Club’s facilities;
1.1.5 In order to manage and provide you with on-site connectivity services at the Club (such as Wi-Fi, television, library amenities, and entertainment system), the Club may collect and use your name, guest room number, mobile phone number, MAC address, internet links and destination address;
1.1.6 When you use the website or mobile applications of the Club, the Club may collect and use information on your device (including the brand, model, operating system, configuration, unique equipment identifier, network service provider information, app display language and other information on the device environment), geographical location, browsing history, clicks on our website/applications, routine operations and diagnostic data, and service log (including search records, IP addresses, browser model, telecom operator, language used, date and time of access and other online behaviour);
1.1.7 When you get in touch with our staff (including when booking, registering for or using any of the Club’s or its affiliates’ restaurants, accommodations, conferencing, shopping and entertainment facilities and related goods and services; or submitting requests, enquiries, comments, and complaints to the Club) or when you send a message to the Club, the Club may collect and use your Identity Information (including name, gender, mobile phone number, email address, date of birth, nationality), social network ID, check-in/check-out date, reservation number, invoice information, the content of your message and enquiries, and any other information you may have provided;
1.1.8 When processing the insurance claims and payments, the Club may collect and use your identity documents, household registration information, medical records, payment vouchers provided by you;
1.1.9 When you choose to complete questionnaires or responding to surveys, the Club may collect and use any other information that you may provide to the Club.
1.2 Information collected by the Club to enhance your experience or promote the facilities, goods or services of the Club
In order to provide you with better services, for the purposes set out in this Article 1.2, the Club may collect and process Identity Information and other information including information collected when you visit, participate in activities of or purchasing goods from the Club, including hobbies, shopping records, usage of special social networks, social networks ID, language, favourite goods, purchasing details, usage of clubhouse facilities, ways of using services, service preferences, and data collected when you browse our website, including behavioural data recorded using cookies or similar technologies, as described below in our cookies policy below: 4
1.2.1 The Club may, for the purpose of enhancing your experience in the clubhouse or with the Club’s services, process your personal information (such as your Identity Information, data collected when you visit the clubhouse) to enhance or improve the existing facilities, goods or systems (including testing and upgrading of these systems) or to design or develop new facilities, goods and systems.
1.2.2 The Club may conduct indirect user profiling, data analysis (such as analysing trends, usage, and other user behaviour) and commercial exploitation of big data applications by analysing your habits as reflected in the information the Club collects and manages about you (e.g. your preferences and details of your transactions using your account etc.).
1.2.3 For the purpose of providing personalised services or carrying out research analysis, to send, by telephone, correspondence, e-mail, text messages, magazine and multimedia messages, social networks and instant messaging etc., information about facilities, goods, charitable or non-profit programs and activities offered or arranged by the Club, its affiliated companies or their respective business partners, or information about similar activities organised by or involved in the Club, its affiliated companies or their respective business partners (including potential invitations to attend such activities), and to send questionnaires in order to assess the satisfaction of the services provided. If you do not want to receive such correspondences, you may unsubscribe according to the method provided in the message in question.
1.3 Information collected for the performance of relevant obligations or protection of the legal rights of the Club
The Club may collect and use your personal information if required by relevant laws and regulations, agreements, or related legal procedures in order to comply with such requirements or obligations, including the information collected and used in accordance with this Article 1 and/or any personal information or data provided by you in the course of entering into agreement between you and the Club.
1.3.1 Meeting any obligations, requirements or arrangements (whether compulsory or voluntary), or establishing, exercising or defending any legal rights of the Club, in connection with:
e) Any existing or future law, regulation, judgment, court order, sanctions regime, within or outside the PRC;
f) Any guidelines, directions, demands or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside the PRC;
g) Any of the Club’s bye-laws, policies and procedures; or
h) Any agreements between you and the Club.
1.3.2 Complying with any obligations, requirements, policies, procedures, measures or arrangements to share information and news of the Club and/or to use such information and news in other ways in accordance with relevant programmes for sanctions compliance or prevention or detection of money laundering, terrorist financing or other unlawful activities;
1.3.3 Preventing, detecting or investigating anomalies and preventing and/or remediating fraud or other potentially prohibited or illegal activities or otherwise protecting the integrity of the Club and its affiliated companies;
1.3.4 Responding or taking part in legal proceedings, including seeking professional advice.
1.4 Information collected through third parties
1.4.1 Third party code and plug-ins. The Club’s website will make use of third-party Software Development Kits (SDK).
1.4.2 Third party services. In order to confirm transaction status and provide you with after-sales services, we will collect your transaction, payment, and logistics information (including buyer’s name, contact information, name of consignee, phone number of consignee) from the transaction method, payment institution, and logistics company you choose for the transaction in question, or share your transaction information with the above-mentioned service providers.
1.4.3 Other sources. Where permitted by applicable laws, we may obtain additional information about you from third party service providers and/or our business partners and combine this information with the information we have about you. In that circumstance, the Club may request the third party to confirm it has obtained the personal information from a legitimate source, and only use the information within the scope of the authorisation given by you. In addition, in order to comply with domestic or foreign sanctions or laws and regulations on the prevention or detection of money laundering, terrorist financing activities or other illegal activities, the Club may collect relevant personal information from the service providers for the purpose of complying with our obligations under the aforementioned laws and regulations. We may request third parties to confirm it has obtained the personal information from a legitimate source and only use the information as permitted under relevant laws and regulations.
4 Please refer to Article 9 for the Club’s policy on the use of cookies.
2. How we share, transfer, and publicly disclose your personal information
2.1 Share
We may share your personal information with third parties such as our affiliated companies and business partners to facilitate provision of services to you. However, we will only share the personal information for purposes that are legitimate, proper, necessary, specific and clear and only to the extent necessary. Such third parties may be entities within or outside of the PRC, including:
2.1.1 Affiliated companies: for our regular operation and provision of services to you, the Club may share your personal information with our affiliated companies to facilitate your use of facilities, goods, or services of the Hong Kong Jockey Club5.
2.1.2 Financial institution or third party payment institution: when you make a payment or apply to reverse your payment, the Club may share the specific order and transaction information with the financial institutions or third party payment institutions. Where the Club deems necessary for detecting or preventing fraud, we will further share other necessary information such as IP addresses with relevant financial institutions. When the Club make an insurance claim (including public liability insurance claim), the Club shall share the ID certificate, household registration information, medical records and payment vouchers with the insurance institutions.
2.1.3 Business partners: the Club may provide goods or services to you together with business partners. Such business partners include companies that provide courier services, payment processing, order fulfilment, information technology and related infrastructure, email transmission, marketing, technical services and consulting services.
2.1.4 Sharing by means of access to third party code and plug-ins:
Name Interface Purpose of Provision and Description of Scenarios Types of Personal Information Provided Name and Contact Information of the Data Recipient
Adobe Web Java Statistical analysis of website data Customer web behaviour (e.g. Page, Clicks, visits, etc) Adobe
https://marketing.adobe.com
Device/Browser/Network info
User identity
Geo
Time/ Date
2.1.5 In addition, your personal information may also be processed by the following companies:
  d) companies sending newsletters, marketing materials and promotional information;
  e) consulting firms sending questionnaires for marketing analysis;
  f) individuals, companies, associations or professionals who provide consulting services (lawyers, accountants and auditors).
  We will agree in writing with the above companies on the purpose, duration, method of processing, types of personal information involved, protection measures, rights and obligations of both parties and will monitor their personal information processing activities.
  For companies, organizations and individuals with whom we share personal information, we will enter into appropriate data processing agreements with them, requiring them to handle personal information in accordance with our instructions and any other relevant confidentiality and security measures. In addition, we will also carry out personal information protection impact assessment, and will only start sharing personal information upon successful completion of the assessment. If you want to know more about such data recipients, please contact us through the contact information set out in Article 11 below.
2.2 Transfer
We will not transfer your personal information to any company, organization or individual, except in the following cases:
2.2.1 With your explicit consent;
2.2.2 In the event of a merger, division, liquidation or bankruptcy, we will require the new company or organisation that will obtain your personal information to remain bound by the Processing Rules or to otherwise obtain your consent separately.
2.3 Public disclosure
We will only publicly disclose your personal information under the following circumstances:
2.3.1 With your explicit consent;
2.3.2 As required by law: we may publicly disclose your personal information when required by law, legal procedures, litigation, or compulsory government authorities.
5 If you want to know more about our affiliated companies, please contact us via the contact information set out in Article 11 below.
3. How we protect your personal information
3.1 We are committed to protecting the security of your personal information. We will use a variety of physical, technological and organisational measures to help protect your personal information from unauthorised or accidental access, processing, deletion or other use. We also ensure that our employees receive appropriate training in relation to the protection of personal information.
3.2 The transmission of information via the internet or mobile network is not completely secure. The security measures described above do not preclude us from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and we do not guarantee that our servers or network will be immune from such attacks. Although we will implement security measures to protect your personal information, we cannot guarantee security of the data transmitted via internet or mobile network. You agree that the Club shall not be liable for any loss or damage arising from risks relating to any transmission.
3.3 In order to respond to personal information security incidents, we will comply with reporting and notification obligations required by laws and regulations, the scope of the notification may include: the basic situation and possible impact of the security incident, the measures we have taken or will take, suggestions for you to prevent and reduce risks, remedial measures for you, etc. Where applicable, we will promptly inform you of the relevant circumstances of the incident by email, letter, telephone call, push notification, etc. If it is difficult to inform the individuals affected one by one, we will take a reasonable and effective way to publish an announcement. Meanwhile, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
4. Your rights
4.1 Access, reproduce, rectify, and delete your personal information
You have the right to access, reproduce, rectify, and delete your personal information, subject to the exceptions provided by laws and regulations. You also have the right to request the transmission of personal information, provided that it complies with the law. To exercise the aforesaid rights or require us to provide an explanation, please contact us via the contact information set out in Article 11 of the Rules.
4.2 Withdraw consent and change the scope of consent
4.2.1 We process your personal information on the basis of your consent. You can withdraw your consent at any time by contacting us via the contact information set out in Article 11 of the Rules below, whereupon you should specify the consent you would like to withdraw. Unless otherwise permitted by law, upon withdrawal of your consent, we will no longer process your personal information. This decision will not affect the personal information processing activities conducted based on your authorisation before such withdrawal.
4.2.2 By contacting us via the contact information set out in Article 11 below, you may change the scope in your consent with respect to the collection and use of the information you provide.
5. How we process personal information of minors
5.1 We attach great importance to the protection of the minors’ personal information (i.e. children under the age of 14), therefore, we have developed special rules on processing of minors’ personal information based on the Processing Rules to clarify relevant matters in relation to the protection of minors’ personal information. Please refer to our Rules on Processing Minors’ Personal Information and Instructions to Guardians for details. We have no intention to collect personal information from minors, unless upon the agreement of their parents or guardians and only if such collection is necessary for the provision of goods, services or facilities to the minors.
5.2 If you are under 14, you should only provide your personal information to us if your parent or guardian expressly consent to the provision of your personal information in accordance with the Processing Rules. Your use of the services, facilities of the Club and/or your purchase of any goods from the Club shall be under the guidance and consent of your parent or guardian. If your parents or guardians subsequently withdraw the consent for you relating to the provision of your personal information to us, you should immediately cease the provision of such personal information, refrain from using the services, facilities of the Club and/or cease in purchasing any goods from the Club, and notify us of such withdrawal without delay so as to allow us to take appropriate measures.
5.3 If we find that we have collected minors’ personal information without the prior consent of a verifiable parent or guardian of such minor, we will delete the relevant data in accordance with the law.
6. Retention of personal information
For the purpose of collection as set out herein and for the performance of the Club's obligations under the relevant contracts, laws and regulations, all personal information collected from you by the Club shall only be stored for a reasonable period of time, for example, your personal information collected for the purposes stated in Article 1.1.2 and Article 1.1.8 above shall be stored for a period of thirty (30) years from the date of collection as required by applicable laws and regulations.
However, please note that under certain circumstances, we may retain your personal information for longer period of time, for instance we may be required to do so to fulfil certain legal, regulatory, tax or accounting requirements.
7. Cross-border transmission
7.1 As the Club provides facilities, goods or services to you through cross-border resources and servers, the Club may have to make cross-border transmission of your personal information in order to complete your orders, process your information or provide the relevant services. To the extent permitted by the PRC laws, the Club may, with your separate consent, transmit the collected personal information out of the PRC or share it with our affiliated companies, suppliers or business partners for processing6. The Club will take all steps reasonably necessary to ensure that your personal information is handled securely and in accordance with the Processing Rules and applicable laws.
7.2 If cross-border transmission will be made beyond the scope as stipulated herein, we will obtain separate authorisation from you and fulfil the conditions precedent for cross-border transmission as required by relevant laws and regulations on personal information protection.
7.3 Upon the receipt of your separate consent and fulfilment of relevant conditions precedent for cross-border transmission, your personal information may be transmitted to, or subject to the access from, offshore jurisdictions of the countries or regions from which your facilities, goods or services are located. Such jurisdictions may have different data protection laws, or even fail to do so. In such cases, we shall ensure that your personal information is accorded adequate and equivalent protection within the territory of the PRC. For example, we may request a separate consent from you for cross-border transmission or carry out security measures such as de-identification of data before cross-border data transmission.
6 You may contact us at any time via the contact information set out in Article 11 hereof with respect to the names and contact information of these entities.
8. Special instructions on links to third party websites
The Club’s websites may contain links to other sites and pages which are operated by third parties. You understand and acknowledge that we have no control over and do not endorse the content of the linked websites or the way in which the operators of those websites deal with your personal information. You should review the personal information processing rules for those third party websites to understand the ways in which your personal information may be used by those third parties.
9. Cookies policy
9.1 By using our website and mobile applications, you agree that we can store and access cookies, IP addresses and use other methods in order to collect website usage data and enhance your on-line experience.
9.2 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.
9.3 We use cookies on our websites to track visitor preferences. These cookies allow the websites to remember information that changes the way the websites behave or look, such as your preferred languages. These cookies can also assist you in changing text size, font and other parts of the website that you can personalize. However, please note that we cannot control the transfer of data on electronic communication facilities (including the internet), therefore, we will not take any responsibilities for the security breaches or unauthorized disclosure or use of such data on the internet. You may refuse to accept cookies by altering the settings on your internet browser but it should be noted that if you choose not to permit cookies, some areas of the websites may not function properly.
10. Updates of the Processing Rules
You acknowledge and agree that we will post on our website at https://www.beijingclubhouse.com/zh-CN/privacystatement.aspx changes to the Processing Rules from time to time, we shall mark the latest update date of the Processing Rules and such rules shall come into effect after being publicised. Without your explicit consent, we will not mitigate your rights under the Processing Rules. For major changes to the Processing Rules, we will provide prominent notifications (including changes of certain personal information processing matters, in which circumstance we will send a notice to you by email, letter or other contact means explaining the specific changes and obtaining your separate consent (if required)). You are kindly requested to read the latest version of the Processing Rules.
11. How to contact us
If you have any questions, concerns or suggestions regarding the Processing Rules, you may contact our Data Privacy Compliance Officer. We reserve the right to charge a reasonable fee for the processing of requests for access or rectification of your personal information.
You may direct your request in writing to:
  • Data Privacy Compliance Officer
    No.68 Jinbao Street, Dongcheng District Beijing, 100005, P.R.C.
    Tel: (86 10) 5911 8888
    E-mail: membership@hkjc.com.cn
12. Interpretation
This Processing Rule is written in Chinese and may be translated into English and other languages. The Chinese version shall have the same legal validity as other translated versions. In the event of any inconsistency between the Chinese version and the translated versions of this Processing Rule, the Chinese version shall prevail.

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Rules on Processing Minors’ Personal Information and Instructions to Guardians

Beijing Hong Kong Jockey Club Clubhouse is operated and managed by Beijing Hong Kong Jockey Club Clubhouse Limited, a company incorporated under the laws of the People's Republic of China (“the PRC”, for the purpose of the Rules only, excluding Hong Kong Special Administrative Region, Macau Special Administrative Region and Taiwan), with its registered address at No. 68 Jinbao Street, Dongcheng District, Beijing (“the Club”, “we”, “us” or “our”). The Club is committed to ensuring the security and privacy of the minors’ personal information (i.e. children under the age of 14, same hereinafter), therefore, on the basis of the Personal Information Processing Rules, the Club wishes to, through this Rules on Processing Minors’ Personal Information and Instructions to Guardians (“the Processing Rules” or “the Rules”), explain the handling rules with which the Club collects and uses minors’ personal information and other relevant matters. Please read and fully understand the Rules before you allow your children use the facilities or purchases/uses the goods/services provided by the Club, and please do not use or allow your children to use the facilities or services provided by the Club until you understand and agree to all terms herein.

Special instructions:

  • Your understanding and cooperation are necessary for us to protect the personal information and privacy of your children. In order to safeguard the legitimate rights and interests of your children, we hope that you can assist us to ensure that your children’s use of the facilities, purchase/use of goods and services, provision of their personal information are all within your consent and guidance. We will take special measures to protect the personal information of your children obtained by us according to the Rules. If you do not agree to the Rules, please ask your child to immediately stop using the Club’s facilities or purchasing/using the Club’s goods/services.
  • Minors must obtain prior consent from their parent or guardian before using any facilities of the Club or purchase/use any goods/service of the Club. If you are a “minor”, please inform your parent or guardian to read the Rules and seek his/her consent and guidance before you use any of the Club’s facilities, goods or services or submit any personal information.

Latest update version: November 3rd, 2021

The Processing Rules will help you understand the following:

1. How we collect and use minors’ personal information
2. How we share, transfer, and publicly disclose minors’ personal information
3. How we store minors’ personal information
4. How we protect minors’ personal information
5. How we deal with minors’ personal information
6. Updates to the Processing Rules
7. How to contact us
8. Interpretation

1. How we collect and use minors’ personal information
1.1 By voluntarily providing the Club with the personal information of your children when applying for the Club’s membership (if applicable), you have agreed that the Club may collect and use the personal information of your children according to the Rules for the purpose of providing facilities, goods and/or services to you and your children. If you do not agree to provide your children’s personal information, your children will not be able to enjoy the facilities, goods and services provided by the Club.
1.2 During your or your children’s use of the facilities of the Club and purchase/use of the goods/services of the Club, the Club may collect and use other personal information of your children for the purpose of providing you or your children with the relevant facilities, goods and services. For the specific purposes for such use or scope of the said minors’ personal information collected for such purposes, please refer to the section titled “How we collect and use your personal information” in the Personal Information Processing Rules7.
1.3 The Club may also collect personal information about you or your children through cookies or other technologies, you may refer to the section titled “Cookies policy” in the Personal Information Processing Rules for more information.
1.4 In addition, please be reminded that under certain circumstances, the Club is unable to identify and determine whether the personal information collected and processed falls under the scope of minors’ personal information. In such case, the Club will collect and process such personal information in strict accordance with Personal Information Processing Rules.
7 The Personal Information Processing Rules is available on the website of the Club at https://www.beijingclubhouse.com/zh-CN/privacystatement.aspx for your perusal. Same hereinafter.
2. How we share, transfer, and publicly disclose minors’ personal information
2.1 The Club may only share, transfer and publicly disclose minors’ personal information in compliance with the Rules and your explicit authorisation and consent, you may refer to the section titled “How we share, transfer, and publicly disclose your personal information” in the Personal Information Processing Rules for more information.
2.2 If it is necessary to share minors’ personal information with a third party, the Club will evaluate the legality, legitimacy and necessity of the collection of minors’ personal information by the third party. In addition, the Club shall require the third party to take measures to protect the minors’ personal information and strictly abide by the relevant laws and regulations and supervision requirements. The Club will require the third party receiving the minors’ personal information to comply with strict confidentiality obligations and take effective confidentiality measures so as to prohibit the third party from using the minors’ personal information for the purposes not authorised by the children and their guardians.
3. How we store minors’ personal information
3.1 The minors’ personal information collected and generated by the Club in the territory of the PRC will be stored within the territory of the PRC.
3.2 As the Club provides facilities, goods or services through cross-border resources and servers, the Club may have to make cross-border transmission of your children’s information in order to complete the relevant orders, process the relevant information or provide the relevant services. To the extent permitted by the PRC laws, the Club may, with your separate consent, transmit the minors’ personal information collected to a location outside of the PRC or share it with our affiliated companies, suppliers or business partners for further processing. You may refer to the section titled “Cross-border transmission” in the Personal Information Processing Rules for more information.
3.3 For the purpose of collection as set out herein, all minors’ personal information collected from you by the Club shall only be stored for a reasonable period of time. Under certain circumstances, we may retain minors’ personal information for longer period of time, for instance we may be required to do so to fulfil certain legal, regulatory, tax or accounting requirements. You may refer to the section titled “Retention of personal information” in the Personal Information Processing Rules for more information.
4. How we protect minors’ personal information
The Club attaches great importance to your children’s privacy, and will take all reasonable and feasible measures to protect the minors’ personal information. The Club shall strictly control the access to the minors’ personal information and adopt the principle that only the minimum number of staff necessary to process minors’ personal information are authorised to get access to the personal information of such minors, in addition, the Club will take technical measures to record and control the staff's processing of the minors’ personal information so as to avoid illegal copying or downloading of such information. If you wish to know more about the measures taken by the Club to protect the minors’ personal information, please refer to the section titled “How we protect your personal information” in the Personal Information Processing Rules for more information.
5. How we deal with minors’ personal information
For the minors’ personal information collected and processed by the Club, you may contact the Club via the contact information set out in Article 7 of the Rules for access, reproduction, rectification or deletion of the minors’ personal information and other relevant actions, if you have any opinions, suggestions, complaints or reports concerning the matters of minors’ personal information, you may also contact the Club as specified in Article 7 of the Rules for further handling.
6. Updates to the Processing Rules
You acknowledge and agree that we may post on our website at https://www.beijingclubhouse.com/zh-CN/privacystatement.aspx changes to the Rules from time to time, we shall mark the latest update date of the Processing Rules and such Rules shall come into effect as and when published online. Without your explicit consent, we will not reduce your and your children’s rights under the Processing Rules. For major changes to the Rules, we will provide prominent notifications (including changes of certain minors’ personal information processing matters, in which circumstance we may send a notice to you by email, letter or other contact means explaining the specific changes and obtaining your separate consent (if required)). You are kindly requested to read the latest version of the Processing Rules.
7. How to contact us
If you have any questions, concerns or suggestions regarding the Rules, you may contact our Data Privacy Compliance Officer. We reserve the right to charge a reasonable fee for the processing of requests for access or rectification of your and your child’s personal information.
You may direct your request in writing to:
  • Data Privacy Compliance Officer
    No.68 Jinbao Street, Dongcheng District Beijing, 100005, P.R.C.
    Tel: (86 10) 5911 8888
    E-mail: membership@hkjc.com.cn
8. Interpretation
This Processing Rule is written in Chinese and may be translated into English and other languages. The Chinese version shall have the same legal validity as other translated versions. In the event of any inconsistency between the Chinese version and the translated versions of this Processing Rule, the Chinese version shall prevail.

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