PRIVACY POLICY STATEMENT

Go Royal by SHKP (“Go Royal”) is operated and managed by Sun Hung Kai Real Estate Agency Ltd. It is the policy of Go Royal to comply with the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of Hong Kong. We also strive to ensure compliance by our staff with the strictest standards of security and confidentiality.

We safeguard information provided by Go Royal members, mobile application (“App”) users, and website users (“User”). With the only exceptions that personal data may be collected in relation to the services of membership application, membership renewal, membership/account maintenance, email registration, Go Royal programme activities and the giving/collection of opinion online, and the IP address of the computer used to visit our website may be recorded, we do not collect any personally identifiable information from User while they use the App and website, and no personal data is collected, unless specified. This information is used only for preparing general statistics on the usage of our App and website.

We use cookies across our website (including the App) in order to improve their performance and enhance User’s online experience. Session cookies are used to enable User to move around the site and use essential functions on our websites (including the App), such as maintaining log-in details for the session such that the need to transfer information across the internet may be reduced. We will not collect any personal data from User when the cookies are being used.

The collection of any personal data collected will be subject to our Personal Information Collection Statement. Personal data is stored securely in our system and Go Royal will take all practicable steps to ensure that personal data is not kept longer than is necessary for (i) the fulfilment of the purpose (including any directly related purpose) for which the data is or is to be used and (ii) the purpose of compliance with legal, regulatory or internal policy requirements. The information will either be irreversibly anonymized or securely disposed when it is no longer needed. Only trained, authorized staff shall have access to the data, and we do not release personal data to parties outside Go Royal except as set out in our Personal Information Collection Statements. User has the right to request access to and correction of their personal information in accordance with the procedure set out in our Personal Information Collection Statements.

Go Royal may, from time to time, send direct marketing materials promoting products and services to User based on their personal data, but suitable opt-out mechanisms are provided.

Go Royal makes every effort to protect the privacy of User, but given the nature of the Internet, we cannot guarantee perfect security.

Go Royal uses third party content and service and product providers and offers links to third party websites. These third parties may collect personal data from Users and they adhere to their own privacy policies. Whilst there are always risks associated with the transmission of data over the internet (including by email), we take proactive steps to manage these risks and work with those third parties or business partners who share our view on the importance of protecting your data. We endeavor to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

User who has any questions about our privacy policy and practice can contact our Data Protection Officer at dpo@shkp.com or by post to 45/F Sun Hung Kai Centre, 30 Harbour Road, Wan Chai, Hong Kong.

Personal Information Collection Statement

This Personal Information Collection Statement (“PICS”) sets out the purposes for which the information provided by you as a User will be used following collection, what you are agreeing to with respect to our use of such information and your rights under the Personal Data (Privacy) Ordinance, Cap 486. This PICS may be subject to amendments. Any future changes or additions to the processing of personal information as described in this PICS affecting you will be communicated to you through an appropriate channel. When you complete the application form to join our membership and/or services by submitting thereon or each time you log in to this App and website and use its services, you agree to be bound by the PICS in force at that time.

Collection of Data

User may be asked to provide with personally-identifiable information such as name, contact number and email address. This is necessary to provide User the various services and activities offered on this App and website. You, as a User, are not obliged to supply the data, but if you do not, the services and activities will be unavailable.

IP address of the computer used to visit our website may be recorded.

Go Royal is open to individuals aged 18 or above.

Purpose and Use of Data

Information collected is used for the followings:

• providing the services and information relating to such services to you including any renewal or recurrent services thereof;

• processing billing and payment;

• monitoring use of the App and website to help its further development;

• compiling aggregate statistics about our users to analyse App and website usage;

• collecting data for identity verification and record and maintaining contact lists for correspondence;

• operating internal control, resolving disputes, troubleshooting problems and enforcing terms of use;

• creating accounts for User who intends to register with the services offered on this App and website and maintaining such accounts;

• registering membership for User who intends to join Go Royal and maintenance of the membership;

• identifying and verifying identity and/or eligibility of the User who uses/used and/or applies/applied for the services offered on our App and website and/or by Go Royal;

• researches and/or analysis by Go Royal and/or participating hotels including The Royal Garden, Royal Plaza Hotel, Royal Park Hotel, Royal View Hotel, ALVA HOTEL BY ROYAL (collectively “Participating Hotels”) and/or Sun Hung Kai Properties Limited and/or any of its subsidiaries or associated companies (“the Group”);

• meeting any requirements to make disclosure under any applicable law;

• any other purpose which an applicant or member may from time to time agree;

• communicating with User in respect of matters related to or arising from the use of the services offered on this Go Royal App and website and/or by Go Royal;

• providing information related to Go Royal including the products, facilities, services and other privileges, benefits and other advantages from time to time offered by the Group or Third Party Service Providers to User and rallying and arranging for the same to be provided (see also Use of Information in Direct Marketing);

• evaluating and improving the facilities, services and/or products offered by Go Royal and/or Participating Hotels;

• facilitating communications between User and Go Royal and encouraging feed-back from User on their needs and expectations of facilities, services and/or products offered by Go Royal and/or Participating Hotels;

• in order to determine the User’s eligibility to any products, facilities, services and other privileges, benefits and other advantages offered by Go Royal and Participating Hotels and consider what may best suit User’s needs, comparing User’s personal information with all personal information concerning User previously provided to the Group;

Use of Information in Direct Marketing

Use of Information in Direct Marketing: We intend to use all information provided by you as a user including your name, contact details and all other information which may assist the Group and/or the Participating Hotels to understand the goods and services which you might be interested in, for delivering the aforesaid information and conducting direct marketing including products, services, advice and subjects in relation to the followings: Hong Kong and worldwide properties including residential, offices, commercial and industrial buildings, shops, hotels, shopping malls and the events therein, theme park and observatory deck, property management, construction, insurance, financial services, telecommunication, information technology, transport infrastructure operations and management, port business, transport and logistics, waste management, educational, recruitment, reward/loyalty/privilege programmes, corporate social responsibility activities, charitable and non-profitable causes. We also intend to, and in this regard you consent to, transfer and provide the abovementioned information to the Participating Hotels, the subsidiary and/or associated companies of the Group and the Third Party Service or Product Providers through whom the Groups and / or Third Party’s products, facilities, services, privileges, benefits or advantages are provided inside and outside Hong Kong for the said purpose. We may not so use or provide the said information unless we have received your consent. Your consent may be communicated to us without charge at the time when you provide such information through our website or by writing to our Data Protection Officer.

Transfer of Data

Members personal data will be kept confidential but we may transfer or disclose such personal data to (i) our contractors under a duty of confidentiality to us who provide administrative, telecommunications, computer, data processing or other services to us in connection with management, operation and maintenance of the system with the purpose of personal data collection; and (ii) the Group, the Third Party Service or Product Providers and the Participating Hotels for those purposes mentioned in this PICS and/or direct marketing purpose.

Use of Cookies

We use cookies across our websites in order to improve their performance and enhance Users online experience. Session cookies are used to enable User to move around the site and use essential functions on our websites, such as maintaining log-in details for the session such that the need to transfer information across the internet may be reduced. We will not collect any personal data from User when the cookies are being used.

Access to data

You have the right to request access to and correction of your personal data in accordance with the provisions of the Personal Data (Privacy) Ordinance (Cap.486). Any data access request or data correction request may be made to our Data Protection Officer at dpo@shkp.com or by post to 45/F Sun Hung Kai Centre, 30 Harbour Road, Wan Chai, Hong Kong.

If there is any inconsistency or conflict between the English and Chinese version, the English version shall prevail.

We will share with you the latest information about the Participating Hotels, Third Party Service Providers and/or Go Royal which might interest you. Should you not wish to receive direct marketing material and/or information from Go Royal, the participating hotels or Third Party Service Providers, you may exercise your opt-out right by notifying us in writing to Go Royal’s Data Protection Officer at its office situated at 45/F Sun Hung Kai Centre, 30 Harbour Road, Wan Chai, Hong Kong, or by email to dpo@shkp.com

Please be assured that even if you have chosen not to receive our direct marketing materials, we shall continue to honour your membership and you will continue to enjoy the benefits conferred accordingly thereunder. You can still learn of our offers on our website or notices at the various venues under the Group.

Go Royal by SHKP ("Go Royal" (also known as “帝賞” in Chinese), hereinafter referred to as "we", "our" or "us") is operated and managed by SUN HUNG KAI REAL ESTATE AGENCY LIMITED. We value your privacy. This Addendum applies to all the services we provide to you in connection with Go Royal whether you register to be a member through the "Go Royal WeChat Mini Programme” ("Mini Programme") or any other channel or means, and explains how we collect, store, use, process, transfer and/or disclose your personal information for purposes relating to Go Royal, including but not limited to when you visit, browse the Mini Programme, our APP or website, or interact with us via the Mini Programme or other channels or means, how we will protect your personal information, how you can manage your personal information, and how you can contact us regarding the processing of your personal information.

This Addendum supplements the Personal Information Collection Statement and Privacy Policy Statement of the "Go Royal by SHKP Hotel Loyalty Programme". If there is any inconsistency between the contents of this Addendum and Go Royal's Personal Information Collection Statement or Privacy Policy Statement, the contents of this Addendum shall prevail for the purposes of Mainland China's data protection laws and regulations and your personal information.

This Addendum is formulated in accordance with the applicable data protection laws and regulations of China. "Personal information" in this Addendum refers to all kinds of information related to identified or identifiable natural person's recorded by electronic or other means, excluding anonymized information. Personal information includes sensitive personal information as stipulated in China's data protection laws and regulations, i.e., personal information that, if leaked or used illegally, may easily lead to the infringement of the dignity of natural persons, or may seriously endanger their personal and property safety, including information relating to biometrics, religious beliefs, specific identities, healthcare, financial accounts, an individual’s whereabouts etc., and personal information of minors' under the age of 14.

You should read this Addendum carefully before providing your personal information to us. If you have any questions or concerns about how we process your personal information, you may contact us through the contact information set out at the end of this Addendum. If you do not agree with this Addendum, please do not provide your personal information to us.

This Addendum will describe the following contents:

1.    How we collect and use your personal information

2.   How we entrust, share, transfer and publicly disclose your personal information

3.   How we protect minors' personal information

4.   How we protect your personal information

5.   How we store your personal information

6.   Your rights as a personal information subject

7.    Updates to the Addendum

8.   How to contact us

1.    How we collect and use your personal information

The main purposes of obtaining your personal information are to provide you with Go Royal member registration, member login, membership maintenance, rewards redemption, activity registration and other services, and to continuously improve and enhance your experience. Some of the core functions of the Mini Programme or our APP or website require you to actively provide personal information to achieve the corresponding purposes (including but not limited to member registration, login, rewards redemption etc.), and if you are unable to provide the required personal information, we may not be able to provide you with the relevant functions.

1. 1.   When you apply for registration as a member of Go Royal, we will collect your English and Chinese name, title, birth month, age range, residence district and region, preset language, mobile number and email address. Once your registration is complete, we will automatically create a membership number for you.

1. 2.  When you log in to the Mini Programme or our APP, we will collect your mobile number and password.

1. 3.  You must present a valid Go Royal digital membership card through the Mini Programme or our APP to enjoy member benefits and earn points for your qualifying spending, stays and events.

1. 4.  When you use The Point Bonus Points to redeem rewards in the Mini Programme or our APP, we will collect your membership password to verify your identity. In addition, we will collect information about the rewards you redeem to provide redemption services. You must open the reward collection QR code on Mini Programme or our APP at participating hotels and restaurants for rewards collection.

1. 5.  During your use of our services, we may use your name, contact information (including email address and mobile number) and other information that helps us to understand the goods and services that may be of interest to you to provide you with commercial promotional information through email, text message, phone call etc.. If you do not wish to receive such communications, you may opt out of receiving them by selecting "Unsubscribe" or by contacting us through the contact information set out at the end of this Addendum to unsubscribe.

1. 6.  In order to continually optimize our services and enhance your experience, we may conduct internal research and/or analysis based on the contact information you provide and information on your rewards redemption and Go Royal activities registration.

1. 7.   When you use the Mini Programme or our APP or website, we may automatically collect certain information, including your IP address, device and network information, page view information, operation logs, device used etc., in order to ensure the safe operation of the Mini Programme or our APP or website, retain service logs and for internal analysis.

2.   How we entrust, share, transfer and publicly disclose your personal information

2.1    Entrust:

When our affiliates and business partners provide services for us to fulfill the purposes described in this Addendum (e.g., to conduct internal statistics, research and/or analysis), we may provide them with your personal information and engage them to assist us in processing such information. These business partners are not allowed to use your personal information in any way other than to provide services to us. We will require the relevant business partners to process personal information in accordance with contractual agreements, this Addendum and applicable laws and regulations.

2.2    Share:

·   Please understand that certain services of the Mini Programme or our APP are provided by third-party service/product providers, and in order to realize such services, we may share your necessary information with the relevant third-party service/product providers so that these third-party service/product providers can provide the relevant services to you. In order to provide you with account binding and payment facilities, we may cooperate with other electronic payment channels or credit card operators (collectively, the "Payment Channels"). In order to do so, we need to share the necessary membership data with the Payment Channels so that you can link your Go Royal membership account to your account with the Payment Channels.

·   We may transfer the "Go Royal by SHKP Hotel Loyalty Programme" including the Mini Programme to a third party in the event that we undergo a change or are involved in a merger, acquisition, reorganization, dissolution, or bankruptcy and liquidation etc. In such transactions, as an integral part of the "Go Royal by SHKP Hotel Loyalty Programme", your personal information will also be transferred to such third parties so that such third parties can continue to provide services to you on the "Go Royal by SHKP Hotel Loyalty Programme" including the Mini Programme. We will inform you of the name and contact details of the recipient and will require the recipient to process your personal information in the manner agreed in this Addendum. If such third parties holding your personal information need to use your personal information for purposes other than those set out in this Addendum, those third parties will obtain your consent, unless otherwise provided by applicable laws and regulations.

·   To make disclosures to the relevant law enforcement agencies, regulators, governments, courts or other third parties that we believe are necessary to (1) comply with an applicable law or regulation, (2) exercise, establish or defend our legal rights, or (3) protect your or any other person's important legitimate interests.

When required by applicable laws and regulations, we will inform you of the name and contact information of the third party, the purpose and method of processing, the types of personal information processed, and obtain your consent (or satisfy conditions of other lawful basis for processing personal information) prior to specific sharing, unless otherwise provided by applicable laws and regulations.

3.   How we protect minors'’ personal information

The "Go Royal by SHKP Hotel Loyalty Programme" including the Mini Programme and related services are not available to minors' under the age of 18.

We take the protection of minors' personal information very seriously. If you find that we may have collected personal information of minors' without your consent, please contact us through the contact information set out at the end of this Addendum. We will delete or otherwise deal with it after verification in accordance with the law and the request of the parent or guardian.

4.   How we protect your personal information

We take appropriate security measures to ensure the security of your personal information that we collect and process. These security measures include the use of encryption technology to store your personal information. Please be aware and understand that the Internet is not completely secure. If you become aware of a leak of your personal information, please contact us immediately through the contact information set out at the end of this Addendum so that we can take appropriate actions.

5.   How we store your personal information

5.1    Storage location and cross-border transfer

As a company established and operating in Hong Kong, China, we will store your personal information in Hong Kong, China. We may also transfer your personal information to our affiliates or service providers in other countries or regions in order to provide services to you, fulfill our legal obligations and for other purposes as set out in this Addendum. The data protection rules in these countries and regions may differ from those in your own location.

In carrying out such processing and transfer, we will fulfill the relevant requirements of China's data protection laws and regulations and take all necessary and appropriate safeguards to ensure the security of your personal information in accordance with this Addendum and China's data protection laws. We will also require data recipients outside of China to adopt appropriate protection measures to protect your personal information (such protection measures should be at least equivalent to the level of protection of personal information as stipulated in China's data protection laws and regulations) and to process and protect it in accordance with the requirements of this Addendum.

5.2    Storage period

Unless otherwise provided by laws or regulations, we will store your personal information for the period necessary to provide you with our services. Upon expiration of the aforementioned period or upon expiration of the storage period stipulated by laws and regulations (whichever occurs later), we will delete or anonymize your personal information or, if there are objective difficulties in deleting or anonymizing it (e.g., if your personal information is already stored in backups), we will only store your personal information in a secure manner and will not carry out any other processing activities.

6.   Your rights as a personal information subject

Unless otherwise provided by laws or regulations, you have the following rights with respect to your personal information:

Ÿ   You have the right to be informed and to decide on the processing of your personal information, and you have the right to restrict or refuse our processing of your personal information;

Ÿ   You have the right to access your personal information or to obtain a copy of your personal information;

Ÿ   If you find that your personal information is inaccurate or incomplete, you have the right to request us to correct or supplement it;

Ÿ   You have the right to withdraw your consent to the processing of personal information based on your consent. If you withdraw your consent, it does not affect the validity of the personal information processing activities that have been carried out based on your consent before the withdrawal;

Ÿ   You have the right to request us to transfer personal information to another personal information processor designated by you;

Ÿ   You have the right to request an explanation of the rules governing the processing of personal information;

Ÿ   You have the right to ask us to delete your personal information in specific circumstances;

Ÿ   If you have any objections to the personal information processing activities carried out by us and this Addendum, you have the right to resolve them by other means.

Among other things, you can perform the following operations yourself within the Mini Programme or our APP:

Ÿ   If you need to check or change your email address, residential area & district and change your password, you can complete the corresponding operations through the page for modifying personal information of "新地商場會員計劃" WeChat Mini Programme or The Point APP;

Ÿ   If you need to check the name and membership number of your registered membership, you can do so through the My Account (我的賬戶) page of the Mini Programme or our APP;

Ÿ   If you need to change the name or birth month of your registered membership, you can click on "Customer Service" (客服) on the My Account (我的賬戶) page of the Mini Programme or contact the Go Royal Member Services team through the contact information set out at the end of this Addendum, fill in the personal information changing form and provide a valid identification of membership information. We will then process the changes for you;

Ÿ   If you need to unbind your Go Royal account from WeChat or cancel your Go Royal membership, you can click on "Customer Service" (客服) on the My Account (我的賬戶) page of the Mini Programme or contact the Go Royal Member Services team through the contact information set out at the end of this Addendum, and the cancellation request will be processed within the time period required by applicable laws, regulations or competent authorities.

If you are unable to exercise your rights in the above manner or wish to exercise other rights of the personal information subject under China's data protection laws and regulations, you can contact us through the contact information set out at the end of this Addendum. We will respond to your request for personal information rights in accordance with the requirements and response timeline specified by the relevant laws and regulations.

To the extent permitted by laws or regulations, we may not be able to respond to your request to exercise your rights under the following circumstances:

Ÿ   If your request is contrary to the fulfillment of our obligations under laws and regulations;

Ÿ   If the requested information is directly related to national security and defense security;

Ÿ   If the requested information is directly related to public safety, public health, or significant public interest;

Ÿ   If the information requested is directly related to criminal investigations, prosecutions, trials and enforcement of sentences;

Ÿ   If we have sufficient evidence of subjective malice or abuse of rights on your part;

Ÿ   For the purpose of safeguarding your or other individuals' life, property and other significant legal rights and interests where it is extremely difficult to obtain your authorization or consent;

Ÿ   Responding to your request for exercising your rights will result in serious damage to your legitimate interests or those of other individuals or organizations;

Ÿ   If the requested information involves trade secrets.

7.    Updates to the Addendum

We may update this Addendum from time to time. When we make updates to this Addendum, we will make a prominent announcement on the Mini Programme or our APP or website to inform you of the changes to this Addendum and obtain your consent for any material changes to this Addendum as required by applicable data protection laws.

You can find out when this Addendum was last updated from "Last updated on" at the top of this Addendum. By continuing to use the "Go Royal by SHKP Hotel Loyalty Programme" including the Mini Programme or our services, you agree to be bound by any such revisions.

8.   How to contact us

We have designated a specialized Personal Information Protection Officer. If you have any questions or concerns about how we use your personal information or this Addendum, you can contact us in the following manner:

Ÿ   Send your questions to dpo@shkp.com

Ÿ   Send your questions to the following address: 45/F Sun Hung Kai Center, 30 Harbour Road, Hong Kong

You can also contact Go Royal Member Services team by using one of the methods below:

Ÿ   Email: info@goroyal.com.hk

Ÿ   Tel: (852) 2827 8636

Ÿ   WhatsApp: (852) 2827 8636

Ÿ   Go Royal Official WeChat Public Account: GoRoyalbySHKP (新鴻基地產集團酒店帝賞)

(Office hours: 9:00 a.m. to 1:00 p.m. and 2:00 p.m. to 6:00 p.m., Monday through Friday, except Hong Kong public holidays)

Updated on 15 July 2024