PRIVACY POLICY

MASK CLUB LIMITED

PRIVACY POLICY


Foreword

MASK CLUB LIMITED (“Mask Club” or “the Company”) recognises the importance of personal and data privacy of its customers and treats all personal and private data provided to us as confidential.  We pledge to comply with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong (Cap. 486)(“the Ordinance”) and, where possible, internationally recognised standards of Personal Data privacy protection.


The Application of this Policy

This Policy gives effect to Mask Club’s commitment to protect customers’ personal information and has been adopted by the Company and its subsidiaries and representative offices.

This Policy applies to Mask Club or the companies directly owned or controlled by it.

The term “Personal Data” in this Policy refers to personal data which is capable of identifying you as an individual, as defined in the Ordinance.

The Policy applies to all Personal Data and information regarding Mask Club customers, users of the Mask Club mobile application, users of any Mask Club services, customers who purchase or accept the Company’s goods and service as well as visitors to the www.mask.club website.

Personal Data submitted to Mask Club’s Mask Points Rewards Program and Travel Buddies Program or Mask Club’s Online Member Website will also be governed by the rules in this Policy.


Collection, Use and Retention of Personal Data

Prior to collecting Personal Data, you will be asked to voluntarily supply information we need in order to provide the particular service requested.  Personal Data may be collected, used, disclosed and retained for: -

  • Administering, processing and/or confirming your travel and freight reservations and other transactions with us;
  • Verifying your identity and/or improve our security;
  • Facilitating your participation in loyalty programs and travel partner programs;
  • Accommodating special requests and providing a more personalised level of service;
  • Responding to requests for information and services;
  • Facilitating communications;
  • Conducting market research, market analysis and quality assurance surveys;
  • Facilitating direct marketing;
  • Facilitating matching with other Personal Data;
  • Providing you information regularly, including the information of relevant services or products and details of our latest offers;
  • Conducting data analysis enabling us to understand clients’ characteristics and buying habits anonymously, providing or designing other services or products which suit clients’ needs, or assisting us in choosing services or products which our clients may be interested in;
  • Designing new relevant services or products of our or our related companies, or for improving the existing relevant services and products;
  • Investigating complaints or suspicious transactions, or researching for service improvement of our or our related companies;
  • Detection or prevention of crimes, security problems or technical problems;
  • Comprehensive behavioral analysis;
  • Enforcing the Terms and Conditions, including but not limited to investigating issues which may against the Terms and Conditions;
  • Complying with any law, legal or regulatory requirement; and
  • Complying with governmental, judicial or administrative direction or order.

We will update our policy and erase your personal data in our possession pursuant to the laws of Hong Kong from time to time.  Basically, our policy includes the following principles: -

  • Unless the keeping of the abovementioned personal data is required by laws of Hong Kong or foreign laws, or it is in the public interest for such data not to be erased, otherwise your personal data will be kept until the purpose, or the directly related purpose for which the data was collected, is achieved.
  • According to the above principle, we will erase your personal data from our storage system after a specific storage period.


Types of Personal Data We Collect

The types of Personal Data that we process include: -

  • Your personal details, contact information, passport and visa information;
  • Your credit card details, loyalty program membership information and online user account details, profile and password details;
  • Any information necessary to fulfill special requests (for example, meal and seat preferences);
  • Information relating to the credit of customers;
  • Your reviews and opinions about our services; and
  • Activity records of Mask Club website visits and usage patterns.


Disclosures and Transfer of Personal Information

We may disclose or transfer (wherever within the Hong Kong SAR or countries or regions not within the Hong Kong SAR) your personal data to/at our offices, affiliates, operations, travel related companies and business partners worldwide and other institutions or organizations like our agents, network administrators, legal institutions, accounting institutions or contractors (including any credit providers or third party collection agencies), banks or other financial institutions who are under a confidentiality duty to us and provide management, data analysis, marketing, research, telecommunications services, network provider, debt collection, credit investigation, payment processing services, accounting services, professional services, legal services or other similar services.  We may also disclose or transfer your personal data to any actual or proposed transferees or assignees when a merge or transfer of any of our assets, stock rights or other rights and interests take place, and to collect, use, transfer, retain, disclose, or process personal data for the purposes mentioned in this Policy.

Mask Club reserves the right to disclose any Personal Data and information we hold on you if we: -

  • are compelled to do so by a court of law;
  • are requested to do so by a governmental entity;
  • determine that it is necessary or desirable to comply with the law; or
  • determine that it is necessary or desirable in providing services and facilities to you.

We also reserve the right to retain information collected and to process such information to comply with accounting and tax rules and regulations, as well as, for safety and security assessment as Mask Club may deem necessary.

We may also share aggregated demographic information with our business partners, affiliates or other entities.  This aggregate information is not linked or traceable to any personally identifiable information about you.


Right of Refusing Direct Marketing and Other Rights

Pursuant to the Personal Data (Privacy) Ordinance (Cap.486), unless we obtained your consent, we will not use your personal data in direct marketing.

If we obtain your consent, we may use your personal data, such as email address, correspondence address, mobile phone numbers, telephone numbers and fax numbers, for delivering publicity materials to you, and we may promote to and inform you our news, offers, promotions, events to be offered by us and our business partners and updated information of various services and products.

If you do not agree or do not want us to use or continue to use your personal data in direct marketing, you can at any time inform us your wish and decision in writing to: -

The Data Protection Officer

privacy@mask.club

We shall not charge you any fee for this request.

You have the rights to:

  • Make a request to us for checking whether we are holding your personal data;
  • If we are holding such data, make a request for accessing such data;
  • If your personal data we holding is inaccurate, you may make a request to us for making the necessary correction to such data;
  • Confirm with us our policy from time to time that applies to your personal data, and the type of your personal data we are holding; and
  • At any time make a request to us for stop delivering any promotional material to you.

If you want to make any of above requests, please write to: -

The Data Protection Officer

privacy@mask.club

When submitting your request, please include your full name, address and contact number so we can ascertain your identity and attend to your enquiry.

Pursuant to the Personal Data (Privacy) Ordinance (Cap. 486), we reserve our right to charge the requestor reasonable administrative fees for complying with data access requests.


The Protection of Personal Data

Mask Club retains Personal Data collected for as long as it may be necessary to fulfill the purpose (including any directly related purpose) which the information was initially collected for.

To maintain the accuracy of your Personal Data, as well as preventing unauthorised access to and ensuring the correct use of your Personal Data, we carry out appropriate physical, technical and administrative protective measures to control and safeguard the collection, access and disposal of the Personal Data we collect.  These measures are subject to ongoing review and monitoring.  Whilst we make every effort to protect your Personal Data, no security measures can guarantee that your Personal Data and information will not be subject to interference, misuse or hacking.  Mask Club shall not be responsible for any loss, misuse or alteration arising as a result of such incidents.


Links to Third Party Sites

The Mask Club website may contain links that will direct users to third party operated sites that are not owned or managed by Mask Club.  Personal Data submitted to or obtained by third parties will not be under the protection of this Policy.  Mask Club shall not be responsible any loss, misuse or alteration arising from access of any third party operated sites.


Cookies

Cookies will be used in our website for recording the type of website you are interested in and improve the efficiency of browsing our website.  Cookies are small computer files which can be stored in the user’s computer, and it can be used for many aspects, including analyzing Internet users’ using habits and obtaining computer configuration information.  But even the Cookies are used in our website, those Cookies will not be used for collecting any personally identifiable information which relates you or identifies you.  If you do not want to accept Cookies from our website, you can refuse those Cookies by modifying the relevant Internet setting or browsing setting in your computer system, but you may not able to browse or use certain functions available in our Website if you do so.


Miscellaneous

This Policy may be modified from time to time.  Any changes to this Policy will become effective upon posting of the revised Policy on the Mask Club website.  Use of the Mask Club website following such changes constitutes your acceptance of the revised Policy then in effect.

This Policy shall be interpreted and construed in accordance with the laws of Hong Kong SAR, and the parties relying on this Policy shall submit to the exclusive jurisdiction of the Courts of the Hong Kong SAR.

The terms in this Policy shall not limit your rights which are protected by the relevant laws of Hong Kong SAR.

In the event that any part of this Policy is held to be unenforceable under the applicable law of this statement, the unenforceable part shall be given effect to the greatest extent possible under the law and the remainder of this statement shall remain in full force and effect.

This Policy is written in the English language and may be translated into other languages.  In the event of any inconsistency, the English version shall prevail.


DIRECT MARKETING

Mask Club Limited aims at providing quality and comfortable travelling experience, products and services, as well as providing its latest news, offers, promotions, events to be offered by us and our business partners and updated information of various services and products.

Pursuant to the current Personal Data (Privacy) Ordinance (Cap. 486), providing any of the above information can be considered as direct marketing, and the law of which requires us to obtain your consent before providing such information.  Upon your consent, we will use your contact information (like SMS, email or mailing address) to provide the above information and latest offers.  We shall never provide your personal data to any third party promoter for direct marketing purpose.

You can withdraw the above consent at any time.  We shall not charge you any fee for withdrawing such consent.