Privacy Policy

Hong Kong Tourism Board ("HKTB", "we", "us" or "our") is committed to protecting and respecting the privacy of those viewing or using our website www.partnernet.hktb.com ("Website"). The protection of your personal information is very important to us, and we understand our responsibilities to handle your personal information with care, to keep it secure and to comply with legal requirements. If you sign up for my partnernet, or when you interact with us by contacting us for services, enquiries or providing feedback, we may collect and process certain personal information about you.

The purpose of this privacy policy ("Policy") is to provide a clear explanation of when, why and how we collect and use your personal information. We have designed it to be as user friendly as possible, and have labelled sections to make it easy for you to find the information that may be most relevant to you and to allow you to click on a topic to find out more.

Please read this Policy carefully. This Policy is not intended to override the terms of any contract that you may have with us (for example, the terms and conditions you agreed if you sign up to one of our events or programmes) or any rights you might have under applicable data protection laws.

We may make changes to this Policy from time to time, for example, to keep it up to date or to comply with legal requirements or changes in the way we operate our business. We will notify you about significant changes through our website www.partnernet.hktb.com. We encourage you to regularly check and review this policy so that you will always know what information we collect, how we use it, and who we share it with.

This Policy is effective from [November 2018].

  1. WHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL INFORMATION?
  2. WHAT PERSONAL INFORMATION DO WE COLLECT?
  3. HOW DO WE COLLECT THIS INFORMATION?
  4. WHAT PURPOSES DO WE USE YOUR PERSONAL INFORMATION FOR?
  5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
  6. DIRECT MARKETING
  7. INTERNATIONAL TRANSFERS
  8. PROFILING
  9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
  10. YOUR RIGHTS
  11. HOW WE PROTECT YOUR PERSONAL INFORMATION
  12. CONTACT AND COMPLAINTS
APPENDIX 1: LAWFUL BASIS FOR PROCESSING

 

1. WHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL INFORMATION?

Hong Kong Tourism Board is a Hong Kong government-funded body tasked to market and promote Hong Kong as a travel destination worldwide and to enhance visitors' experience once they arrive. Our registered office in Hong Kong is at 9-11 Floor, Citicorp Centre, 18 Whitfield Road, North Point, Hong Kong with operations through our branch offices and representatives worldwide. As such, the personal information you submit to us in one country may be transferred, used, processed, stored and accessed worldwide by our offices and representatives in one or more countries. For details of our worldwide offices and representatives, please visit here. HKTB will be the data controller as we are originally responsible for collecting information about you. You should be aware that although we may be principally responsible for looking after your personal information, information may be held in databases which can be accessed and used by other HKTB offices and representatives worldwide.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect certain information from you when you use our Website. This includes:

3. HOW DO WE COLLECT THIS INFORMATION?

Your personal information is collected by us either directly, for example, when you sign up for my partnernet, or when you interact with us by contacting us for services, enquiries or providing feedback. You are under no obligation to provide the personal information when we seek to directly collect it from you. However, if you do not provide us with certain information marked as mandatory or with an asterisk on the relevant forms, we may not be able to process your submission, provide you with our services or respond to your enquiries.

We may receive information about you indirectly from other sources and combine that with information we collect through our services where this is necessary to help manage our relationship with you. These other sources may include third party software applications or advertising technologies.

4. WHAT PURPOSES DO WE USE YOUR PERSONAL INFORMATION FOR?

We use your personal information for the following purposes:

We have to establish a legal ground to use your personal information for the purposes set out above, so we will make sure that we only use your personal information for the purposes set out above and in Appendix 1, where we are satisfied that:

5. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?

We may share your personal information with our worldwide offices and representatives. We may also share your personal information with third parties, to help manage our business and deliver services. These third parties may from time to time need to have access to your personal information. These third parties may include:

6. DIRECT MARKETING

We may use your personal information to send you direct marketing communications about our products and services or our related services including our latest e-newsletter and upcoming events and offers. This may be in the form of email, post, SMS, telephone or targeted online advertisements or in-app notifications. We limit direct marketing to a reasonable and proportionate level, and to send you communications which we think will be interesting and relevant to you, based on the information we have about you.

From the effective date of this Policy onwards, where you register for our events, programmes or offers, sign-up for our e-newsletter or have elected to receive direct marketing information by email or SMS, then for the purposes of the General Data Protection Regulations and where required under relevant e-privacy laws, we will ask you for your consent for our processing of your personal information for direct marketing purposes.

The above statement does not apply if you have previously provided us with your personal information and opted-in to direct marketing in accordance with relevant laws, in these cases our continued processing of your personal information is based on our legitimate interests as further detailed in Appendix 1.

You have a right to stop receiving direct marketing at any time. You can do this by following the opt-out links in electronic communications (such as emails), or by contacting us using the details set out in Section 12 below.

7. INTERNATIONAL TRANSFERS

Hong Kong Tourism Board is a statutory body of the Hong Kong Government established under the Hong Kong Tourism Board Ordinance. All HKTB offices are branches of the Hong Kong statutory body, accordingly any personal information which you provide to us via our offices or otherwise will automatically be transferred to HKTB in Hong Kong and your personal information may be accessed or used by staff in HKTB offices or representatives outside Hong Kong.

We may transfer your personal information to HKTB offices and representatives or service providers that are located outside of the EU. We will always take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests and is undertaken in accordance with any rules governing such transfers.

You have the right to ask us for more information about the safeguards we have put in place. Contact us as set out in Section 12 if you would like further information or to request a copy where the safeguard is documented (which may be redacted to ensure confidentiality).

8. PROFILING

'Automated decision making' refers to a decision which is taken through the automated processing of your personal information alone. This means processing using, for example, software code or an algorithm, which does not involve human intervention. As profiling uses automated processing, it is sometimes connected with automated decision making. Not all profiling results in automated decision making, but it can do.

We may use profiling to ensure that marketing materials are tailored to your preferences and to what we think you will be interested in. This does not have any significant effect, or a legal effect on you. In certain circumstances it may be possible to infer certain information about you from the result of profiling, which may include special categories of data. We will not however conduct profiling based on your special categories of data unless we have obtained your explicit consent to do so.

Please note that you have certain rights in respect of automated decision making, including profiling where that decision has significant effects on you, including where it produces a legal effect on you. You may find more information in Section 10.

9. HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

We will retain your personal information for as long as is reasonably necessary for the purposes listed in Section 4 above. In some circumstances we may retain your personal information for longer periods of time, for example where we are required to do so to meet legal, regulatory, tax or accounting requirements.

In specific circumstances we may also retain your personal information for longer periods of time so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a possibility of legal action relating to your personal information or dealings.

10. YOUR RIGHTS

Subject to applicable laws and regulations, you may have a number of rights in relation to your personal information. For example, under GDPR, you may request access to your data, rectification of any mistakes in our records, erasure of records where no longer required, restriction on the processing of your data, objection to the processing of your data, data portability and various information in relation to any automated decision making and profiling or the basis for international transfers. You also have the right to complain to your supervisory authority (further details of which are set out in Section 12 below).

Where permitted by applicable laws and regulations, you may have the following rights:

Please contact us as set out in Section 12 if you do wish to exercise these rights.

11. HOW WE PROTECT YOUR PERSONAL INFORMATION

We endeavour to protect us and you from unauthorised access to or unauthorised alteration, disclosure or destruction of personal information that we hold.

In particular:

12. CONTACT AND COMPLAINTS

You may contact us at:

Hong Kong Tourism Board
9-11 Floor, Citicorp Centre
18 Whitfield Road
North Point
Hong Kong

E-mail: partnernet@hktb.com

If you are in the EU, you also have a right to lodge a complaint with your national data protection supervisory authority at any time, or contacting our EU representative. However, we encourage you to first contact us.

APPENDIX 1: LAWFUL BASIS FOR PROCESSING

No.

Purpose for processing

Lawful basis

1

To create customer profiles, maintain customerrecords and to communicate with you, fulfil your requests and respond to yourenquiries, bookings and feedback.

This processing is necessary for the purpose ofthe legitimate interests pursued by HKTB.
HKTB considers that it has a legitimate interestin ensuring your requests and feedback are attended to and to maintain anaccurate record of your data.

2

To send you important notices or personalisedmessages.

This processing is necessary for the purpose ofthe legitimate interests pursued by HKTB.
HKTB considers that it has a legitimate interestin ensuring that all customers receive the best possible experience, helpingus to preserve our business operations, and ensuring that you are providedwith information relevant to you.

3

Toadministrate the operation of our Website, to allow you to use the servicesand functions of our Website, to conduct website maintenance, trouble shootproblems and to continually improve your Website experience and improve ourproducts and services

This processing is necessary for the purpose ofthe legitimate interests pursued by HKTB.
HKTB considers that it has a legitimate interestin ensuring that all customers receive the best possible experience andimproving our products and services offering in order to preserve ourbusiness operations.

4

To maintain opt-out and opt-in lists (includingresponding to customer requests to opt-out of direct marketing)

This processing is necessary for the purpose of alegal obligation to which HKTB is subject in order to not provide directmarketing materials to individuals which have opted-out of, or opted-in to,receiving such communications.

5

To provide services in connection with registration with our events and programmes.

This processing is necessary to perform thecontract between you and HKTB.

6

To sendyou marketing materials, news and information which we think will be ofinterest to you such as our latest promotional activities and upcoming events.

HKTB considers that it has a legitimate interestin ensuring that our existing customers are kept up to date with informationabout our products and services, as this helps us to preserve our businessoperations.
However, for new customers and where required byapplicable law, we will obtain your consent before sending you suchinformation, and therefore, will rely upon such consent as our lawful basisfor processing.

7

To assist with identification of visitors, and todetermine appropriate services.

This processing is necessary for the purpose ofthe legitimate interests pursued by HKTB. HKTB considers that it has alegitimate interest in facilitating requests from you and provide you withrelevant appropriate services.
HKTB may also in certain situations also has alegal obligation to respond and comply with your requests.

8

To monitor, evaluate and analyse trends, data,usage and activities in connection with our Website and services.

This processing is necessary for the purpose ofthe legitimate interests pursued by HKTB.
HKTB considers that it has a legitimate interestin reviewing our Website and services, including how customers use ourWebsite and services, in order to ensure that we are providing our customerswith what they need, helping us to preserve our business operations.

9

To keep internal records, decision making andfacilitate internal purposes such as auditing, data analysis, and research toimprove our products and services.

This processing is necessary for the purpose ofthe legitimate interests pursued by HKTB.
HKTB considers that it has a legitimate interestin continually improving our services in order to preserve our businessoperations, and ensuring that you are provided with information relevant toyou.

10

To detect, investigate and prevent fraud andother illegal activities and protect our rights and property.

HKTB considers that it has a legal obligation toensure its business operations is operating in accordance with the applicablelaws and regulations.

11

To use your personalinformation for purposes associated with our legal or regulatory obligations.

HKTB considers that it has a legal obligation toensure its business operations is operating in accordance with the applicablelaws and regulations.

12

Todevelop, display and track content for the purposes of customising orpersonalising advertising, offers and content made available to you based onyour usage of websites, mobile applications or services, and analysing theperformance of those advertisements, offers and content, as well as yourinteraction with them.

HKTB considers that it has a legitimate interestto ensure that you receive information about our products and services (andthose of our partners) which may be of interest to you, this also helps us topreserve our business operations.