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.

WHO IS RESPONSIBLE FOR LOOKING AFTER YOUR PERSONAL INFORMATION?
WHAT PERSONAL INFORMATION DO WE COLLECT?
HOW DO WE COLLECT THIS INFORMATION?
WHAT PURPOSES DO WE USE YOUR PERSONAL INFORMATION FOR?
WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
DIRECT MARKETING
INTERNATIONAL TRANSFERS
PROFILING
HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION
YOUR RIGHTS
HOW WE PROTECT YOUR PERSONAL INFORMATION
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:

Contact details and basic user information including your name, company, title, email address, telephone number, address and country, industry sector;
Your marketing preferences including interests and market list assignments, marketing objections, website data;
Usage information including how you use our Website such as clicks and pages which have been shown to you, referring webpage address;
Device data and log information including IP addresses, device ID and type, and details about your use of our website, browsing history, search queries, browser type, session frequency, geolocation information, wireless and mobile network connection information;
Cookies and tracking technologies including technologies cookies and web beacons and advertising IDs. (Please see our separate Cookie Policy for further details on cookies.)

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:

To create customer profiles, maintain customer records and to communicate with you, fulfil your requests and respond to your enquiries, bookings and feedback;
To send you important notices or personalised messages;
To administer the operation of our Website to allow you to use the services and functions of our Website, to conduct website maintenance, trouble shoot problems and to continually improve your Website experience and improve our products and services;
To provide services in connection with registration with our events and programmes;
To send you marketing materials, news and information which we think will be of interest to you such as our latest promotional activities and upcoming events;
To monitor, evaluate and analyse trends, data, usage and activities in connection with our Website and services;
To keep internal records, decision making and facilitate internal purposes such as auditing, data analysis, and research to improve our products and services, in addition, such internal records will be used to maintain opt-in and opt-out lists;
To detect, investigate and prevent fraud and other illegal activities and protect our rights and property; and
To use your personal information for purposes associated with our legal or regulatory obligations.
We also use your personal information to develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them. We may also recommend content to you based on information we have collected about you and your viewing habits. This may amount to profiling in respect of which more information is provided at Section 8 of this Policy.

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:

our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g. to fulfil obligations under the contract signed between you and us);
you have provided your consent;
it is necessary to comply with a legal obligation; or
our use of your personal information is necessary to support the 'legitimate interests' that we have as a business (for example, to improve our products and services, to provide help or support in connection with our services/ websites, to ensure that they operate efficiently and securely, and to carry out analytics across our datasets), provided it is always carried out in a way that is proportionate, and that respects your privacy rights.

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:

Our partners, such as hotels, restaurants, airlines, retailers, travel agents, government departments and public bodies and other companies in our database of the Hong Kong travel industry;
Service providers, who provide administrative, marketing and research, distribution, data processing and management, advertising delivery, computer system, web development, payment gateway and other functions on our behalf to help us operate our business, such as sending postal mail and e-mails, help manage our IT and back office systems, analysing data, providing marketing and targeted advertising services assistance, providing search results and links (including paid listings and links). If you share your data through our Website with a third party account such as Facebook, Twitter or Instagram, your personal information will be managed respectively by one of those third parties. Please review the third party's privacy policy, as their data processing will not be covered by this Policy;
Event sponsors or authorised managers, agents or contractors, who facilitate the event or programmes registrations, lucky draws, presentation, redemption or delivery (as appropriate) of prizes in connection with the associated events or activities organised or promoted by us;
Government or non-government authorities and/or regulators;
Other third parties, for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public;
Professional advisors (including our lawyers and auditors);

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:

Access: you can ask us to provide details of what personal information (if any) we process about you, what we use it for, who we disclose it to, whether we transfer it abroad and how we protect it, how long we keep it for, how you can make a complaint, where we got your data from, you can also ask us to provide a copy of it;
Rectification: you can ask us to rectify inaccurate personal information;
Erasure: you can ask us to erase your personal information in certain circumstances (for example if it is no longer needed for the purposes for which it was collected or you have withdrawn your consent if the data processing was based on consent);
Restriction: you can ask us to restrict (i.e. keep but not use) your personal information in certain circumstances (for example where its accuracy is contested);
Portability: in certain circumstances you can ask us to provide your personal information to you in a structured, commonly used, machine-readable format, or you can ask to have it 'ported' directly to another data controller;
Objection: you can object to any processing of your personal information which has our 'legitimate interests' as its lawful basis if you believe your fundamental rights and freedoms outweigh our legitimate interests; and
Automated Decision Making: you can ask for certain automated decisions to be reconsidered by us using human intervention.

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:

we review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems;
we use password protection where appropriate; and
we restrict access to personal information to employees and contractors who need access to the relevant personal information in order for them to process it for us and who are subject to strict contractual confidentiality obligations.

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 customer records and to communicate with you, fulfil your requests and respond to your enquiries, bookings and feedback.	This processing is necessary for the purpose of the legitimate interests pursued by HKTB. HKTB considers that it has a legitimate interest in ensuring your requests and feedback are attended to and to maintain an accurate record of your data.
2	To send you important notices or personalised messages.	This processing is necessary for the purpose of the legitimate interests pursued by HKTB. HKTB considers that it has a legitimate interest in ensuring that all customers receive the best possible experience, helping us to preserve our business operations, and ensuring that you are provided with information relevant to you.
3	To administrate the operation of our Website, to allow you to use the services and functions of our Website, to conduct website maintenance, trouble shoot problems and to continually improve your Website experience and improve our products and services	This processing is necessary for the purpose of the legitimate interests pursued by HKTB. HKTB considers that it has a legitimate interest in ensuring that all customers receive the best possible experience and improving our products and services offering in order to preserve our business operations.
4	To maintain opt-out and opt-in lists (including responding to customer requests to opt-out of direct marketing)	This processing is necessary for the purpose of a legal obligation to which HKTB is subject in order to not provide direct marketing 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 the contract between you and HKTB.
6	To send you marketing materials, news and information which we think will be of interest to you such as our latest promotional activities and upcoming events.	HKTB considers that it has a legitimate interest in ensuring that our existing customers are kept up to date with information about our products and services, as this helps us to preserve our business operations. However, for new customers and where required by applicable law, we will obtain your consent before sending you such information, and therefore, will rely upon such consent as our lawful basis for processing.
7	To assist with identification of visitors, and to determine appropriate services.	This processing is necessary for the purpose of the legitimate interests pursued by HKTB. HKTB considers that it has a legitimate interest in facilitating requests from you and provide you with relevant appropriate services. HKTB may also in certain situations also has a legal 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 of the legitimate interests pursued by HKTB. HKTB considers that it has a legitimate interest in reviewing our Website and services, including how customers use our Website and services, in order to ensure that we are providing our customers with what they need, helping us to preserve our business operations.
9	To keep internal records, decision making and facilitate internal purposes such as auditing, data analysis, and research to improve our products and services.	This processing is necessary for the purpose of the legitimate interests pursued by HKTB. HKTB considers that it has a legitimate interest in continually improving our services in order to preserve our business operations, and ensuring that you are provided with information relevant to you.
10	To detect, investigate and prevent fraud and other illegal activities and protect our rights and property.	HKTB considers that it has a legal obligation to ensure its business operations is operating in accordance with the applicable laws and regulations.
11	To use your personal information for purposes associated with our legal or regulatory obligations.	HKTB considers that it has a legal obligation to ensure its business operations is operating in accordance with the applicable laws and regulations.
12	To develop, display and track content for the purposes of customising or personalising advertising, offers and content made available to you based on your usage of websites, mobile applications or services, and analysing the performance of those advertisements, offers and content, as well as your interaction with them.	HKTB considers that it has a legitimate interest to ensure that you receive information about our products and services (and those of our partners) which may be of interest to you, this also helps us to preserve our business operations.