Personal Information Collection Statement

Your Personal Data

The Henderson Club (the "Henderson Club") is offered and operated by Henderson Club Limited ("we” or “us”). This Personal Information Collection Statement (the “Statement”) applies to the personal data provided by or for you and held by us from time to time, including the data of members of Henderson Club, applicants for membership of Henderson Club and users of our website (the “Website”), whether Henderson Club members or not. This Statement sets out the purposes for which your personal data may be used, to whom the personal data will be transferred and to whom data access and data correction requests are to be addressed and other matters relating to the Personal Data (Privacy) Ordinance, Cap. 486 (the "Ordinance"), and may from time to time be revised or otherwise changed where we deem necessary.

Throughout this Statement, the meaning of the term “personal data” is as defined in the Ordinance.

Provision of Personal Data

You are not obliged to provide personal data to us. However, if you do not provide certain personal data, we may be unable to process your Henderson Club membership registration, application, admission or request and offer or continue to offer to you the Henderson Club membership or any of the facilities, services, products, membership benefits and privileges (including any reward program) of the Henderson Club. Some functionality or features of the Website may also not be available.

If you are under the age of 13, you must ask your parent or guardian before providing any personal data to us. For the avoidance of doubt, all applicants for membership of Henderson Club must be aged 18 or above.

Purposes For Which Personal Data Held By Us May Be Used

We may use your personal data for one or more of the following purposes from time to time:

(a) process your registration for Henderson Club membership, or consider and assess your application for Henderson Club membership and process your admission as a Henderson Club member as appropriate;

(b) handle and administer any matters in relation to your Henderson Club membership and communicate with you on such matters. These matters may include verifying personal data or other information about you, providing and maintaining your Henderson Club membership, providing membership benefits to you, and investigating and handling any comments, enquiries or complaints received by us from or against you;

(d) monitor, administer, maintain and manage the use of membership benefits, the Henderson Club, the Henderson Club membership and the Website and other services, arrangements and facilities provided by us, including improving membership benefits and Henderson Club member experience;

(e) design, arrange, procure and provide membership benefits of any type and nature;

(f) process your request or application for membership benefits;

(g) conduct surveys, research and analysis in connection with the Henderson Club, Henderson Club membership and membership benefits, whether relating to you or to Henderson Club members generally, and compile aggregate statistics about users to analyze usage of membership benefits, the Website and other services, arrangements and facilities;

(h) designing, providing and marketing any services, products and facilities provided by us, Henderson Land Development Company Limited or any of its subsidiaries and associated and/or related companies (Henderson Land Development Company Limited and all of its subsidiaries, associated and/or related companies collectively, "Henderson Land Group" or "Henderson Land Group Members") or any other person (whether or not a Henderson Land Group Member) who has made any co-branding or cooperative arrangement with us (each, a "Partner"), please see further details in "Use of Your Personal Data in direct marketing" section below);

(i) calculate any amount payable by you or by us, and collect or recover any amount payable by you;

(j) operate internal control, resolve disputes, troubleshoot problems and enforce terms of use;

(k) contact and communicate with you;

(l) verify identity and maintain contact lists for communications;

(m) promote, improve and/or further the provision of Henderson Club membership, our facilities, services and/or products, and that of the Henderson Land Group;

(n) offer or deliver information that users may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;

(o) recruitment and other human resources related purposes;

(p) communicate with our investors and/or potential investors, and that of the Henderson Land Group and any of its subsidiaries, associated and/or related companies;

(q) comply with (i) any law or court order binding on us, (ii) any guidelines or codes of practice issued by regulatory or other authorities or governmental or law enforcement agencies with which we are required or reasonably expected to comply, and (iii) any internal policies and measures for using or disclosing personal data implemented by us or Henderson Land Group for prevention or detection of money laundering, terrorist financing or other unlawful activities or suspicious activities;

(r) match or compare your personal data with any other data relating to you to produce or verify data which may be used for taking adverse action against you;

(s) identifying and taking legal action against you, for any reason whatsoever including but not limited to recovering from you any money you owe us;

(t) enable actual or potential assignees of the Henderson Club business, or actual or potential purchasers or assignees of us or our business, in each case to evaluate the assignment or purchase in question; and

(u) any other purpose(s) which has been agreed by or notified to you.

Disclosure or Transfer of Your Personal Data

We will take all reasonably practicable steps to keep your personal data confidential but we may disclose, transfer or exchange your personal data with one or more of the following classes of persons from time to time for the purposes set out above, and your personal data may be transferred in or outside of Hong Kong:

(a) the Henderson Land Group Members and Partners for purposes relating to the Henderson Club, your Henderson Club membership or membership benefits;

(b) agents, contractors, sub-contractors or third party service providers (including their employees, directors, officers, agents, contractors, service providers and professional advisers) who provide services or support to us in connection with the Henderson Club business or our business or operations. These services or support may include banking services, insurance services, computer, information technology, data processing or storage, telecommunications services, mailing and logistic and administrative services. These agents, contractors, sub-contractors or service providers may or may not be Henderson Land Group Members;

(c) persons who owe a duty of confidentiality to us. These persons may include our accountants, auditors, legal advisers and other professional advisers;

(d) persons to whom we or any Henderson Land Group Member are under an obligation to make disclosure under the requirement of any law, regulation or court order binding on us or for the purposes of any guidelines or codes of practice issued by any governmental agency, regulatory authority or law enforcement agency with which we are required or reasonably expected to comply;

(e) persons to whom we are required to disclose personal data by any policies and measures implemented by it or Henderson Land Group for prevention or detection of money laundering, terrorist financing or other unlawful activities or suspicious activities;

(f) for marketing purposes, (i) Henderson Land Group Members, (ii) Partners (the names of these Partners can be found in the request or application form or information leaflet relating to the relevant membership benefits) and (iii) service providers engaged by us (these service providers may include printing, advertising, market research, marketing, telemarketing and direct sales agencies and mailing agencies); and

(g) actual or potential assignees of the Henderson Club business, or actual or potential purchasers or assignees of us or our business.

Use of Your Personal Data in Direct Marketing

We intend to use your personal data in direct marketing and we require your consent for this purpose. Please note the following:

(a) Types of personal data to be used

We may use the following types of personal data that is held by us from time to time in direct marketing:

your name, month of birth, address, telephone number and email address;
pattern and behaviour relating to your use of membership benefits or your purchase or consumption of products and services (including products and services portfolio information and spending habits); and
your demographic data.

(b) Class of products, services and subjects to be marketed

We may market one or more of the following classes of products, services and subjects:

consumer goods and services, including food and beverages, fine dining, clothing and apparel, fashion and accessories, foot-ware, lifestyle and leisure products, amenities and entertainment, travelling services, sports goods, toys and children goods, beauty and personal care, healthcare, dental and medical services and products, groceries, supermarkets, delicatessen and convenient stores, books and magazines, home furnishing, electrical appliances, audio and video products, optical products, and jewellery, watches and other luxurious goods;
real estate properties or property developments offered by any Henderson Land Group Member singly or jointly with any other developer or person;
financial, investment, banking, insurance, credit cards and related products and services; and
donations or contributions for charitable or non-profit making purposes and related events or activities.

The above products, services and subjects may be provided by one or more of the following classes of persons:

us;
any Henderson Land Group Members; and
any Partners (the names of these Partners can be found in the request or application form or information leaflet relating to the relevant membership benefits). Partners may include retail merchants, service providers, real estate developers, financial institutions, charitable bodies and non-profit making organisations.

Your Right To Access and Correct Your Personal Data

You have the right to, at any time, request access to and correct personal data relating to you on our records. You also have the right to withdraw or give consent for use of your personal data in direct marketing from time to time. Please send your data access and data correction requests or your choice relating to direct marketing to us at the address below marking your communication “Confidential”. We may ask you to provide further information to enable us to verify that you have the right to make the relevant request. We may charge you a reasonable fee for handling a data access request.

Personal Data Privacy Officer

Please send your data access and data correction requests, your choice relating to direct marketing and other requests and enquiries about our policies and practices with respect to personal data to our Personal Data Privacy Officer as follows:

Version effective date : 28 April 2024

Note: In case of discrepancies between the English and Chinese versions of this Statement, the English version shall prevail.

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