Privacy Policy Statement

Your Personal Data Privacy

Henderson Club Limited (“we” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy Statement (the “Statement”) explains our personal data privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”).

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This 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 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.

Types of Personal Data Held By Us

When you apply, register or request for Henderson Club membership, membership benefits, services, products or other arrangements, or when you use the Website or other facilities provided by us, we may collect and hold your personal data. Types of personal data collected and held by us may include your name and other identification information, your month of birth, your mobile number, address, email address and other contact information, and information relating to your mobile device.

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:

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;
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;
process your subscriptions;
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;
design, arrange, procure and provide membership benefits of any type and nature;
vi.process your request or application for membership benefits;
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;
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 the "Use of Your Personal Data in direct marketing" section in the Personal Information Collection Statement);
calculate any amount payable by you or by us, and collect or recover any amount payable by you;
operate internal control, resolve disputes, troubleshoot problems and enforce terms of use;
contact and communicate with you;
xii.verify identity and maintain contact lists for communications;
promote, improve and/or further the provision of Henderson Club membership, our facilities, services and/or products, and that of the Henderson Land Group;
offer or deliver information that users may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;
recruitment and other human resources related purposes;
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;
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;
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;
identifying and taking legal action against you, for any reason whatsoever including but not limited to recovering from you any money you owe us;
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
any other purpose(s) which has been agreed by or notified to you.

Disclosure and Transfer of 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:

the Henderson Land Group Members and Partners for purposes relating to the Henderson Club, your Henderson Club membership or membership benefits;
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;
persons who owe a duty of confidentiality to us. These persons may include our accountants, auditors, legal advisers and other professional advisers;
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;
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
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
actual or potential assignees of the Henderson Club business, or actual or potential purchasers or assignees of us or our business.

Please refer to our Personal Information Collection Statement for further details on the use, disclosure and transfer of personal data.

Use of ‘Cookies’

When you use the Website, cookies will be stored in your computer. Cookies are small text files that are automatically created and stored on the web browser in your computer which can be retrieved by the Website. Cookies will collect and store information about your preferences, navigation pattern, login name, etc. We use cookies to track users’ visits to the Website to provide better user experience and customized services. We will not use cookies to collect any personal data from you. Most web browsers automatically accept cookies. You can disable the cookies on your web browser, but if you do, certain functionality or features of the Website may not be available.

Links to Other Websites

This Statement only applies to the Website. If you click on any advertisement or hyperlink linking to other website(s), the protection of your personal data privacy and your exposure to cookies on the other website(s) are not our responsibility. You are advised to refer to the privacy policy and practices of the relevant website.

Web Logs

When a user visits the home page of the Website, the visit will be counted and included in the total number of visits to the Website for statistical purpose. This information does not identify you as an individual. No personal data will be collected.

Security

We will take all reasonably practicable steps to keep your personal data protected against unauthorized or accidental access, processing, erasure, loss or use. Our protective measures may include providing training to the employees who handle personal data, restricting access to personal data and deploying encryption and other technology available in the market.

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:

Henderson Club Limited
Address: 71/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong
Attention : Personal Data Privacy Officer - Henderson Club
(Marked Confidential)
Email: info@hldclub.com

Retention of Data

We will only keep your personal data for as long as necessary to fulfill the purposes for which the data was collected unless otherwise required or permitted by the Personal Data (Privacy) Ordinance. An example is we may retain the personal data to satisfy any applicable statutory or contractual obligations. Personal data which is no longer necessary will be destroyed.

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

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