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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.discoverhongkong.com ("Website"). The protection of your personal data is very important to us, and we understand our responsibilities to handle your personal data with care, to keep it secure and to comply with legal requirements. If you visit or use our website, mobile, social media and other services through any channels, enrol or participate in our events or programmes, download our apps, enter lucky draws or competitions, or sign up for our e-newsletter, we may collect and process certain personal data about you.
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 changes through our website www.discoverhongkong.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.
Hong Kong Tourism Board is a statutory body of the Hong Kong Government established under the Hong Kong Tourism Board Ordinance 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 data 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 which may also be collected by our branch officers and representatives elsewhere. You should be aware that although our head office in Hong Kong may be principally responsible for looking after your personal data, information may be held in databases which can be accessed and used by other HKTB offices and representatives worldwide.
We collect certain information from you when you use certain services within our Website. This may include:
Your personal data is collected by us either directly, for example, when you use our services, enrol or participate in our events or programmes, enter lucky draws or competitions, or sign up for our e-newsletter, download our app, or when you interact with us by contacting us for enquiries or providing feedback. You are under no obligation to provide the personal data 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, advertising technologies, and social media platforms such as Facebook, Instagram and Twitter, or by our third party event participating merchants or service providers.
We use your personal data for the following purposes:
We have to establish a legal ground to use your personal data for the purposes set out above, so we will make sure that we only use your personal data for the purposes reasonably related thereto as set out above and in Appendix 1, where we are satisfied that:
We may share your personal data with our worldwide offices and representatives. We may also share your personal data 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 data. These third parties may include:
We may use your personal data to send you direct marketing communications about products and services in the travel industry or 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 and otherwise share content with you 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 entered a lucky draw and 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 data for direct marketing purposes.
The above statement does not apply if you have previously provided us with your personal data and opted-in to direct marketing in accordance with relevant laws, in these cases our continued processing of your personal data is based on our legitimate interests as further detailed in the Appendix.
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.
Hong Kong Tourism Board is a Hong Kong government funded body. All HKTB offices are branches of this Hong Kong statutory body, accordingly any personal data which you provide to us via our offices or otherwise will automatically be transferred to HKTB in Hong Kong and your personal data may be accessed or used by staff in the HKTB head office in Hong Kong as well as HKTB offices or representatives outside Hong Kong.
We may transfer your personal data 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).
'Automated decision making' refers to a decision which is taken through the automated processing of your personal data with or without human involvement. This means processing using, for example, software code or an algorithm, which does not involve human intervention. ‘Profiling’ is defines as the automated processing of personal data for evaluating personal aspects, in particular to analyse or make predictions about individuals. As profiling must involve automated processing, it is a form of automated decision making.
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.
We will retain your personal data for as long as is reasonably necessary for the purposes listed in Section 4 above. In some circumstances we may retain your personal data 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 data 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 data or dealings.
Subject to applicable laws and regulations, you may have a number of rights in relation to your personal data. For example, under GDPR, you may request access to your data, rectification of any inaccuracies in our records, erase records where no longer required, restrict processing of your data, object to the processing of your data, obtain a copy of your personal data from us for transfer to another someone else who controls and use your personal data and various information in relation to any automated decision making and profiling or the basis for international transfers. You may 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.
We endeavour to protect us and you from unauthorised access to or unauthorised alteration, disclosure or destruction of personal data that we hold.
For enquiries, you may contact us at:
Hong Kong Tourism Board
9-11 Floor, Citicorp Centre
18 Whitfield Road
Fax: +852 2503 6114
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.
|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 bookings or registration with our events and programmes.||This processing is necessary to perform the contract between you and HKTB.|
|6||To identify you for entry into lucky draw or any other promotional activities or events.||This processing is necessary to perform the contract between you and HKTB.
HKTB may also in certain situations has a legitimate interest to ensure that we are providing our customers with the opportunity to engage with us and participate in our activities and events.
|7||To facilitate lucky draws, promotional activities or events and notify you of the results of the lucky draws, promotional activities or events, announce winners and arrange for the subsequent presentation or redemption of prizes.||This processing is necessary for the purpose of the legitimate interests pursued by HKTB.
HKTB considers that it has a legitimate interest in administrating the lucky draws, promotional activities or events and notifying winners to the lucky draw and allowing winners to claim their prizes.
|8||To tailor and personalise content and make recommendations (including by sending you push notifications) to suit your tastes, interests and preferences.||HKTB considers that it has a legitimate interest in ensuring that our existing customers are kept up to date with information about products and services in the travel industry that are relevant and tailored to them to enhance customer experience.
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.
|9||To suggest nearby places of interest, give you point-to-point navigation through Google Map and enable us to send you location based push notification via GPS technology when you are in Hong Kong.||You will be asked for your consent via your device settings before the location tracking function will be activated.|
|10||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.
|11||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.
|12||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.
|13||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.
|14||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.|
|15||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.|
|16||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.|
Updated in November 2020