This Personal Information Collection Statement (this “Statement”) is made by The Town Club (HK) Limited (“HKGTA Town Club”, “we”, “us”, or “our”), and applies between us and you (“you”, or “your”). This Statement should be read together with the Terms and Conditions (if any) of the website at https://www.hkgtatownclub.com/en/ (the “Website”) (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data, this Statement shall prevail.
 
HKGTA Town Club is part of the New World group of companies including New World Development Company Limited (“NWD”) and its affiliated or related companies from time to time (as listed here: https://www.nwd.com.hk/pics) (the “New World Group”, or “NWG”) whose activities include real estate (sale, leasing and investment), mortgage services, retail, property management, facilities management, activity planning and management, infrastructure, shopping malls, loyalty programmes, department stores, jewelleries and luxury products, e-commerce, hospitality services, food and beverages, convention and exhibition centres, sports and recreational facilities, education, health care and senior care, other health and wellness products and services, financial services and insurance, transportation, sustainability programmes and products, TMT (Technology, Media and Telecom), corporate innovation, accelerator and incubation programmes, organization of competitions, conferences and events, start up and social innovation programmes and charitable pursuits including sports, recreation, art and cultural programmes, relief of poverty, advancement of education, advancement of religion, and other purposes that are beneficial to the community (the “Goods and Services”) (the New World Group and joint venture companies together referred to as “Affiliates”).
 
In order to enable us to perform the Purposes (as defined in the “Purposes for using personal data collected” section below), you are required to provide all the requested/mandatory personal data in the relevant forms and documents that we may issue to you from time to time on or through the Website, including but not limited to the expression of interest form and other application forms on the Website. If you do not provide the required personal data, then we may not be able to perform the Purposes and/or provide goods or services to you.
 
Kinds of personal data collected
 
The kinds of personal data we may collect from you and/or from other sources as mentioned below in this Statement include but are not limited to your name, gender, age range, date and month of birth, contact details, e-mail address, mailing/ residential/ correspondence address, contact number, membership number, marital status, family status, educational level, occupation, username and password, Log Files (see below), interests and favourite activities, tracking information about your use of the Website and transaction information (including your characteristics and transaction behaviour) (“Tracking Data”), social media account information, etc. For Tracking Data collected through the use of cookies and other tracking mechanisms, please also refer to our related policies (including but not limited to the New World Group Privacy Policy Statement and Cookies Policy)for further details as to how we collect, use and process Tracking Data.
 
Purposes for using personal data collected
 
The personal data to be collected from you and/or from other sources as mentioned below in this Statement will be used and retained by us (and/or our Affiliates) for the following purposes (as may be applicable from time to time) (together, the “Purposes”):

• Assessing and reviewing your eligibility to be the HKGTA Town Club patrons;
• Contacting you in connection with your interest in the HKGTA Town Club patronage programme;
• Processing your enquiry about HKGTA Town Club and its services and/or facilities, and/or use of the same;
• Contacting you in connection with your enquiry about HKGTA Town Club and its services and/or facilities, and/or use of the same;
• Processing and managing applications, bookings, orders or requests made by you;
• Facilitating and conducting the management and daily operation of HKGTA Town Club and administration of your patronship, and contacting you in connection with your patronship;
• Identifying and verifying your identity and/or as a patron;
• Registering you as a user of the Website;
• To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Website;
• Following registration as a user of the Website, accessing your account information (including, but not limited to, your name, patron number, etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/unsubscribing from direct marketing, etc.);
• Research, development, and analysis in relation to your/patron behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining;
• For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
• Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future);
• Improving the Website, the Purposes, and our and our Affiliates’ Goods and Services;
• Data analytics, profiling, information management and database administration;
• Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal;
• Collection or recovery of any debt owed by you to us or our Affiliates;
• The normal management, operation, and maintenance of the Website and the provision of the Goods and Services to you;
• Storing your personal data (whether by a single or multiple Affiliates (including us)) for the purpose of sharing such personal data with our Affiliates for any and all of the other Purposes listed above; and/or
• Other purposes ancillary or related to the above.

Those with whom we share personal data
 
We may engage agents, contractors, suppliers and service providers (whether within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”)) in connection with the Purposes and/or the provision of the Goods and Services, e.g. IT/software solutions/technology services providers, social media, research companies, and service providers of development and maintenance, administrative, data processing, digital storage, or other similar services, and may transfer to or share your personal data with them for the Purposes within or outside Hong Kong. We may also share your personal data with our Affiliates and the social media platforms that we and/or our Affiliates use for such Purposes. Where we are required by the law of any country or place or requested by any court, regulatory body or governmental body of any country or place, we may also disclose your personal data as required. In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our Affiliates or our Affiliates’ businesses, your personal data may be transferred to the new entity as part of the transaction, provided that the new entity abides by this Statement and continues to exercise the same level of care, in respect of your personal data, as we would. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.
Your personal data may be stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with our Affiliates located within or outside Hong Kong. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the country or place in which it is stored, and we procure by contract or use our reasonable endeavours to ensure that our Affiliates do the same.
 
Direct marketing
 
We will not use, and/or transfer to third parties, any of your personal data that we may collect from the Website without obtaining your prior consent to do so.
Your rights
 
You have the following rights to:

• check whether we hold any of your personal data;
• access your personal data held by us;
• require us to correct any personal data which is inaccurate; and
• ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by
  us.

If you would like to make a request in relation to the above (or make any general enquiries), please contact our Personal Data Privacy Officer (Legal and Company Secretarial Department) at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or privacy@hkgtatownclub.com (marked Confidential, and with the name of The Town Club (HK) Limited). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.
 
Privacy Policy Statement
 
We adopt the New World Group Privacy Policy Statement. You can find out more about our policy on personal data protection by accessing the New World Group Privacy Policy Statement available at https://nwd.com.hk/privacy-policy. If there is any inconsistency or conflict between the New World Group Privacy Policy Statement and this Statement, this Statement shall prevail.
 
Please also see the New World Group Privacy Policy Statement for our policies and information about:

• our collection and/or use of Log Files (data relating to your use of/visits to the Website, including but not limited to your IP address, domain name, browser type and access time);
• the use of cookies and other tracking mechanisms;
• retention of your personal data;
• third party merchants and/or websites that may be contained in the Website;
• how we keep your personal data secure;
• use of your personal data in legal proceedings.

Inconsistency or conflict
 
If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.
 
Miscellaneous
 
This Statement may be updated from time to time to reflect changes to our policy with respect to personal data protection and/or changes to personal data/data privacy laws and regulations. Where there are significant changes, we will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Website for updates to this Statement on a regular basis.
 
Nothing in this Statement shall limit your rights under the PDPO.
 
If you are:

(i) an individual located in Mainland China who visits or uses our relevant website(s) or mobile application(s), or otherwise uses or attends our facilities, events, programmes, products and/or services by phone or any other means from Mainland China;
and/or
(ii) an individual holding a Mainland China passport and/or resident identity card who visits, uses or attends our Club premises, facilities, events and/or programmes in Hong Kong or otherwise use NWG’s products and/or services by phone or any other means in Hong Kong,

your personal data will be processed by us in accordance with the “People’s Republic of China Addendum” in addition to the New World Group Privacy Policy Statement, HKGTA Town Club Privacy Policy Statement and this Statement, as well as the applicable data protection laws and regulations in Mainland China which, for the current purposes, excludes Hong Kong, the Macau Special Administrative Region of the People’s Republic of China and Taiwan.
 
This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.