PRIVACY POLICY

A) Privacy Policy Statement of The Town Club (HK) Limited

 
The Town Club (HK) Limited (“HKGTA Town Club”, “we”, “us”, or “our”) is part of the New World group of companies including New World Development Company Limited 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”) and 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, and HKGTA Town Club Personal Information Collection Statement (“PICS”) that will be issued to you when we collect your personal data (whether in person, on or through our website, or otherwise). If there is any inconsistency or conflict between the New World Group Privacy Policy Statement and this Statement, this Statement shall prevail. If there are any inconsistency or conflict between our PICS and this Statement, our PICS shall prevail.

Please also see the New World Group Privacy Policy Statement and the PICS, if/where applicable, for our policies and information about:

  • our collection and/or use of log files (data relating to your use of/visits to this website, including but not limited to your IP address, domain name, browser type and access time);
  • our collection, use and/or transfer of your personal data for the relevant purposes as further specified in our PICS (if/where applicable);
  • the use of cookies and other tracking mechanisms;
  • retention of your personal data;
  • third party merchants and/or websites that may be contained in this website;
  • how we keep your personal data secure;
  • use of your personal data in legal proceedings.

Enquiries

 
If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by us, please contact our Personal Data Privacy Officer at:

30th Floor, New World Tower,
18 Queen’s Road Central,
Hong Kong
Attention: Personal Data Privacy Officer (Legal and Company Secretarial Department)
(Marked Confidential, and with the name of The Town Club (HK) Limited)

or by email at privacy@hkgtatownclub.com

The PRC Addendum

 
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 uses our 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, this Statement and our PICS, 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. For the purpose of this Statement, “Hong Kong” means the Hong Kong Special Administrative Region of the People’s Republic of China.
 

B) People’s Republic of China Addendum

 
1. Application
 
The Town Club (HK) Limited (the “HKGTA Town Club”, “we”, “us”, or “our”) is part of the New World group of companies including New World Development Company Limited and its affiliated or related companies from time to time (as listed here: https://www.nwd.com.hk/pics) (“NWG”) and is committed to protecting personal data of individuals in territories where we do business.
 
If you are:

    (i) an individual located in Mainland China who visits or uses the relevant website(s) or mobile application(s) of HKGTA Town Club, or otherwise uses or attends HKGTA Town Club’s premises, facilities, event, 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 the HKGTA Town Club’s premises, facilities, events and/or programmes of HKGTA Town Club in Hong Kong or otherwise uses HKGTA Town Club’s products and/or services by phone or any other means in Hong Kong,

your personal data will be processed by HKGTA Town Club in accordance with this Addendum in addition to the HKGTA Town Club Privacy Policy Statement (“Privacy Policy Statement”), the HKGTA Town Club Personal Information Collection Statement (“PICS”), and the New World Group Privacy Policy Statement (“NWG’s Privacy Policy Statement”), as well as the applicable data protection laws and regulations in Mainland China.
 
Therefore, before using HKGTA Town Club’s products and/or services or providing any personal data to us, please ensure that you have carefully read, understood and agree to the PICS, the Privacy Policy Statement, NWG’s Privacy Policy Statement and this Addendum.
 
For the purpose of this Addendum, “Mainland China” refers to the People’s Republic of China excluding the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the Macau Special Administrative Region of the People’s Republic of China and Taiwan. Unless defined otherwise, all defined terms (capitalised terms) in this Addendum shall have the same meaning as the defined terms in the Privacy Policy Statement, NWG’s Privacy Policy Statement and PICS.
 
In the event of any conflict or inconsistency, they shall be resolved in the following order of precedence (from higher to lower) in respect of such conflict or inconsistency: – (a) this Addendum; (b) the PICS; (c) the Privacy Policy Statement; (d) NWG’s Privacy Policy Statement.
 
2. Personal data
 
In this Addendum, “personal data” refers to various information related to an identified or identifiable natural person recorded electronically or by other means and does not include anonymized information. Personal data involved in this Addendum includes those set out in Clause 5 of the NWG’s Privacy Policy Statement.
 
In addition, “sensitive personal data” refers to “personal data” that, once leaked or illegally used, may easily lead to violation of the personal dignity of a natural person or harm of personal or property safety. The “sensitive personal data” involved in the Privacy Policy Statement and this Addendum includes residential address, marital status, Log Files, Tracking Data (including information about your use of our club premises, facilities, events and programs), transaction information (including your payment information, club credit details, characteristics and transaction behavior).
 
“Process” or “processing” of “personal data” includes the collection, storage, use, processing, transmission, provision, disclosure, deletion, etc. of “personal data”.
 
3. How we collect and process your personal data
 
Apart from Clauses 5 and 6 of the NWG’s Privacy Policy Statement, the following also applies to how we collect and process your personal data:-

    a) Your personal data will be processed by HKGTA Town Club for the purposes as further specified below and set out in the relevant PICS (“Purposes”). In particular, for us to carry out the Purposes and provide you with the relevant products/services, the personal data (including sensitive personal data) set out below (either collected from you directly or via Hong Kong Golf & Tennis Academy Management Company) is necessary. If such information are not available or not accurate, we may not be able to provide the relevant products/services to you:-
     

    No. Purposes Personal data we may collect
    1. Processing your enquiry about HKGTA Town Club and its services and/or facilities, and/or use of the same • Name
    • Contact number
    • Email address
    • Membership Number
    2. Contacting you in connection with your enquiry about HKGTA Town Club and its services and/or facilities, and/or use of the same • Name
    • Contact number
    • Email address
    • Membership Number
    3. Processing and managing applications, bookings, orders or requests made by you • Name
    • Contact number
    • Email address
    • Membership Number
    4. Facilitating and conducting the management and the daily operation of HKGTA Town Club and administration of your patronship, and to contact you in connection with your patronship • Name
    • Contact number
    • Email address
    • Membership number
    5. Identifying and verifying your identity and/or as a patron • Name
    • Membership number
    • User name and
    password
    • E-mail address
    6. Registering you as a user of the Application and/or the Website (as the case may be) • Name
    • Date and month of birth
    and age range
    • Contact details
    • E-mail address
    • Mailing/correspondence
    address
    • Contact number
    7. 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 Application and/or the Website (as the case may be) • Log Files
    • Tracking Data
    8. Following registration as a patron and/or as a user of the Application and/or the Website (as the case may be), 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 • Log Files
    • Membership number
    9. 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 (subject to your consent for direct marketing, if/where applicable) to provide other goods and/or services better tailored to your needs, and to assist us in selecting Marketing Subjects (see below) that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining • [Interests and favourite activities
    • Social media account information
    • Tracking Data
    • Marital status
    • Family status
    • Educational level
    • Occupation
    • Transaction information (including your characteristics and transaction behavior)
    10. 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 of, or by text message, email and/or mail, and/or other media whether now known or available in the future) • Name
    • Contact number
    • E-mail address
    • Membership number
    11. 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 of, or by text message, email and/or mail, and/or other media whether now known or available in the future) • Interests and favourite activities
    • Transaction information (including your characteristics and transaction behavior)
    12. Improving our club, facilities and related services, the Application, the Website, the Purposes, and our and our Affiliates’ and Marketing Partners’ Goods and Services • Tracking Data
    • Interests and favourite
    activities
    • Transaction information (including your characteristics and transaction behavior)
    13. Direct marketing and cross-marketing for the Marketing Subjects, subject to consent • E-mail address
    • Gender
    • Date and month of birth
    and age range
    • Contact number
    • Mailing/
    correspondence
    address
    • Tracking Data
    • Interests and favourite
    activities
    • Transaction information (including your characteristics and transaction behavior)
    14. Data analytics, profiling, information management and database administration • Interests and favourite activities
    • Social media account information
    • Tracking Data
    • Marital status
    • Family status
    • Educational level
    • Occupation
    • Transaction information (including your characteristics and transaction behavior)
    15. 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 subject to the applicable laws and regulations in the Mainland China • Name
    • Contact details
    • Residential address
    16. Collection or recovery of any debt owed by you to us or our Affiliates • Name
    • Contact details
    • Residential address
    • Transaction
    information (including your characteristics and transaction behavior)
    17. The normal management, operation, and maintenance of the Application, the Website and the provision of the Goods and Services to you • Name
    • Contact details
    • Mailing address
    • Membership number
    • Contact number
    • User name and password
    • Transaction information (including your characteristics and transaction behavior)
    18. Storing your personal data (whether by a single or multiple Affiliates (including us) or our Marketing Partners) for the purpose of sharing such personal data with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above • Name
    • Contact number
    • Email address
    • Date and month of birth
    and age range
    • Residential or
    Business Address
    • Emergency Contact
    • Business Nature
    • Job Title Office
    • Spouse’s Name,
    Contact Numbers , email address, date and month of birth and age range

    b) In general, we process your personal data with your consent, and where appropriate, with separate consent from you for processing your personal data under specific circumstances required by the applicable data protection laws and regulations in Mainland China. You acknowledge and agree that under the following situations, we are not required to obtain your consent to process your personal data:-

      (i) the processing is necessary for the conclusion or performance of a contract to which you are a party, or where it is necessary to conduct human resources management according to lawfully formulated labour rules and lawfully concluded collective contracts;
      (ii) the processing is necessary for the performance of our duties or obligations under any applicable laws and regulations, including those directly related to:

        a) National security and national defence;
        b) Criminal investigation, prosecution and trial and execution of court orders, judgments or related matters; or
        c) Public security, public health, or major public interest;

      (iii) the processing is necessary for responding to public health emergencies, or for the protection of life, health and property safety of natural persons under emergency circumstances;
      (iv) the personal data is processed within a reasonable scope to conduct news reporting, supervision by public opinion and other activities in the public interest;
      (v) the personal data is made available to the public by you or the personal data about you from legitimate public sources is processed within a reasonable scope in accordance with the laws and regulations; or
      (vi) other circumstances as provided by the laws and regulations.

4. Your rights as the personal data subject

    1) Please refer to Clause 15 of the NWG’s Privacy Policy Statement and the PICS in relation to your rights to access, correct your personal data and withdraw your consent. Further, in accordance with the applicable data protection laws and regulations in Mainland China, we will ensure that you may exercise the following rights over your personal data, including:-

      a) You may request to delete your personal data if:-

        （1）our processing of your personal data breaches laws or regulations;
        （2）we collect or use your personal data without your consent;
        （3）our processing of your personal data breaches our agreement with you;
        （4）you no longer use our products and/ or services, or the purposes described in Clause 3 of this Addendum have been achieved or accomplished;
        （5）you withdraw your consent;
        （6）we no longer provide products and/or services to you;

      b) Change the scope of your consent;
      c) Obtain a copy of your personal data; or
      d) Request to transfer your personal data to another personal data processor provided that such request is compliant with the applicable laws and regulations.

    2) Such requests shall be made to 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). We will endeavour to reply to your reasonable requests in relation to the above within fifteen (15) PRC working days from the day we receive your request.
    3) However, please note we may refuse your requests under the following circumstances:-

      a) Circumstances relevant to the fulfilment of our obligations under laws and regulations, including our provision of your personal data (including your sensitive personal data) generated during the transaction between you and us to the regulatory authority(ies) and or other governmental departments under the laws and regulations of Mainland China;
      b) The data retention period required by any law or administrative regulation has not expired, or it is difficult to delete personal data technically (in such cases, we will take necessary security protection measures to ensure the security of your personal data or anonymize such personal data);
      c) Circumstances directly related to national security and defence security;
      d) Circumstances directly related to public security, public health, or significant public interest;
      e) Circumstances directly related to criminal investigation, prosecution and trial, and execution of court decision;
      f) Circumstances where we have sufficient evidence to prove that you have subjective malice, or you are abusing your rights;
      g) Circumstances where protection of your or other individual’s life, property and other important lawful rights is involved;
      h) Circumstances where responding to your request will cause serious harm to the lawful rights and interests of you or other individuals or organisations (including us); or
      i) Circumstances where trade secrets are involved.

    5. Retention of personal data
     
    Your personal data will be kept by us for no longer than necessary for the fulfillment of the Purposes. Please refer to Clause 8 of the NWG’s Privacy Policy Statement for further details.
     
    6. How we entrust others to process, share, transfer and publicly disclose your personal data

      a) To achieve the Purposes under Clause 3 of this Addendum, you understand and agree that we may entrust the processing of your personal data (including sensitive personal data) to third party service providers as set out in Clauses 9 and 11 in the NWG’s Privacy Policy Statement as well as to Hong Kong Golf & Tennis Academy Management Company.
      b) The third party service providers entrusted by us have no authority to use your personal data for any other purposes. If there is any change to the purpose of processing of your personal data, we will ask for your consent again.
      c) Your personal data (except Hong Kong Identity card number and Passport Number) may also be shared with the New World Group and joint venture companies together referred to as “Affiliates” and our “Marketing Partners” located within or outside Hong Kong, which include property developers, banks, financial and investment institutions, insurance companies, private clubs, concierge and customer service providers, retail outlets and online businesses (products and services including fashion and beauty, health and personal cares, luxury, home and living, food, wine, and beverage, books and stationery), shopping malls, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, catering service providers, healthcare and senior care, services and/or products providers including health and wellness, art and culture, gallery and exhibition, green and nature, sport and recreation, travel and accommodation, leisure and entertainment, transportation and logistics, telecommunication, media and information technology, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, pre-school, primary, secondary and/or tertiary education institutions etc., the details of which are set out in Index 1 of this Addendum.

7. How we store and transfer your personal data
 
In principle, we collect, produce and process the personal information in the PRC in accordance with the business purposes set out in Clause 3 of this Addendum and they will be stored in the Hong Kong. You understand, authorise and consent that we may transfer your personal information outside Mainland China to our headquarters in Hong Kong, Affiliates, Marketing Partners and other entities outside Mainland China (please refer to Index 2 of this Addendum for further details), and to the servers and/or data centres in Hong Kong of our partners, co-operators, agents, contractors, suppliers and service providers whom we have entrusted to process your personal information (please refer to Index 3 of this Addendum for further details), due to business needs and solely for achieving the business purposes set out in Clause 3 of this Addendum and to the maximum extent permitted by law and in accordance with the mandatory requirements under the laws and regulations of the PRC. The Mainland China and Hong Kong have enacted personal information protection laws, and we will also ensure that your personal information is adequately protected in accordance with this Addendum. If you would like to learn more about the storage and cross-border transfer of your personal information, withdraw your consent and/or exercise your other rights in accordance with Clause 4 of this Addendum, please contact us via the means set out in Clause 10 of this Addendum and we will respond to your request to a reasonable extent.
 
We will not transfer your personal data to any company, organisation or individual outside of HKGTA Town Club, its Affiliates and/or Marketing Partners, except under the following circumstances:

    （1） Transfer with separate consent. After obtaining your separate consent, we will transfer your personal data to other parties in accordance with this Addendum;
    （2） When we are involved in any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer or purchase of HKGTA Town Club’s business (please refer to Clause 18 of the NWG’s Privacy Policy Statement);
    （3） We may otherwise transfer your personal data in accordance with applicable laws and regulations, requirements under legal proceedings, compulsory administrative or judicial requirements.

8. How we process minors’ personal data
 
Our products and services are only provided to those who are above the age of eighteen (18). If we are aware that we have collected personal data of any individuals below the age of eighteen (18), we will immediately delete such personal data.
 
9. Miscellaneous
 
Further, the following Clauses in the NWG’s Privacy Policy Statement shall apply:-

    a) Clause 4 shall apply in respect of the use of cookies and other tracking mechanisms;
    b) Clause 12 shall apply in respect of the security of personal data;
    c) Clause 13 shall apply in respect of circumstances where HKGTA Town Club excludes liability for disclosure of your personal data, which will be subject to the applicable laws and regulations in Mainland China;
    d) Clause 17 shall apply in respect of the update of the Privacy Policy Statement and this Addendum.

10. How to contact us
 
If you have any questions, comments or suggestions regarding this Addendum, or wish to exercise your rights over your personal data in accordance with the Privacy Policy Statement or this Addendum, please feel free to 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).
 
 

Index 1

Name of recipient Purpose of
sharing		 Manner of
sharing		 Types of information shared personal being Contact particulars
New World Development Company Limited Marketing, data analysis internal study Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 privacy@nwd.com.hk
Hong Kong Golf and Tennis Academy Management Company Limited Marketing, data analysis internal study Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 privacy@hkgta.com
New World Corporate Services Limited • data analysis
• internal study		 Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 tdshelpdesk@nwcs.com.hk
Humansa Physiotherapy & Fitness Limited Marketing, data analysis internal study Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers, email address, Date and month of birth and age rage		 privacy@humansa.com.hk

 

Index 2

Name of recipient Purpose of
sharing		 Manner of
sharing		 Types of personal information being shared Contact particulars
New World Development Company Limited • Marketing
• data analysis
• internal study		 Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of birth and age range
• Residential or Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 privacy@nwd.com.hk
Hong Kong Golf and Tennis Academy Management Company Limited • Marketing
• data analysis
• internal study		 Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of birth and age range
• Residential or Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 privacy@hkgta.com
New World Corporate Services Limited • data analysis
• internal study		 • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 tdshelpdesk@nwcs.com.hk
Humansa Physiotherapy & Fitness Limited • Marketing Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers, email address, Date and month of birth and age rage		 privacy@humansa.com.hk

 

Index 3

Name of recipient Purpose of
processing		 Manner of
processing		 Types of personal information being processed Contact particulars
New World Development Company Limited • Marketing
• data analysis
• internal study		 Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of birth and age range
• Residential or Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 privacy@nwd.com.hk
Hong Kong Golf and Tennis Academy Management Company Limited • Marketing
• data analysis
• internal study		 Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of birth and age range
• Residential or Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 privacy@hkgta.com
New World Corporate Services Limited • data analysis
• internal study		 • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers , email address, Date and month of birth and age rage		 tdshelpdesk@nwcs.com.hk
Humansa Physiotherapy & Fitness Limited • Marketing Sharing the reports of the database • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers, email address, Date and month of birth and age rage		 privacy@humansa.com.hk
Aspen Software Limited • Storing data
• Data analysis		 • Data storage
• Sharing the reports of the database		 • Name,
• Contact Numbers
• Email address
• Date and month of
birth and age range
• Residential or
Business Address
• Emergency Contact
• Business Nature
• Job Title
• Spouse’s Name, Contact Numbers, email address, Date and month of birth and age rage		 Kip
kip@aspen.com.hk