This Personal Information Collection Statement (this “Statement”) is made by Hong Kong Golf & Tennis Academy Management Company Limited (“HKGTA”, “we”, “us”, or “our”), and applies between us and you (“you”, or “your”). This Statement should be read together with the Terms and Conditions applicable to our academy, facilities and related services, including but not limited to our terms and conditions applicable to Patrons and guests, and terms and conditions of the relevant mobile application operated by us or hosting or running our services (the “Application”) and the website at http://www.hkgta.com (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 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, organisation 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 and/or our Affiliates may issue to you from time to time, including but not limited to the application forms and other documents for eligible Patrons, their spouse, children, and/or guests. If you do not provide the required personal data, then we may not be able to perform the Purposes and/or provide the relevant Goods and Services to you.

If you are under 18 years of age, you should consult with your parent or legal guardian before sharing or providing your personal data to us. To protect your interest as a minor, even if you agree for us to use and disclose your personal data for the relevant purposes as specified in this Statement, we will require your parent or legal guardian to give consent on your behalf before we proceed to so use and disclose your personal data.

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 your name, nickname (or preferred greeting name), gender, age (or age range) (as the case may be), month of birth, date of birth (optional, in the case of an individual over the age of 18), identity card number (or passport number, where applicable), contact details, e-mail address, mailing/residential/correspondence address, contact number, Patron number and/or any other unique identifier or personal identifier of the relevant club(s)/loyalty programme(s) that may be operated by us, our relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be), marital status, family status, educational level, occupation, special health condition (optional), username and password, Log Files (see below), interests and favourite activities, tracking information about your use of our academy premises, facilities, events and programmes, the Application and/or the Website (as the case may be) and transaction information (including your payment information, academy credit details, characteristics and transaction behaviour on the Application and/or the Website (as the case may be)) (“Tracking Data”), analytics data, social media account information, the relevant account metadata, transactional and/or activity records under or relating to your account(s) with the relevant club(s)/loyalty programme(s) operated by us, our relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be), browsing history on the Application, Website and/or third party website browser (and where such third party browser is involved, the personal data we may collect will depend upon your privacy setting with the website browser), 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 (if any)) for further details as to how we collect, use and process Tracking Data.

Please note that your identity card number (or passport number, where applicable) will only be used for verifying your identity when providing you with service(s) requested from us, dealing with your enquiries, Patronship/membership approval checks, registration of the relevant services and for security purposes.

As our privileged and invaluable patron we would like to further collect your actual date of birth (which is only optional in the case of an individual over the age of 18) for us to give to you bespoke birthday gifts and/or birthday rewards/offers/benefits on your actual date of birth and/or ensure that you are eligible to participate in bespoke birthday celebration events, activities and/or campaigns on your actual date of birth organised by us, our relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be), and if you are willing to provide this optional data to us, we will use for the aforesaid purpose only but not for other purposes. However, if you do not want to give us such optional data, you may still be eligible for our general birthday rewards/gifts that we may have during your month of birth.

If you are under the age of 18, your actual date of birth will be collected by us in order for us to verify your eligibility for and to maintain your status as a specific class of Patronship/membership.

For the avoidance of doubt, if where applicable, we will indicate which kind of personal data is mandatory or optional for you to provide at the relevant time of data collection, e.g. when you register your Patronship/membership account(s) with us.

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 and/or our Marketing Partners as defined in the “Direct Marketing” section below, as applicable) for the following purposes (as may be applicable from time to time) (together, the “Purposes”):

• Processing your enquiry about HKGTA and its programmes, services and/or facilities, your enrolment and/or application, and/or use of the same;
• Contacting you in connection with your enquiry about HKGTA and its programmes, services and/or facilities, your enrolment and/or application, and/or use of the same;
• To send you birthday rewards/offers/benefits/gifts (if you have provided your birthday information and consented to direct marketing);
• Processing and managing applications, bookings, orders or requests made by you;
• Facilitating and conducting the management and daily operation of HKGTA and administration of your Patronship, and contacting you in connection with your Patronship;
• Assisting you as the Patron to enrol in the programmes, services and/or facilities provided/operated by our agents, contractors, suppliers, service providers, relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be) by transferring your relevant Patron information (including, but not limited to name, nickname, Patron number and contact details) for the purpose of enrolment. For avoidance of doubt, insofar as your personal data are transferred to such provider/operator of the programmes, services and/or facilities for the aforesaid purpose, the handling of your personal data will be further subject to the terms and conditions and personal information collection statement of any of such provider(s)/operator(s);
• Facilitating your access to the clubs/associations/unions or the like of our Affiliates and/or our Marketing Partners by transferring your relevant Patron information (including, but not limited to name, Patron number, photo, gender, contact number, E-mail address and transaction information (including the minor’s characteristics and transaction behaviour for the purpose of access. For avoidance of doubt, insofar as your personal data are transferred to such provider/operator of the clubs/associations/unions or the like for the aforesaid purpose, the handling of your personal data will be further subject to the terms and conditions and personal information collection statement of any of such provider(s)/operator(s);
• Identifying and verifying your identity and/or as a Patron and/or as a member of any of the relevant club(s)/loyalty programme(s) operated from time to time by us, our relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be);
• Assisting you to register for your selected or designated membership(s) of other clubs/loyalty programmes of our Affiliates and/or our Marketing Partners by transferring your relevant account information (including, but not limited to, your Patron/membership number/unique and/or personal identifier, name, email and mobile, age (or age range) (as the case may be), month of birth, date of birth (optional, in the case of an individual over the age of 18) as applicable) to the aforesaid clubs/loyalty programmes (as the case may be) for the purpose of registration; and enabling the consequent account administration, management and related functions of such selected or designated clubs/loyalty programmes for the purposes of unified access control for your various accounts on the relevant club/loyalty programme’s website, application and/or application platform, data migration or synchronisation for or across your various accounts, and/or unified/centralised management of certain member rewards/benefits initiatives (e.g. K Dollars) that may be applicable to your various accounts. For avoidance of doubt, insofar as your personal data are transferred to such other club(s)/loyalty programme(s) for any of the aforesaid purposes (as applicable), the handling of your personal data will be further subject to the terms and conditions and personal information collection statement of the operator(s) of those other applicable club(s)/loyalty programme(s);
• If/where applicable, facilitating the administration, processing and/or distribution of the relevant member rewards/benefits (if any) (e.g. K Dollars) that you may be eligible for (if any) under those club(s)/loyalty or other programme(s) of our Affiliates of which you are also a member of, and/or your account(s) with the other participating companies you have registered or transacted with that honour or make available such rewards/benefits (hereafter “Other Participating Companies”), subject to the applicable terms and conditions/rules for those other club(s)/loyalty or other programme(s) and/or Other Participating Companies (as the case may be). Without prejudice to the generality of the foregoing, enabling the provision of and/or your usage of eligible member rewards/benefits (e.g. K Dollars) under the relevant club/membership events/campaigns, trade promotion competitions, activities, accounts and/or arrangements offered from time to time (whether solely or jointly) by us, any other relevant club(s)/loyalty or other programme(s) of our relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be) and/or the relevant Other Participating Companies (as the case may be). Likewise, for avoidance of doubt, insofar as your personal data are transferred to such other club(s)/loyalty or other programme(s) and/or Other Participating Companies for these purposes, the handling of your personal data will be further subject to the terms and conditions and personal information collection statement of the operator(s) of those other applicable club(s)/loyalty or other programme(s) and/or Other Participating Companies;
• Handling the registration of your Patronship/membership account(s) with the relevant club(s)/loyalty programme(s) operated by us;
• For our operations, management, administration, processing and/or distribution of the relevant member rewards/benefits (if any) under the relevant promotional campaigns/events and/or activities, campaigns, accounts and/or arrangements for our member rewards/benefits initiatives (e.g. K Dollars) that you may be eligible for (if any), subject to our applicable terms and conditions/rules for those promotional campaigns/events (as the case may be); and in the event that you may be claiming the eligible rewards/benefits (if any) with us through any other clubs/loyalty programmes of our Affiliates and/or our Marketing Partners/Other Participating Companies running your account(s) with them, for our processing of such cross-club/programme claims and handling related data transfers of your relevant account information and transactional records with those other participating clubs/loyalty programmes/Other Participating Companies running your account(s) with them for the administration, processing and/or distribution of the relevant member rewards/benefits (if any);
• Registering you as a user of the Application and/or the Website (as the case may be);
• 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);
• Following registration as a Patron and/or as a user/member, 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, processing eligible member rewards/benefits (if any) for your applicable account(s), 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 (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;
• 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 calls, text message, email and/or mail, and/or other media whether now known or available in the future);
• Improving our academy, facilities and related services, the Application, the Website, the Purposes, and our and our Affiliates’ and Marketing Partners’ Goods and Services;
• Direct marketing and cross-marketing for the Marketing Subjects, subject to consent (see below section entitled “Direct marketing”);
• 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 Application, the Website and the provision of the Goods and Services to you, including without limitation sending messages and/or notifications to you in relation to the management, operation, maintenance and administration of the Application, the Website and the provision of the Goods and Services;
• 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 (and subject to your consent in the event that transfer to any or all such data transferees for direct marketing are involved); 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, including but not limited to, e.g. IT/software solutions/technology services providers, marketing agents, social media, research companies, call centres, customer support outsourcing or customer relationship management service providers, credit card and electronic/digital payment companies, banks, 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 (subject to your consent, if/where applicable) with our Affiliates, our Marketing Partners (see below) and the social media platforms that we and/or our Affiliates/our Marketing Partners (see below) 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 and/or our Marketing Partners (see below) 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 and our Marketing Partners (see below) do the same.

Direct marketing

Subject to your consent, we may use your personal data to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, or other media whether now known or available in the future.

Subject to your consent, we may also use your personal data for, or provide your personal data to, our Affiliates and/or our Marketing Partners (see below) so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, and/or other media whether now known or available in the future.

Our “Marketing Partners” include property developers, banks, financial and investment institutions, credit card and electronic/digital payment companies, insurance companies, private clubs, concierge and customer service providers, retail outlets and online businesses (for various products and services including but not limited to fashion and beauty, accessories, hair dressing and grooming, health and personal cares, luxury, home and living, food, wine and beverage, electronics, books and stationery, cigarettes and cigars, baby and children, veterinary and pet care, outdoor equipment), shopping malls, loyalty programmes, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, restaurants and lounges, catering services providers, healthcare and senior care, services and/or products providers including but not limited to body care, medical/pharmaceutical, health and wellness, art and culture, advertising and marketing, consultancy, gallery and exhibition, event management, green and nature, sports and recreation, travel and accommodation, leisure and entertainment, housekeeping, agriculture, installation and repair, engineering, architectural, transportation and logistics, telecommunication, media and information technology, business management, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, legal, charities, education, pre-school, primary, secondary and/or tertiary education institutions. Without prejudice to the generality of the foregoing descriptions, our Marketing Partners may include Other Participating Companies that we may collaborate with from time to time and/or Other Participating Companies of our Affiliates of which you are also a member of their relevant club(s)/loyalty programme(s).

As we may share your personal data with our Affiliates and/or our Marketing Partners, we may also receive your personal data from them. Subject to your consent given to our Affiliates and/or our Marketing Partners, we may also use such personal data to send you direct marketing about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects (see below).

The types of products, services, events and charitable initiatives that we, our Affiliates and/or our Marketing Partners may market to you include the following (together, the “Marketing Subjects”):

• goods and services offered by us, our Affiliates, and/or our Marketing Partners (including but not limited to the relevant Other Participating Companies) in relation to the Goods and Services and/or the goods and services of those Other Participating Companies;
• finance, banking, mortgage, insurance and other related services and products by banks, financial and investment institutions, credit card and electronic/digital payment companies and insurance companies;
• access and privileges at private clubs;
• professional consultation on customer services, including but not limited to event planning, holidays, hotels, travel, and tickets reservation;
• consumer products and services by retail outlets and/or online businesses, including clothing, shoes, fashion, fashion accessories and beauty, hair dressing and grooming, health and personal cares, luxury, home and living, household products, food, wine, liquor and beverages, confectionary, groceries, books and stationery, toys, cigarettes and cigars, fragrances and cosmetics, baby products, pet services and products, telephones and mobile devices, electronics and electrical appliances, computer software, games, bags and luggage, furniture, sports and leisure equipment, and entertainment and attraction;
• pharmaceutical products, medical and pharmaceutical services, therapists;
• tutoring, mentoring, home cleaning, janitor services, landscape and plant maintenance services, agricultural services, part time housekeeping, plumbing services, locksmiths, barber and salon services, gym and fitness services, laundry services, florists, vehicle towing, and motor vehicle services;
• reward, loyalty, privileges programmes and promotions at shopping malls and department stores;
• reward, loyalty, privileges programmes and promotions for customers and/or potential customers of the New World Group, our Affiliates, our Marketing Partners and/or Other Participating Companies;
• watches, jewelleries and accessories;
• restaurants, lounges, catering services on food, wine and beverage;
• travel, hospitality and accommodation services and products, including but not limited to hotels and serviced apartments, holiday package products and services offered by travel agents, tickets to attractions;
• transportation and logistics services, including but not limited to air travel and non-air transportation services such as hotel transfers, car rentals, bus operators, train operators and cruise operators, and courier services and shipping services;
• conference and exhibition management services, consultancy and marketing research services, supply chain management, event and project management services, gaming services, advertising and public relations services, media production services;
• tickets for concerts, galleries, exhibitions, films, theatricals, sporting, special and cultural events;
• green and nature activities;
• technology, telecommunication, internet and mobile communication services, social networking and media;
• graphic and interior design services, photography services, printing and publishing services;
• legal services, medical services, accounting, auditing, bookkeeping and taxation services, engineering services, architectural services, surveying services, equipment rental services, hospitality services;
• professional advice and/or consultation on education and/or personal enhancement;
• charitable initiatives which support areas 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.

We cannot use or provide your personal data for direct marketing purposes and/or provide your personal data to third parties (whether to our Affiliates and/or our Marketing Partners) for their direct marketing purposes unless you consent. Even if you give your consent, you can opt out of direct marketing – at any time (or you may request that we cease to provide your personal data to third parties, at which point we will cease to do so), free of charge, by emailing privacy@hkgta.com or writing to our Personal Data Privacy Officer (Legal Department) at 4/F, Tsim Sha Tsui Centre, No.66 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong (marked Confidential, and with the name of Hong Kong Golf & Tennis Academy Management Company Limited).

Your rights

Apart from your right to opt out of direct marketing as mentioned above, you have the following additional 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 Department) at 4/F, Tsim Sha Tsui Centre, No.66 Mody Road, Tsim Sha Tsui, Kowloon, Hong Kong or privacy@hkgta.com (marked Confidential, and with the name of Hong Kong Golf & Tennis Academy Management Company 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 Application and/or the Website (as the case may be), 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 Application and/or the Website (as the case may be);
• 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 latest version of this Statement issued to you and/or to check the Application and/or the Website (as the case may be) for updates to this Statement on a regular basis.

Nothing in this Statement shall limit your rights under the PDPO.

If you are:

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

your personal data will be processed by HKGTA in accordance with the “People’s Republic of China Addendum” in addition to the New World Group Privacy Policy Statement, the HKGTA 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.