Collection of Personal Data
From time to time and for the purpose of carrying on Sino-Asia’s businesses and operations, including the provision of services to you, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data") such as, but not limited to, the following:
- Your name;
- Contact details such as email address, mailing and residential address, telephone number, and fax number;
- Membership number and details (such as transactions conducted using your membership account);
- Information for verification of identity, including identification type and identification number (such as your HKID and passport number) and other related information;
- Billing information such as your credit card number, bank account information and billing address;
- Demographic information such as age, gender, nationality, marital status, preferences, educational background and employment history;
- Details of transactions conducted using your membership account.
- Supply of Personal Data to Sino-Asia is non-obligatory, but failure to do so may result in Sino-Asia being unable to process your application(s) or to provide services to you.
Occasionally, you may need to provide Personal Data about other individuals to Sino-Asia (e.g. spouse or children or guests). In that event, to comply with the Ordinance, you are required to have first obtained the authorisation of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to Sino-Asia possible use, disclosure and transfer of their Personal Data, for the purposes you would want to achieve from Sino-Asia. If necessary, Sino-Asia may require you to provide to Sino-Asia any supporting documents which may be necessary to prove such authorisation. You should also advise them that Sino-Asia can be contacted for further information.
Use of Personal Data
Your Personal Data may be used for the following purposes:
- Providing goods, services and support or performing transactions and administration work
- Processing of your application to subscribe to the Club’s services and facilities as set out in paragraph 1;
- Verifying your identity;
- Matching (as defined in the Ordinance) your Personal Data with other data collected (by Sino-Asia or third parties) for other purposes, in relation to, the provision of facilities, goods and services to you and/or the performance of any transactions and administration work related to Sino-Asia ‘s operations;
- Marketing and advertising of any goods and services to you by Sino-Asia, such as sending you offers and promotions (please see further details in "Direct Marketing" below);
- Maintaining and developing Sino-Asia ‘s business systems and infrastructure, including testing and upgrading of these systems;
- Facilitating communications between you and Sino-Asia.
- Sino-Asia may also use from time to time aggregate non-identifying information about its customers to better design and improve Sino-Asia’s goods and services that it offers. This information will not identify any individual in particular.
Sino-Asia intends to use your Personal Data for direct marketing carried out by Sino-Asia. The intended kinds of Personal Data to be used and the intended classes of marketing subjects are specified below. However, Sino-Asia may not so use or provide your Personal Data unless exempted by the Ordinance or Sino-Asia has received your consent.
For the above direct marketing use, Sino-Asia intends to:
- use your name, contact details and demographic information; and
- market or promote goods, services, support and related events and activities offered or arranged by Sino-Asia or our respective business partners:
- You can always contact Sino-Asia if you no longer wish any of your Personal Data to be used in any of the described direct marketing purposes.
Disclosure of Personal Data
Personal Data supplied to Sino-Asia will be kept confidential. However, Sino-Asia may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, provide such Personal Data to the following parties:
- any parties for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above), and to Sino-Asia ‘s business partners for direct marketing use as described in "Direct Marketing" above;
- any person or company who is acting for or on behalf of Sino-Asia in respect of the purpose or a directly related purpose for which the data was provided;
- any other person or company who is under a duty of confidentiality to Sino-Asia and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
- Sino-Asia’s agents, contractors, suppliers and any third party service provider who provides administrative, marketing and research, distribution, data processing, telemarketing, telecommunications, computer, payment or other services to Sino-Asia in connection with the operations of its business;
- government and regulatory authorities, investigative bodies and law enforcement agencies and other organisations, as required or authorised by law;
- any financial institutions, including banks, necessary to establish and support the payment of any services and facilities provided to you; and
- your authorised representatives or your legal advisers when requested by you to do so.
- Sino-Asia may also disclose your Personal Data to third parties: (i) when required by law, by court order or in response to a search warrant or other legally valid inquiry; or (ii) pursuant to Sino-Asia’s good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defences, to obtain legal advice, to exercise and defend Sino-Asia’s legal rights or to protect the life, body or property of any individual. This also applies when Sino-Asia has reason to believe that disclosing the Personal Data is necessary to identify, contact or bring legal action against someone who may be causing interference with Sino-Asia’s rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by activities causing such interference.
The Personal Data that Sino-Asia collects or obtains may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. By submitting Personal Data to Sino-Asia or using any of Sino-Asia’s services, you understand and consent to such transfer.
Links to Third Party Websites
By using Sino-Asia’s website ("Website") and mobile apps, you agree that Sino-Asia can store and access cookies, IP addresses and use other methods in order to collect website usage data and improve your on-line experience.
Cookies are small files that are placed on your computer by websites that you visit or certain emails you open. They are widely used in order to make websites function properly, as well as to provide business and marketing information to the website owners.
All Personal Data that has been collected from you will only be stored for a duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.
Commitment to Data Security
Sino-Asia is committed to protecting the security of your Personal Data. It uses a variety of physical, technological and organisational measures to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.
Requesting Access, Correction, and Deletion of Personal Data
You are entitled to request access to your Personal Data held by Sino-Asia, to correct or delete such data. Sino-Asia may charge a reasonable fee for the processing of such data access requests.
Data Privacy Compliance
Room 12, 15/F., Honour Industrial Centre, 6 Sun Yip Street, Chai Wan, Hong Kong
This notice is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.