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- Brilliant Business Centre Limited ("we", "our" or "us") and its subsidiaries, holding companies and their direct or indirect subsidiaries, joint ventures, and associated companies (we and the above companies collectively, the "Group Companies") attach great importance to your privacy. When you use our Services (as defined below), we may collect and use your personal data ("Personal Data"). We are committed to protecting the privacy of your Personal Data we hold.
1. 2. 1 What Personal Data We Collect
1. 2. 2 How We Use Your Personal Data and Who We Disclose To
1. 2. 3 How We Retain, Store and Protect Your Personal Data
1. 2. 4 Your Rights and Contacting Us
1. 2. 5 Cookies
1. 2. 6 Third Party Websites
1. 2. 7 Reminder about Information Sharing
- "Services" or "Activities" means any new and/or existing services, products, facilities, activities, contests, lucky draws and/or other events, such as using our websites or mobile applications, following or using our social media accounts e.g. WeChat Official Account, receiving emails or text messages from us or sending us emails or text messages, using our telephone customer service, etc. relating to us and/or our Group Companies or our or their portfolios of properties or tenants in such portfolios of properties. If you do not provide the relevant Personal Data, you may not be able to register as our user, enjoy the Services, or, even if we continue to provide you with certain Services, the quality of such Services may not be optimal.
- Note: Protecting the privacy of children under eighteen (18) years of age is our primary concern. Our website or mobile applications are not intended for children under eighteen (18) years of age.
What Personal Data We Collect
We may collect and process some or all of the following Personal Data about you:
2. 1. 1 your personal information ► personal information that you provide to us, such as when using our Services, website or mobile application, including your name, gender, date of birth, age, identity card number or other personally identifiable number, etc.;
2. 1. 2 your contact information ► contact information you disclose to us, such as telephone numbers, addresses, mailing addresses, WeChat accounts, email addresses and fax numbers, etc.;
2. 1. 3 your business information ► including company name, business title, and associated contact information, etc.;
2. 1. 4 your payment details ► information on your credit or debit or other charge cards, or other means of payment, including name of cardholder, card number, billing address, security code and expiry date, information on other electronic payment accounts (including but not limited to WeChat Wallet, Alipay account, Apple Pay etc.);
2. 1. 5 survey information ► your comments and responses, etc. to market surveys, contests and promotional offers conducted by us or on our behalf; and/or
2. 1. 6 website and communication usage ► details of your visits to our websites or mobile apps or social medial platforms collected through cookies or other tracking technologies including behavioural information, browser details, IP addresses, purchasing history, location information, etc.;
- Your Personal Data is required for the use of our Services. If you fail to supply such Personal Data requested, we may not be able to deliver to you the relevant Services. By providing your Personal Data to us, you acknowledge that you have made an informed decision in providing such Personal Data.
- We may collect Personal Data about you directly or from third parties such as business partners under joint promotions and brand collaborations. We may also generate and compile Personal Data and collect Personal Data from publicly available sources about you.
- We may collect and process some or all of the following Personal Data about you:
How We Use Your Personal Data and Who We Disclose To
We may use the Personal Data collected about you for one or more of the following purposes:
3. 1. 1 To provide the Services ► to provide the Services to you (e.g. to process your reservation requests and confirm your booking, to facilitate any special requests or assistance that you have asked for), to process payment for any of the Services (e.g. to verify credit card details with third parties), to identify and verify your information in connection with any of the Services that may be provided to you;
3. 1. 2 To provide customer support ► To manage customer relationship such as responding to your enquiries, and communicating with you by email, letter, telephone, mobile application (e.g. WeChat Push) or other means;
3. 1. 3 To operate loyalty or reward programmes ► To operate and administer any Services (including membership, loyalty or reward programmes (including joint collaborations with other brands) etc.). We may transfer your Personal Data to the operators of the Services (including our loyalty or reward programmes or our business partners (including brands that we collaborate with)) to facilitate your participation;
3. 1. 4 For marketing purposes ► Where you have provided consent or do not object in writing (as required by law), to provide you with news, latest offers and promotions or marketing communications, where you have chosen to receive these. 3. 1. 4. 1 We may use your name, contact details, location data, customer profiling information (including information about your use of our website and activity on social media platforms, including your preferences, transaction pattern and behaviour) collected compiled, generated or held by us from time to time for marketing our own, other Group Companies’ and/or our business partners’ Services to you by email, letter, telephone, fax, text messages. 3. 1. 4. 2 In particular, we may use your Personal Data (a) for marketing, research, questionnaires, promotional and customer relationship management purposes including sending you information relating to our own, our Group Companies’ and/or our business partners’ products, facilities, services, membership clubs, reward programmes (including joint collaborations with different brands), activities, contests, lucky draws, promotions, blogs, newsletters and/or events. 3. 1. 4. 3 Where required by law, we will ask for your consent at the time we collect your Personal Data to conduct any of these types of marketing and promotions. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in the “Contacting Us” section below. We may share data or statistics with third parties in aggregated and anonymised form for marketing purposes;
3. 1. 5 For analytics and profiling ► To conduct analysis from time to time to better understand your spending, dining and/or other consumption needs, preferences, interests, experiences and/or habits. In order to enhance your experience or for other uses to which you agreed, we, subject to compliance with applicable laws and regulations, may combine the Personal Data we collected about you from other Group Companies or our business partners so that we can customise the content or display information which is most relevant to you. For example, Personal Data collected about you when you use the Services provided by other Group Companies may be combined with Personal Data we collected about you when you stayed in one of our hotels, so we can better understand your preferences and tailor our marketing communication to include offers that are of the most interest to you.
3. 1. 6 To improve the Services ► To design new and/or enhance existing Services.
3. 1. 7 For safety and security purpose ►To safeguard public interest, or protect the personal safety of our customers, our employees or other office users, and property safety of the Group Companies. We may also conduct background checks and/or credit searches on companies who wish to open a corporate account with any of our offices for verification purposes and to prevent fraud or other criminal activities. This may include disclosures to credit reference agencies, credit, debit and/or charge card companies and/or banks.
3. 1. 8 For legal and administrative purposes ► To comply with applicable laws and regulations, court order or any requirements of relevant government authorities or securities exchange; to establish legal claims or defences; to obtain legal advice; to exercise, safeguard and/or protect the rights or properties of any member of the Group Companies, including identifying or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or property of any other person could be damaged by such interfering activities. This may include disclosures to any counterparties (and its legal advisors), insurers, loss adjustors, government, regulatory or law enforcement authority, administrative organisation or securities exchange of any jurisdiction;
In addition to the disclosures we have identified above, we may disclose Personal Data for the purposes set out in section 3.1 to the following entities (the "Transferees"):
3. 2. 1 any members of the Group Companies;
3. 2. 2 our or our Group Companies’ advisors (e.g. legal, financial, business or other advisors) who are under a duty of confidentiality to us or our Group Companies.
- We may use the Personal Data collected about you for one or more of the following purposes:
How We Retain, Store and Protect Your Personal Data
- In order to ensure the correct use and to maintain the accuracy of the Personal Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Personal Data, we have implemented various internal policies (including physical, electronic and management measures) and various security technologies and procedures. For example, where we collect Personal Data online, we use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol to protect the Personal Data. Our websites have firewalls in place, which should protect the Personal Data collected from you against unauthorised or accidental access. However, please understand that, due to technical and risk prevention limitations, even if we have made our best effort to enhance security measures, we cannot ensure that your Personal Data is absolutely safe. You should note that the systems and communication networks you use to access our Services may be subject to problems beyond our control. Therefore, you are advised to protect against unauthorised access to your password and credit card details. When using a shared computer, make sure you sign out from your account when finished.
Your Rights and Contacting Us
Under certain conditions, you may have the right to:
5. 1. 1 access your Personal Data held by us;
5. 1. 2 correct your Personal Data held by us;
5. 1. 3 request deletion or erasure of your Personal Data;
5. 1. 4 object to the sharing of your Personal Data; and/or
5. 1. 5 object to the profiling of your Personal Data.If you would like to exercise any of the above rights or obtain a copy of any of your Personal Data, or if you believe that any of your Personal Data which we collect and maintain is inaccurate or would like to request for information regarding policies and practices and kinds of personal data held by us, please contact us at the address set out in section 5.5 below.
- We will endeavour to use appropriate technical means to ensure that you can access, update and correct your Personal Data. In accessing, updating, correcting and/or deleting your Personal Data, we may ask for you to authenticate your identity in order to protect the safety of your Personal Data.
- To the extent permitted by relevant laws and regulations, we reserve the right to refuse unreasonable requests (for example, requests which infringe the privacy of others). To the extent permitted by relevant laws and regulations, we reserve the right to charge a reasonable fee for the cost of processing any request set out in Section 5.1 above.
If you agree to receive marketing communication but do not wish to receive them in the future, you may opt out of receiving them at any time, free of charge, by the following applicable means:
5. 4. 1 unsubscribing by following the "Reply To" instructions contained in the marketing text message;
5. 4. 2 following the unsubscribe instructions or hyperlink in the email;
5. 4. 3 notifying us that you no longer wish to receive marketing communication when receiving our marketing calls; or
5. 4. 4 contacting us at the address stated in section 5.5 below to tell us that you no longer wish to receive marketing communication through any channel.
- We may issue service-related announcements to you when necessary (e.g. when we suspend a service due to system maintenance). You may not be able to opt out of these announcements which are service-related and not promotional in nature.
Right to opt out of direct marketing
Contact person: Data Protection Officer
Company Name: Brilliant Business Centre Limited
Email address: firstname.lastname@example.org
- Under certain conditions, you may have the right to:
- Third-party websites are independent from our websites, and we have no control over the contents of such third-party websites, their privacy policies or compliance with the law. You should therefore be fully aware that the provision of links to third party websites does not constitute an endorsement, approval, or any form of association by or with the Group Companies. We have no control over Personal Data that you have submitted to these websites. Therefore, you should remain alert when you leave our websites.