Personal Information Collection Statement
This Personal Information Collection Statement (this “Statement”) is made by K11 Loyalty Program Limited (“K11 LP” “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 “K11 HK” Mobile App, “Wechat” and/or other device(s) or application(s) (“Application”) and the K11 website at www.KLUB-11.com (“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.
K11 LP is part of the New World group of companies which includes New World Development Company Limited (“NWD”), New World Property Management Company Limited, NWS Holdings Limited, New World China Land Limited, New World Department Store China Limited, K11 Concepts Limited, New World Loyalty Programme Limited, New World Group Charity Foundation Limited, K11 Art Foundation Limited, Humansa Limited and other affiliated or related companies from time to time as listed here (“New World Group”) (including any joint venture companies where any of the New World Group’s companies has an interest from time to time as listed here) whose activities include real estate (sale, leasing and investment), mortgage services, retail, property management, facilities management, activity planning and management, infrastructure, shopping malls, 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, transportation, sustainability programmes and products, TMT (Technology, Media and Telecom), 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 (see below), you are required to provide all the requested/mandatory personal data in the application form for KLUB 11 membership. 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
The kinds of personal data we may collect from you include your name, gender, age (or age range), month and date 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 Application/Website and transaction information (including your characteristics and transaction behavior) (“Tracking Data”), social media account information, etc.
Purposes for using personal data
The personal data to be collected from you 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”):
- For daily operation and administration of your membership, and to contact you in connection with your membership;
- To deliver bespoke services and membership benefits to you;
- To process bookings, purchases, orders or requests made by you;
- To send you birthday messages and offers (if you have provided your date of birth) or event reminders;
- Identifying and verifying your identity and/or as a member;
- Registering you as a user of the Application/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 Application/Website;
- Following registration as a user, accessing your account information 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/customer behavior including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour to provide other 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 of, 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 of, or by text message, email and/or mail, and/or other media whether now known or available in the future);
- Improving the Application/Website, 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/Website and the provision of the Goods and Services to you;
- 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/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 in connection with the Purposes and/or the provision of the Goods and Services, e.g. IT providers, marketing agents, 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. We may also share your personal data 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 requested by any court, regulatory body or governmental body of any country, 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 place or country in which it is stored, and we procure by contract or use our reasonable endeavours to ensure that our Affiliates and our Marketing Partners do the same.
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 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 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, finance and investment institutions, insurance companies, private clubs, concierge and customer service provider, 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 services providers, healthcare and senior care, services and/ or products providers including art and culture, gallery and exhibition, green and nature, sports and recreation, travel and accommodation, leisure and entertainment, transportation and logistics, telecommunication and information technology, education and institutions.
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.
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 and/or our Affiliates in relation to the Goods and Services;
- finance, banking, mortgage, insurance and other related services and products by banks, finance and investment institutions 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, 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, telephones and mobile devices, electronics and electrical appliances, computer software, and games, bags and luggage, furniture, sports and leisure equipment, ;
- 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;
- watches, jewelleries and accessories;
- restaurants, 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 service, 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 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 writing to our Personal Data Privacy Officer at 4th Floor, Tsim Sha Tsui Centre, 66 Mody Road, Tsim Sha Tsui East, Kowloon, Hong Kong (marked Confidential).
You have the right 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;
- 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 at 4th Floor, Tsim Sha Tsui Centre, 66 Mody Road, Tsim Sha Tsui East, Kowloon, Hong Kong (marked Confidential). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.
- our collection and/or use of log files (data relating to your use of/visits to the Application/Website, including but not limited to your IP address, domain name, browser type and access time);
- retention of your personal data;
- third party merchants and/or websites that may be contained in the Application/Website;
- how we keep your personal data secure;
- use of your personal data in legal proceedings.
If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.
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 Application/Website for updates to this Statement on a regular basis.
Nothing in this Statement shall limit your rights under the Personal Data (Privacy) Ordinance of the laws of Hong Kong.
This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.
Updated: 18 March 2020