We, App Media Group Limited, undertake in our data management policies and practices to observe the data protection principles and to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong). This Statement explains our policies and practices.
1. Collection of information
In order for us to promote, to improve and to provide better services/products we offer and to provide personalized services and products to each of our customers, we may collect information when you register with us, use our services or products, including our mobile application, attend our functions, or communicate with us.
You will have the option to decide whether to supply such information to us voluntarily or not. However, if specific information is requested but not supplied, we may be unable to provide the requested services or products accordingly.
The minimum personal information we need is your name, address, e-mail address, telephone and mobile number, postal address, credit card information (including expiry date, security code and number), email address, spa providers and treatments and/or treatment time. In special cases as we deem necessary, we may need additional or more specific information from you to provide personalized services and products. If the specific information is not supplied, we may not be able to provide the personalized services requested and it will be your obligation to provide such information before you may receive the personalized services and products.
We may also collect non-personally identifiable information which may be linked to your personal data, including but not limited your user name, ip address, geographic data, operating system type, nationality and password and search preferences (both specific and generic).
We may also process the technical data of your mobile device when you are using our mobile application, including your ip-address, device ID or MAC-address, information of the manufacturer, model and operating system your mobile device.
We collect information from you when you enter into a user agreement with us or when you accept our services or use our mobile application or register as a user.
All practical steps will be taken to ensure that personal data will not be kept longer than necessary and that we will comply with all statutory and regulatory requirements in Hong Kong concerning the retention of personally identifiable information.
2. Use of information
The purposes for which information may be used by us include:
(a) to register you with the Mobile Application as requested by you;
(b) providing enquirers with contact and information in respect of our services/products;
(c) providing individual and personalised services and products (mainly to process your reservation);
(d) processing applications or reservations;
(e) facilitating the provision of services/products by us including but not limited to the any other related services/products;
(f) distribution of our publications, marketing and promotional materials (and as the case may be, those of our business partners and counterparts);
(g) marketing of our services/products;
(h) observing and complying with the laws in or outside Hong Kong;
(i) to build features that will make the services available in the Mobile Application easier to use;
(j) deliver the functionalities of the mobile application and resolve technical difficulties;
(k) providing a most updated version of the mobile application and improve its function; and
(l) for an improved user experience and general optimization purposes, including but not limited to faster reservations requests, better customer support, payment services and timely notice of new services and special offers.
We may conduct direct marketing via direct mail, telephone, facsimile, e-mail, or other means of communication to you where we will provide you with our latest offer of various gift certificate, coupons, discounts, promotion deals, information and advertisements in relation to different spa providers and spa treatment.. You may choose not to receive promotional materials by indicating your choice when downloading the Mobile Application or simply telling us (see below for contact details), and we will cease to do so, without charge.
3. Disclosure of information
We will disclose your personal data and other information we collected to the spa providers, so that such providers can provide the services and spa treatments as requested by you.
We will keep the personal data we hold confidential but may provide information to the following parties (whether within or outside Hong Kong):
(a) any agent, contractor or third party service provider who provides administrative, telecommunications, payment or securities clearing or other services to us in connection with the operation of our business;
(b) any other person under a duty of confidentiality to us, including a group company of us which has undertaken to keep such information confidential;
(c) persons to whom we are required to make disclosure under applicable laws in or outside Hong Kong;
(d) with third parties we appoint to perform services on our behalf, such as web hosting services, data analysis, to market our products and services, also on websites of third parties, to handle credit card transactions; or
(e) actual or proposed transferees or participants of our services.
All such third parties will be under an obligation to maintain the security and confidentiality of the Personal Data, and to process the Personal Data only in accordance with our instructions.
We reserve the right to disclose your personal data to our affiliated (group) companies (in and outside your home country), including our affiliated (group) companies’ employees and our trusted agents and representatives who have access to this information with our permission and who need to know or have access to this information to perform the service requested by you (including customer services) and internal (audit/compliance) investigations.
Save for disclosures mentioned in this 私隱政策 and the disclosure of your Personal Data and information required for completing your booking with the relevant spa provider and the sharing of certain Personal Data with selected partners where relevant (your details will be used for reporting and analysis purposes only), we will not disclose your Personal Data to third parties without your consent.
We only permit authorized employees to access personal data, and such employees are trained on our privacy policies. Personal data will either be stored electronically in a secured manner or in physical form placed in restricted areas.
5. Data transfers
We will generally hold your data in Hong Kong. However, we may transfer it, as the case may be, to our offices outside of Hong Kong or to any of the parties as listed at paragraph 3 above, who may or may not be located elsewhere.
We reserve the right to update or amend this Statement. You may contact us to obtain a latest copy of this Statement (see below for contact details).
7. Your consent and rights
By using our services/products, making an enquiry or making an application, you consent to the collection and use of your information and other activities as outlined in this Statement.
Under the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong), individuals have the right:
(a) to check whether we hold personal data about you and to access such data
(b) to require us to correct inaccurate data; and
(c) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us.
8. Note About Minors
Persons under the age of 18 are not eligible to use the spa treatment reservation services in our Mobile Application.
9. Contact details
Please direct your requests to access or correct data, to cease communications, and enquiries or complaints to:
App Media Group Limited
Level 9, Central Building,
1-3 Pedder Street
Central, Hong Kong
We may charge a reasonable fee for processing a data access request.