Privacy Policy

1.Introduction

This Privacy Policy (the “this Policy”) sets out how we and member(s) of Emperor Group (together “Emperor Group”, “we”, “our” or “us”) collect, use and handle your personal data provided to us, or which we have obtained from your visits to or use our websites, mobile applications, social media platforms or our online services (collectively “our Platforms”) or purchase or use any products, services, facilities (including loyalty or membership program) and/or other subjects of any member(s) of Emperor Group (collectively “our Services”).

You shall read this Policy carefully before provision of your personal data or placing order for or using our Services or visiting our Platforms.

By using our Services, providing your personal data or accessing, browsing, using, subscribing or logging in our Platforms, you acknowledge that you have read this Policy and accept the terms herein.

2.Scope

We are dedicated to protecting your personal data and privacy in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong SAR) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR"), Personal Data Protection Act 2012 (No. 26 of 2012 of the Republic of Singapore), Personal Data Protection Act 2010 (Act 70g of the Laws of Malaysia),《中华人民共和国网络安全法》，《电信和互联网用户个人信息保护规定》and all applicable laws and regulations.

3.Purposes of collection and use of personal data

3.1 We will only use your personal data for the specific purposes mentioned to you on or before collection and purposes directly related to such specific purposes. Most commonly, we may use your personal data for the following purposes or uses (without limitation):

a. for processing your order for our Services and delivery or provision of our Services to you;

b. for processing your payment for your order;

c. for improvement to our Services, Platforms and marketing;

d. for research and statistical analysis;

e. for sending you direct marketing if you have consented to it;

d. for compliance with laws, regulations and requirements, in or outside Hong Kong SAR;

e. for handling your enquiries/compliant;

f. for communicating with you;

g. to process your application of our membership program;

h. to administer your membership;

i. to provide, activate and/or renew Services and/or membership program;

j. to provide you with promotional benefits, updates, offers and invitation to events;

k. to contact you regarding administrative notices and communications relevant to your use of our websites and membership program and to respond to your request. We may also use your information to match user information with third party data (i.e. to compare two sets of personal data collected for different purposes). By registering for membership program, subscribing to our website or by logging-in, you consent to carry out this matching procedure when we deem it is necessary in order to provide our services;

for such other purposes mentioned at the time of collection and/or specified in the applicable Personal Information Collection Statement (“PICS”) which is provided to you on or before collection of your personal data.

3.2 If we wish to use your personal data for any new purposes, we will seek your prior consent before use.

3.3 The Platforms are not intended for minors and we do not knowingly collect any personal data from minors, except as part of dealings to provide minors with our Services, in such event, a parental/guardian’s consent may be required before submission of personal data under the applicable laws and regulations. The definition of minors shall be according to the law in the minor’s jurisdiction of residence (e.g. under the relevant privacy laws of PRC, a minor is under the age of 14 and under the Interpretation and General Clauses Ordinance (Cap.1) of HKSAR of PRC, children are under the age of 18).

4. Collection of Personal Data

4.1 We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, and the billing and charging of our products and services (if applicable) (collectively, "Service(s)")) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:

a.name, birth month and salary, etc;

b. contact details including but not limited to address, phone number, mobile telephone number and email address, etc.;

c. payment details including but not limited to credit card, debit card, other electronic banking Data, authorization number, security code, billing address, delivery address and expiry date;

d. customer service information including but not limited to customer service inquiries, comments and repair history;

e. purchase and transaction information (if applicable);

f. device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration (if applicable);

g. information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;

h. your credit and service history to enable us to assess your eligibility to our offers of Services or to accommodate your request for transfer of Services or your account with us;

i. all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and

j. any other Data as may be required by any members of the Group and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Services.

k. In some instances, where required by law to do so, we may seek your consent to process the following types of "Special Data" to us so that we may further improve our Services and/or better tailor the type of information or content that we present to you:

(i) age;

(ii) gender and ethnicity;

(iii) marital status;

(iv) Month and Date of birth;

(v) education and profession;

(vi) monthly income range; and

(vii) contact details, etc

Provision of the Special Data mentioned immediately above is optional although, where the requested Service is a personalised Service or provision of a product is dependent upon your provision of all requested Data, failure to provide the requested Data may prevent us from providing those particular Services to you.

4.2 We will not collect, process or use your sensitive personal data unless with your prior consent or otherwise permitted or required by applicable laws and regulations and the sensitive personal data are used for legitimate and necessary business purposes in accordance with the applicable law. Sensitive personal data includes religious beliefs, specific identities, healthcare, financial account and person’s race.

4.3 We collect Data in a number of ways, including, among other things, from:

a. you directly, for example, when you provide Data by phone or via email, attend our functions, complete an application form or agreement for one of our Services, or when you submit your Data through our websites or WeChat; or when you contact us with a query or request; or during the ordinary course of the continuation of our business relationship with you; or when we are legally required to do so;

b. third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;

c. publicly available sources;

d. our own records of how you use our Services;

e. your visits on our websites (see "Privacy Data" section below); and/or

f. your participation in surveys or marketing promotions organised by us or on our behalf, etc.

As stated above, in order to enroll as a member or use any of our Services, you will be requested to provide us with your name, telephone number, email address, postal address, and where applicable company or organization name. We collect billing and payment information you provide when you apply for using our Services or purchase products and services. If you do not provide us with the requested information, we may be unable to deliver you the Services in full.

To the extent that you disclose to us any personal information of another individual, we assume that you have obtained such individual's consent to disclosure of such personal information as well as the processing of the same in accordance with the terms of this Statement.

4.4 You should read the applicable PICS provided to you together with this Policy before provision of your personal data.

5. Retention of Personal Data

5.1 We will take all reasonably practicable steps to ensure that your personal data is not kept for a period longer than necessary for the fulfillment of the purposes for which we collected it, or for compliance with any legal, regulatory or reporting obligations or for assertion or defending against legal claims.

6. Information about your device(s) and your use of the services

6.1 We collect information about how you use our Services and, depending on the access permissions you have chosen for your device, other information, as specified below, from and about the computers, phones, and other devices where you install or access our Services. We use standard internet technologies, such as cookies and web beacons, to collect information about your computer or device and your online activity. The information we collect in this respect is:

a. your browser type and operating system;

b. IP address and device identifiers;

c. your browsing behavior on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services; and

d. whether you have opened or forwarded our e-mails or connected to offers or links that we send you.

If you use our internet connection, networks, telecommunications systems or information processing systems, your activity and any files or messages on those systems may also be monitored by us at any time, in accordance with applicable law, for purposes of an investigation or to ensure compliance with company policies.

7. Cookies

7.1 Cookies are small text files that can be stored on a user’s computer, tablet or mobile device (“your Device”) when you visit a website. A cookie will typically contain the name of the originating domain, the lifetime of the cookie, and a randomly generated unique number or other value. The cookie itself is anonymous and does not contain any personal data, except when such data is supplied by you, for instance, when you provide your name and email address when completing a registration form.

7.2 Cookies improve your browsing experience. We use cookies to help you access our Platforms faster and more efficiently. Cookies also allow us to store user preferences and provide you with a positive experience when you browse our Platforms, including enabling you to personalize website settings.

7.3 If you do not want Cookies to be placed on your Device, you can always modify your browser settings to accept or refuse Cookies at any time. By using our Platforms, you agree to our Privacy Policy and our Cookies usage.

8. Disclosure and Transfer of Personal Data

8.1 We may disclose, transfer or share your personal data to third parties (whether locally or overseas) in the following circumstances:

a. service provider(s) and organisation(s) under a duty of confidentiality to us who provide administrative, data processing, data storage, collection of payment, IT supports, telecommunications, professional or other similar services to us;

b. third parties (including but not limited to co-branding partners that we partner with in connection with our Services and members of Emperor Group) to whom the disclosure, transfer or sharing of your personal data is to fulfill or facilitate the fulfillment of the purpose(s) for which your personal data is collected;

c. those third parties as set out in the relevant PICS; and

d. governmental bodies or authorities (such as regulatory bodies, law enforcement bodies, government and tax authorities, etc.) as required or authorized by law.

9. Use of personal information

We use the personal information that we collect as necessary and appropriate for the following purposes:

a. to verify your identity;

b. to process your application of our membership program:

c. to administer your membership;

d. to manage and fulfil purchase orders, facilitate delivery and to provide after-sale services;

e. manage our accounts and records:

f. send service related communications, including announcements and administrative messages such as order confirmation;

g. undertake credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our platforms and services secure:

h. to carry out matching procedures, as defined under the Ordinance;

i. to verify your eligibility to our offers and/or promotions or other events;

j. to provide, activate and/or renew Services and/or membership program;

k. to provide you with promotional benefits, updates, offers and invitation to events;

l. to promote and market our Services to you;

m. to provide suitable advertisement and website contents to you;

n. to provide suitable products or services to you;

o. to tailor our products or services to your preferences:

p. to provide anonymous report and to send member notice to us or our clients;

q. to respond to complaints or compliments received;

r. to conduct credit checks and detect fraudulent activities in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) or any other relevant regulations and in relation to other compliance purposes;

s. to perform research or analyses so that we may improve and optimise the Services that can be made available to you;

t. to conduct surveys and marketing, promotional, behavioural scoring for business operations and/or planning purposes;

u. to carry out market and product analyses in order to generate statistical or actuarial reports (containing aggregated data that does not relate to any identified or identifiable individual);

v. to contact you regarding administrative notices and communications relevant to your use of our websites and membership program and to respond to your request. We may also use your information to match user information with third party data (i.e. to compare two sets of personal data collected for different purposes). By registering for membership program, subscribing to our website or by logging-in, you consent to carry out this matching procedure when we deem it is necessary in order to provide our services;

w. to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Services to you;

x. to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;

y. to maintain, enhance and develop our products and service offerings;

z. to operate internal control, resolve disputes, troubleshoot problems and enforce our terms of use;

aa. to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products and customer base; performing data analytics; and performing accounting, auditing and other internal functions);

bb. to comply with applicable laws in or outside Hong Kong as may be required by applicable government authorities, courts, law enforcement, or regulatory or investigation bodies, in relation to the supply of Services and/or loyalty programs to you, including to assist in the prevention, detection of crime or possible criminal activities; and

cc. to distribute our collection brochures and/or promotional materials as well as those of our business partners and counterparties

dd. To transfer of Data outside Hong Kong. At times it may be necessary and/or prudent for us to transfer and/or store your Data to places outside of Hong Kong, for instance, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data were collected. In the event that we do transfer your Data outside of Hong Kong, we will do so in compliance with the prevailing requirements of the Ordinance, other relevant regulations and the GDPR where applicable.

10. Direct marketing

10.1 Subject to your prior consent, we intend to use all information provided by you in your registration form (including your name, contact details and your replies in the Questionnaire portion) in direct marketing. The direct marketing may relate to us or our Group, including :

i. real estate properties located in Hong Kong and overseas (whether residential, commercial or industrial, and including car parking spaces) owned or developed by any Group member or for which any Group member acts as sales or leasing agent, and the loan facilities offered by financial institutions for purchasing or leasing these properties,

ii. shopping malls and hotels owned, operated or managed by any Group member, including the products, services, facilities and events offered by the shops and outlets in these shopping malls and hotels, and

iii. other types of products, services, facilities and events offered by any Group member, including entertainment, furniture, financial services, watches and jewellery, reward/loyalty/privilege programs, corporate social responsibility activities, and charitable and non-profitable causes.

Your personal data collected and maintained by us may be transferred/ disclosed to the parties as listed below:

a. Our subsidiaries, associated companies and/ or business associations;

b. Our joint promotion business partners;

c. Banks or financial institutions;

d. Any person under a duty of confidentiality to us; and/or

e. Any person to whom we are required to make disclosure under any law, court order, direction, code or guideline applicable in or outside Hong Kong.

10.2 If you do not wish us to use your personal data for direct marketing, you may exercise your opt-out right by notifying our Data Protection Officer via the channels as set out in “How to contact us” section below.

11. Security of Data

11.1 We are committed to protect your personal data against unauthorized access, use, disclosure, processing, erasure or loss by taking all practicable measures. However, despite our effort to protect your Personal Data, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal data is limited to our relevant employees and contractors who have a need to know and are required to maintain the confidentiality of your personal data.

11.2 Unless specially required or requested by us, please do not send or publish any personal sensitive data (e.g. contents in relations to race, political views, religious or other beliefs, health record, criminal record or chamber membership, etc.) to us or through our websites or social media platforms. If we specially required or requested your provision of sensitive data, we must obtain your prior express consent.

12. Third-party links

12.1 Our Platforms may contain links to other websites, webpages, mobile applications or media platforms operated by other third parties (collectively the “Third Party Links”) which have their own privacy policies. We do not own and have no control over the content on these Third Party Links and shall not be deemed to endorse or recommend the content on these Third Party Links. We shall not be responsible for the content of these Third Party Links and your use of these Third Party Links shall be at your own risk. Before your visit these Third Party Links, you should read their privacy policy to understand the ways in which your personal data may be used by those third parties.

13. Your rights regarding your personal data

13.1 You have the right to ascertain whether we hold your personal data and access, update, correct and object to our use of your personal data held by us.

13.2 If you wish to exercise any of your rights above, please contact our Data Protection Officer via the channels as set out in “How to contact us” section below.

To the extent permitted under applicable laws and regulations, we may charge a reasonable fee for the administrative costs incurred by us in processing and complying with your request above. We may refuse to handle or comply with any unreasonable requests as permitted by the applicable laws.

14.How to contact us

14.1 For all issues and enquiries regarding our privacy policy or use of your personal data, please contact our Data Protection Officer in writing by any of the following means:

Address: Customer Services Counter

L2, The Pulse, 28 Beach Road, Repulse Bay, Hong Kong

Email:info@thepulse.com.hk

14.2To enable us to handle your requests, we may ask you to provide your identity proof or any other necessary information for the verification of your identity.

These privacy statement bind on all members ("Members") of Impulse once the application form, online or mobile app registration has been signed. Members of Impulse agree and totally accept the privacy statement set forth and any amendments to be made from time to time.

We reserve our right to amend and supplement this Policy from time to time without notice. Please visit our Platforms for the updates to this Policy periodically.