Our Privacy Vow
We, STARTER Limited, are committed to protecting your privacy and shall strictly observe the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Hong Kong Special Administrative Region (“Hong Kong”). All our customer-related information, including accounts, transactions and relevant correspondence, are handled with strict confidentiality. Throughout this statement, our use of the term “personal data” has the meaning ascribed to it by the Ordinance.
Types of personal data collected
For the purpose of carrying on our business, including the provision of various travel arrangements, you may be required to provide certain personal data to us, such as, but not limited to, your name, your date of birth, telephone number, email-address, address, credit card information, bank account number, education level, occupation, household income, interests, and favourite activities etc (“Personal Data”). Your provision of the Personal Data to you is made on a voluntary basis. If you refuse to provide such information, you may be denied access to certain parts of our website, or may render us unable to provide our products or services or to handle your application or request.
Main purposes of holding personal data
You agree that your personal data provided by you to us may be used and retained by us for the following purposes, and for other purposes as shall be agreed between you and us or required by law from time to time:
Providing goods, services and administration work related to your membership;
Processing of your membership application;
Processing the preferential offers or benefits in relation to or arising from our services;
Processing any payment instructions, direct debit facilities and/or credit facilities requested by you;
Marketing and advertising of our products and services, such as sending you news, offers, promotions or events relating to our products and services (please see further details in “Direct Marketing” below;
In accordance with the requirements of the Ordinance, we will honour an individual’s request not to use his or her personal data for the purposes of direct marketing. Should you wish not to receive direct marketing material from us, please write to our Privacy Compliance Officer at the address listed below. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for marketing purposes.
For the above direct marketing use, we intend to
use your name and contact details; and
market or promote our goods, services and other related events.
We may not use or provide your Personal Data unless exempted by the Ordinance or we have received your consent. You can opt-out free-of-charge any time by contacting us if you no longer wish any of your Personal Data to be used in any of the described direct marketing purposes.
Security of your personal data
All personal data you provide to us will be kept in a secured environment with restricted access by authorized personnel only. We shall adopt current Internet security methods and technologies for data transmission. This protects your data by encrypting it in a secure format to ensure that privacy is maintained.
Disclosure of personal data
We may disclose and transfer (whether in Hong Kong or abroad) your personal data to the following parties where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected:
any entities (whether in Hong Kong or abroad) for fulfilling the purposes for which it was collected (subject to any consent requirement relating to “Direct Marketing” above), and to our business partners (whether in Hong Kong or abroad) for direct marketing use as described in “Direct Marketing” above;
any telecommunications operators;
any third-party collection agencies, credit reference agencies, security agencies, credit providers, banks, financial institutions;
any other persons under a duty of confidentiality to us;
any of our actual or proposed assignees or transferees of our rights with respect to you to use, disclose, hold, process, retain or transfer such personal data for the purposes mentioned above; and
any of our subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with us.;
government and regulatory authorities, investigative bodies and law enforcement agencies and other organisations, as required or authorised by law.
If you do not want to have your information disclosed to any third party, please write to our Privacy Compliance Officer.
Access to and correction of personal data
Under the laws of the Hong Kong, you have the right to:
check whether or not we hold any of your personal data;
access your personal data held by us;
require us to correct any personal data that is inaccurate; and
ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.
In accordance with the Ordinance, we have the right to charge a reasonable fee for the processing of any personal data access request. All requests for access to or correction of personal data or information regarding policies and practices and types of personal data held should be made in writing and addressed to: Privacy Compliance Officer [email@example.com]
This statement is written in English language and may be translated into other languages. If there is any inconsistency between the English version and the translated version of this statement, the English version shall prevail.