Privacy Notice

PERSONAL DATA PRIVACY NOTICE

Introduction

This Privacy Notice sets out the basis on which we collect and process your personal data through your use of our website(s), our digital applications (Apps), online profiles, signing up for newsletters, request for proposal, competitions and/or other marketing activities on online or through digital communications.

Any changes we make to this Privacy Notice in the future will be posted on this page with or without prior notice so please check this page regularly.

For the purpose of applicable data protection laws, Wharf Hotels Management Limited is the data controller responsible for your personal data. We respect the privacy of all our customers, web users and or business partners, and treat all personal information as confidential. All personal data we collect and process is handled in accordance with the applicable data protection laws, including the General Data Protection Regulation (EU) (2016/679), the Personal Data (Privacy) Ordinance of Hong Kong and, where feasible, internationally recognised standards of personal data privacy protection.

Our Commitment to Protect Personal Data Privacy

This Personal Data Privacy Notice (the “Notice”) applies to personal data (defined as data from which a living individual is identifiable (by anyone) directly or indirectly) and information regarding guests and any other individuals with whom we do business with and to the management of that data and information in any form, whether electronic or written.

This Notice gives effect to our commitment to protect your personal and sensitive information and has been adopted by all the hotel properties owned, managed and/or operated by Wharf Hotels Management Limited or its affiliated or associated companies. References to “Marco Polo Hotels”, "Niccolo Hotels", “we”, “our” and “us” hereinafter, depending on the context, collectively refer to those separate and distinct properties or entities.

Collection of Personal Data

The term “personal data” in this Notice refers to any information relating to an identified or identifiable natural person ("data subject") which we, in the process of providing you with a particular service, may ask you to supply to us. Personal data may be collected as part of but not limited to:

(i) Fulfilling reservations or requests for information or services,
(ii) Meeting local legal requirements for registering guests,
(iii) Browsing of website (please see our Cookies policy below for more information),
(iv) Purchasing our products or services,
(v) Registering for program memberships or online profile,
(vi) Meeting for sales calls/appointments, attending of trade and road shows or requesting for proposals via our procurement team;
(vii) Submitting job applications; or

 
YOUR PERSONAL DATA
Information You Provide to Us

• You will provide some or all of the following information to us when you make reservations from our website, enrol as a member, register an online profile, use one of our Apps, contact us, sign
up for newsletters, request for proposal, register to check-in at one of our hotels, and other marketing activities, either in one of our hotels or online:
• Your Identity and Contact Details -includes your name, date of birth, travel ID, email address, home postal address/billing address, delivery address (if different), and your contact telephone number;
• Your Payment Details - your bank details and payment card details, however your payment transactions will be encrypted during our booking journey and by the acquiring bank so we will not retain any payment card details submitted by you;
• Your Profile Data - if you register an online profile, this includes the profile you create to identify yourself when connecting to our website and Apps (including your username and password) and other data about reservations and your personal preferences; and
• Additional Personal Details - At your option, you can also provide additional personal data to us such as your gender, product preferences and interests. This additional information would only be collected and stored by us for the purposes of analyzing your sales to help us understand and improve our services and for the purposes of any direct marketing emails, pushed messages, telephone calls, social media posts (such as Facebook or WeChat) or SMS , in line with your marketing preferences and provided you have expressly consented to receiving such emails, pushed messages, telephone calls, social media (such as Facebook or Wechat) or SMS .

Direct Marketing includes but not limited to:

• Room offers
• Restaurant, Bars and Events promotions
• Celebratory Offers
• Hotel Opening
• Hotel News and Updates
• DISCOVERY and Marco Polo Rewards Membership News and Updates
• Guest Experience Surveys

Information We Collect When You Use Our Website or Our Apps

As you interact with our website and Apps, we also automatically collect usage and technical data (described below) about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Click here for more information about how we use cookies.

Cookies: We need your consent for our use of cookies, and request this each time your visit our webpage..

Usage Data- includes details of Wharf Hotel, dining restaurants and services you have viewed and reserved, and information about how you use our website and our Apps;

Technical Data - includes:

• your Internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website;
• information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, mobile applications traffic data, weblogs and other communication data;
• if you use a mobile device to access our website or one of our Apps, the type of mobile device you use, a unique device identifier (for example, your device’s IMEI number, the MAC address of the device’s wireless network interface, or the mobile phone number used by the device), mobile

network information, your mobile operating system, the type of mobile browser you use, time zone settings).

Other - We may also receive information from third parties we work closely with such as wifi service provider, online reservation and review platforms, reference agencies and fraud prevention agencies. These third parties may share information with us in accordance with their own data protection policies and procedures.

WHO WE SHARE YOUR PERSONAL DATA WITH

• We may share your information within the Wharf Hotels owned and managed hotels, Global Hotels Alliance for DISCOVERY membership purposes and with our selected third parties for the purposes referred to above. For example:
• Payment Acquiring Services to process your payment;
• Confirmation, amendments, up-grading and cancellation of your reservation to manage your reservation;
• Credit Reference & Fraud Prevention Agencies for credit checking and identity verification;
• Analytics and search engine providers that assist us in the improvement and optimisation of our website and Apps; and for user personalisation and experience
• Build and hosting service providers that help us to maintain the software that runs our website, booking engine and our Apps. They provide us with reporting statistics, and serve cookies on our behalf to enable any website or Apps personalisation and sign-in functionality. Click here for more information on how we use cookies.
• Where you have provided consent to direct marketing, personal pricing recommendation engines, third party advertisers, affiliate marketing agencies and advertising networks engaged by us to select and serve relevant communications to you on our behalf, provided this is in line for your marketing preferences.

We require all third parties engaged by us to respect the security of your personal data and to treat it in accordance with the law. Such third parties are only allowed to process your personal data in accordance with our instructions, and not for their own purposes.

From time to time, we may ask you if you would like to be contacted by other selected third parties, such as part of a joint promotion or a collaboration. If we do this, we will also provide you with a link to that third party’s privacy notice to help you decide whether or not you wish to be contacted by them. If you do consent to this (by an express opt in), that third party would be the data controller in respect of any activity by them that you have consented to, in accordance with their own data protection policies and procedures.

Links to Other Organisations

Our website and/or our Apps may, from time to time, contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

Cookies (including those which enable banner advertising) require a separate opt out and please Click here for more details.

DIRECT MARKETING

We need your consent for direct marketing communications. If you have expressly given your consent to receive direct marketing from us, whether via our website, Apps or at any of our hotels, we may use the information you have given us for:

• delivering direct marketing, advertising and updates from us to you, such as telling you about forthcoming offers, products, features and updates and information about us;
• measuring and understanding the effectiveness of advertising we serve to you and others; and
• making suggestions and recommendations to you and other users of our website and our Apps about goods or services that may interest you or them.

If you have previously given your consent to us, but now no longer wish to receive direct marketing and updates from Wharf Hotels, Marco Polo and or Niccolo Hotels, you can unsubscribe at any time by clicking the ‘unsubscribe’ link available in each email you receive from us. You can also amend

your preferences by contacting customer services on +852 2118-7232 or by emailing communications@wharfhotels.com.

If you are a registered online profile user you can also opt out by contacting customer services on +852 2118-7232 or by emailing communications@wharfhotels.com.

Please Note: It is important that the personal data we hold about you is accurate and up to date. Please keep us informed if your personal data changes during your relationship with us.

and
Our website is not intended for use or access by children and we do not knowingly collect personal data relating to children under 16 years of age. In the event that we are required to process children's personal data, we will obtain verifiable parental/guardian consent .

SECURITY OF YOUR PERSONAL DATA

Our website and Apps have appropriate security measures in place to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. All information you provide to us is stored on secure servers. We have also put in place procedures to deal with any suspected or actual data breach.

Where you have chosen a password which enables you to access certain parts of our website or our Apps, you are responsible for keeping this password confidential. We ask you to choose an effective, secure password and not to share your password with anyone.

We recommend only connecting to secure wireless networks that you trust to reduce the risk of unauthorized people intercepting your online activity. Beware of the risks of using public wifi.

If you receive an email purporting to be from Wharf Hotels, Marco Polo Hotels and or Niccolo Hotels for personal data, please do not respond to the email but please let us know that this has happened so we can check whether the email is genuine. communications@wharfhotels.com

PROCESSING PERSONAL DATA OUTSIDE THE EEA - DATA STORAGE & TRANSFER

Your personal data will be transferred to, and stored at, locations in Hong Kong and Singapore and in the location of the hotel in which you stay or visit. It will also be accessed and processed by our personnel and the personnel of our partners, affiliates and third party service providers, who operate outside of Hong Kong and Singapore. Your personal data will only be transferred to locations outside of Hong Kong and Singapore where we are satisfied that adequate or comparable levels of protection are in place to protect personal data held in that jurisdiction, and (where we are required to do so) with your consent.

When personal data is transferred from the EEA to outside the EEA, we use Model Clauses, so ensuring that such data transfers are compliant with applicable privacy legislation.


HOW LONG WE KEEP YOUR PERSONAL DATA

Your personal data is processed by us and/or our service providers only for the period necessary for the purposes for which the information is collected. Generally, we will keep your personal data for up to 24 months from the date of collection and will be for as long as you are a customer, although we may keep it longer in order to response to any questions or complaints. When we no longer need to use your information for those purposes, we will remove it from our systems and records or take steps to anonymize it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations to which we are subject).


YOUR RIGHTS

If you are a resident in the European Economic Area (EEA), your rights under data protection laws in relation to your personal data are briefly summarised below. You can exercise these rights by emailing us at communications@wharfhotels.com or by writing to us at Branding and Communications Department, Wharf Hotels Management Limited, 5/F Marco Polo Hongkong Hotels, Canton Road, Harbour City, TST, Kowloon, Hong Kong.

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which we will tell you about, if applicable, after receiving your request.
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms.
• Request restriction of processing of your personal data. You can ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, electronic, machine-readable format. Please note that this right only applies to automated information which you initially provided consent for us to use (such as for direct marketing communications) or where we used the information to perform a contract with you (such as to manage your booking).
• Withdraw consent at any time if we are relying on your consent to process your personal data (e.g., to conduct direct marketing and for our use of cookies). This won’t affect any processing already carried out before you withdraw your consent or processing under other grounds. If you withdraw your consent, we may not be able to provide certain products or services to you.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We may also contact you to ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data and we will respond to all requests within one month.

You can make any of these requests in relation to your personal data, and ask questions about this privacy notice, by sending an email to communications@wharfhotels.com


Miscellaneous

This Privacy Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Privacy Policy, the English version shall prevail.


PERSONAL DATA COOKIES POLICY

Our website uses cookies to distinguish you from other users. This helps us provide you with a good experience when browsing and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use or may use the following cookies:

• We use Google AdWords re-marketing technology to market our sites across the Internet. We place a cookie on your browser, and then a 3rd party (Google) reads these cookies and may serve an ad on a 3rd party site, after you have visited our website.

Other cookies:

a) necessary cookies

Necessary cookies are essential and help you navigate the Site. These cookies make sure your basket is saved during all steps of the checkout process. This helps to support security and basic functionality of the Site. These cookies are necessary for the proper operation of our Site, so if you block these cookies we cannot guarantee your use or the security of our Site during your visit.

b) functional cookies

Functional cookies are used to provide you the best user experience. These cookies are for instances used to save and remind you about reservations you have started to make, so will save you time if you want to complete your reservation at a later stage. These cookies could also recognise if a Site user has already signed up for our newsletter/requested information about a service or if the user is seeing a certain page for the first time.

c) performance cookies

Performance cookies help us to understand the behaviour of our visitors and the usage of the Site. This allows us to continuously improve the Site to provide you the best user experience. These cookies are also used to help us understand what interests our users, and measure how effective our advertising is. Some of these cookies are managed by third parties, and you may refer to the third parties' own website privacy notifications for further information.

By way of example, we use Google Analytics cookies to obtain an overall view of visitor habits and visitor volumes, and to help improve the overall experience on our Site. Google Analytics is a third-party web analysis service provided by Google Inc, which uses "performance cookies" and "targeting cookies" to analyze how you use the Site. The information generated by the cookie about your use of the Site (including your IP address) will be transmitted to and stored by Google on servers in the United States. However, this website uses Google Analytics with the expansion '_anonymizeIp()' which means that Google will truncate/anonymize the last octet of the IP address for Member States of the European Union.

On behalf of us, Google will use the information collected for the purpose of evaluating your use of our Site, compiling reports on Site activity and providing other services relating to Site activity and internet usage to us. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser as described below. Furthermore you can prevent Google’s collection and use of data (cookies and IP address) by downloading and installing the browser plug-in available
under https://tools.google.com/dlpage/gaoptout?hl=en-GB#. You may disable the use of Google Analytics by using the link disable Google Analytics. This link creates an opt-out cookie which prevents the further processing of your data. For more information about Google Analytics cookies, please see Google's help pages and privacy policy.

We also use Adobe Experience Cloud cookies, namely Adobe Analytics and Adobe Audience Manager, to analyze visitors’ activities on our website. You may disable the use of Adobe Experience Cloud cookies to stop further processing your data by following the instructions set out in this link: https://www.adobe.com/hk_en/privacy/opt-out.html. For more information about Adobe Experience Cloud cookies, please see the Adobe privacy policy.

If you do not accept the use of these cookies, we cannot guarantee how our Site will perform for you.

d) advertising cookies

Advertising cookies will remember your preferences and, in general, that you visited the Site. We strive to provide you with advertisements for hotels, resorts, and other products and services relevant to you and your interests on other online platforms, where available. These cookies are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of advertisements.

If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows a customer to deny or accept the cookie feature; however, you should note that cookies may be necessary to provide customers with certain features (e.g., customized delivery of information) available on this web site, which you may not be able to access if you block all cookies via your browser. You may opt out of this ad serving on Google’s opt out page HERE

Most cookies (other than essential cookies) will expire within 24 months

If you have any questions or concerns about how we treat your personal information, you wish to ask us to stop processing your personal information, or you would like to request a copy of the personal information we hold about you, please email us at communications@wharfhotels.com