Privacy Policy (“Privacy Policy”)

General Statement of Privacy Policy (“Privacy Policy Statement”)

This Statement is made by Miramar Hotel and Investment Company, Limited and its subsidiaries’ (“Miramar Group”, “we”, “our” or “us”), a member of Henderson Land Group (“Group”), in accordance with the Personal Data (Privacy) Ordinance Cap. 486 (“Ordinance”) of the Hong Kong Special Administrative Region of The People’s Republic of China. This Privacy Policy Statement is intended to inform you Miramar Group’s policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal data.

Miramar Group is committed to ensure that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using our services, mobile applications (“App”) or websites (“Website”), then you can be assured that it will only be used in accordance with this Privacy Policy.

We safeguard information provided by our customers, members, App users, Website users and other individuals (“Users”). With the only exceptions that personal data may be collected in relation to services, App or Website, and the IP address of the computer used to visit our website may be recorded, we do not collect any personally identifiable information from Users while they use the App and Website, and no personal data is collected, unless otherwise specified. This information is used only for preparing general statistics on the usage of the App and the Website.

If personal data is collected in the process of making enquiries or submitting applications for services provided by different operations within the Miramar Group and/or the Group, Users are informed via the Personal Information Collection Statements of such purposes and uses, including the extent of transfer and disclosure and right of access to and correction of the collected data.

We use encrypted data to store and sometimes track information about users in order to provide them with customized information in the App and the Website. The information collected by session includes User’s login name and his or her navigation pattern or preferences. This may be done without the Users being aware that it is occurring. Generally relevant data are used to estimate audience size, to track users’ progress and number of entries in our promotional activities, to know the frequency of user’s browsing or using of individual services, to measure users’ traffic patterns, and to prioritize the information to be provided to them.

We use cookies across our Website in order to improve their performance and enhance Users’ online experience. Session cookies are used to enable Users to move around the Website and use essential functions on the Website, such as maintaining login details for the session such that the need to transfer information across the internet may be reduced. We will not collect any personal data from Users when the cookies are being used.

We may also engage third parties to track and analyze non-personally identifiable data from the App or the Website. We use the data collected by such third parties to help us administer and improve the quality of the App or the Website and to analyze usage of the same. This is unrelated to and separate from your personal data. Such third parties may combine the non-personally identifiable data that we provide about you with other information that they have collected.

The collection of any personal data collected will be subject to our Personal Information Collection Statement. Personal data is stored securely in our system and we will take all practicable steps to ensure that personal data is not kept longer than is necessary for the fulfilment of the purpose (including any directly related purpose) for which the data is or is to be used. Only trained, authorized staff shall have access to the data, and we do not release personal data to parties outside us except as set out in our Personal Information Collection Statement. Users have the right to request access to and correction of their personal information in accordance with the procedure set out in our Personal Information Collection Statements.

We may, from time to time, send direct marketing materials promoting products and services to Users based on their personal data, but suitable opt-out mechanisms are provided.

We make every effort to protect the privacy of Users, but given the nature of the Internet, we cannot guarantee perfect security, especially no information provided over the Internet can be guaranteed to be completely secured.

We use third party content and/or service and/or product providers (the “Third Party Service/Product Providers”) and offers links to third party websites. These Third Party Service/Product Providers may collect personal data from Users and they adhere to their own privacy policies. Our Privacy Policy Statement and Personal Information Collection Statements do not cover third parties.

User who has any questions about our privacy policy and practice can contact our Data Protection Officer at privacy@miramar-group.com or by post to 15/F Mira Place Tower A, 132 Nathan Road, Tsimshatsui, Kowloon, Hong Kong.

Personal Information Collection Statement (“Personal Information Collection Statement”)

This Personal Information Collection Statement sets out the purposes for which the information provided by you as a User will be used following collection, what you agree with respect to our use of such information and your rights under the Personal Data (Privacy) Ordinance, Cap 486. This statement may change from time to time, so please check back periodically. When you use our services, log in to the App and the Website and use its services, you agree to be bound by this Personal Information Collection Statement in force at that time.

What we collect

We may collect the following information:

Personal information including name, gender, birthday, job title
Contact information including email address, phone number, mailing address
Demographic information such as place of residence, preferences and interests
Other information relevant to customer surveys and/or offers

So as to provide you with events, promotions, products and/or services. You are not obliged to supply us with the data, but if you do not, we may not be able to provide you with our products and/or services, and the selected services cannot be provided via the APP and the Website.

1. What we do with the information we gather

We require the information to understand your needs and provide you with a better service, and in particular for the following reasons:

Providing, marketing and promoting products, services, and/or facilities of Miramar Group, the Group, or any Relevant Person, and managing, maintaining, processing, operating, improving and introducing these products, services and/or facilities;
Delivering information to Users that Users may have interest in, such as banners of targeted promotional events, new products and services and other promotions and marketing materials of Miramar Group, the Group, or any Relevant Person;
Processing billing and payments;
Monitoring use of our services, the App and the Website to help facilitate the development of our services, the App and the Website;
Compiling aggregate user statistics to analyze usage pattern of our services, the App and the Website;
Operating internal control, following up on comments and enquiries, investigating and handling complaints and disputes, and enforcing terms of use and related legal matters;
Processing applications, provision and maintenance of the membership programs, and processing membership registration, setting up and maintaining members’ accounts on the App and the Website;
Identifying and verifying the identity/eligibility of Users who use/used the App and the Website, and services provided by us;
Collecting statistics, conducting research and analysis, including market research by Miramar Group, the Group, or any Third Party Service/Product Providers;
Contacting and communicating with Users in respect of matters and arrangement related to the use of the App and the Website and/or the use of services provided by us;
Providing Users with products and/or services offered by us, and/or the information and updated information in relation to these products and/or services;
Processing, following up and evaluating the provisions of services, privileges, rewards, promotions, discounts, special offers or conveniences, or applications, requests, registration and reservation of products, services and/or facilities offered by Miramar Group, the Group, or any Third Party Service/Product Providers;
Designing and optimizing the facilities, services and/or products of Miramar Group, the Group, the Business Units, or any Third Party Service/Product Providers;
Checking and comparing any information relating to you from time to time for the purposes listed in this section;
Preventing or detecting any illegal or suspicious activity;
Complying with any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply; and
Any other purpose(s) which has been agreed by the user from time to time.

If you are under the age of 18, you must seek your parent or guardian’s consent before providing any personal data to us.

2. Disclosure and transfer of Personal Data

We shall take all practicable steps to ensure the security of your personal data. To facilitate the above purposes, we may disclose or transfer the user’s personal data to any of the following parties irrespective of whether such parties are located inside or outside Hong Kong, provided that any disclosure or transfer of the Users’ personal data to another person for direct marketing purposes is subject to the “Use and Provision of Personal Data for Direct Marketing” in the next section:

(i) Members and associates of Miramar Group and the Group;
(ii) Any agents, contractors and/or third-party service providers providing us with services in relation to administrative, telecommunications, information technology, system management, repair and maintenance and/or other services to support the business operation of Miramar Group and the Group;
(iii) Any person who has a duty of confidentiality to us, including our accountants, legal advisers or other professional advisers; and
(iv) Any regulatory or other authorities to whom we are required to make disclosure under any law binding on us or upon any request, guidelines or codes we are reasonably expected to comply with.

3. Use or Provision of Personal Data for Direct Marketing

We are committed to protecting all personal data information to be used for internal purposes only. Miramar Group and the Group may provide such information to any agent or contractor who provides administrative or other services to us and the Group in connection with the operation of its business. We intend to use your data in direct marketing and we require your consents (which include an indication of no objection) for that purpose. In this connection, please note that:

(i) the name, contact detail, services preference and interest of you held by us from time to time may be used by us in direct marketing;
(ii) the following classes of services, products and subjects may be marketed
• Hotels & Serviced Apartments
• Asset Management
• Food & Beverage
• Travel
(iii) the above services, products and subjects may be provided and solicited by us and the Group, or any Relevant Person;

If you do not wish us to use your data for the use in direct marketing as described above, you may exercise your opt-out right by notifying us by following the instructions in the section on “Controlling your personal information” below.

4. Security

To ensure that your information is secure and to prevent unauthorized access or disclosure, we have put in place suitable procedures to safeguard and secure the information we collect online.

5. How we use cookies

A cookie is a small file which asks permission to be placed on hard drive of your computer. Once you agree, the file is added and the cookie helps analyze the Website traffic or lets you know when you visit a particular site. Cookies allow the Website to respond to you as an individual. The Website can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use cookies to help us analyze data about the Website traffic and improve our Website in order to tailor it to customer needs. We only use this information for statistical analysis purposes, the data will be removed from the system afterwards.

Overall, cookies help us provide you with a better Website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your device or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser to decline cookies if you prefer. However, this may prevent you from taking full advantage of the website.

6. Links to other websites

The App and the Website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy policy. You should exercise caution and look at the privacy statement applicable to the website in question.

7. Controlling your personal information

You may choose to restrict the collection or use of your personal information in the following ways:

7.1 Whenever you are asked to fill in a form on the App or the Website, look for the box that you can click to indicate that you do not want the information to be used for direct marketing purposes

7.2 If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at unsubscribe@miramar-group.com.

7.3 We will not sell, distribute or lease your personal information to third parties unless it is required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting.

7.4 You may request details of personal information which we hold about you under the Ordinance. A small fee will be payable. If you would like a copy of the information held on you please write to or email us. Our postal address is 15/F Mira Place Tower A, 132 Nathan Road, Tsimshatsui, Kowloon, Hong Kong. Our email address is privacy@miramar-group.com

7.5 If you believe that any information we are holding on you is incorrect or incomplete, or you would like to delete your personal information, please write to or email us as soon as possible. We will promptly update the information accordingly.

7.6 We may change this policy from time to time by updating this page without notice. You should check this page from time to time to ensure that you are aware of those changes.

7.7 In case of any inconsistency or conflict between the English and versions of other languages, the English version shall prevail.