Data Privacy Policy

1.  Commitment to Personal Data Protection

CCG CRM Limited ("CCG Hearts"), a part ofChinachem group (CCG), mean each of and collectively,Chime Corporation Limited and its holding companies, subsidiaries, affiliates and associated companies.

1.1  In handling personal data, CCG Hearts is committed to protecting your personal data privacy in accordance with the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of Hong Kong (the "Ordinance").

1.2  To enable you to make informed decisions about providing us with your personal data ("Data") when using our websites, we outline in this notice our policies and practices and the choices you have concerning the collection and use of your Data. This notice sets out the kinds of Data which may be collected, the main purposes for which your Data may be used, and who you may contact for making data access requests and data correction requests.

1.3  We may update this notice from time to time. You are advised to review this notice from time to time.



2.  Types of Data We Collect

2.1 By submitting an application for CCG Hearts membership and successfully registering as a CCG Hearts member (member), such applicant / member agrees that CCG Hearts and CCG may collect, store, process and transfer his Personal Information in accordance with these Terms and Conditions and in any manner that CCG deems fit from time to time.

2.2 Each member shall ensure that he provides Personal Information that is true, complete and accurate and not inaccurate, false or misleading. Each member is solely responsible for maintaining access and control of his/her own membership account, username and password and the confidentiality thereof and shall be responsible for any activity that is performed using such Membership account username and password (whether authorized or not).

2.3  The types of Data we collect may include:

a. your personal information (e.g. your name, gender, month and year of birth, nationality, family status, passport or other identification number, the particulars of your registered status with any of the Chinachem Group members or its business associates); 

b. your contact information (e.g. your telephone number, email address); 

c. your business information (e.g. the name of your company and your business title); 

d.  your credit card or other charge card information (e.g. name of cardholder, card number, billing address and expiry date) when necessary for payment or point registration; 

e.  your parent’s or guardian’s name and phone number for authentication and approval of membership application when member is aged between 14-17 upon membership registration;  

f.  information about your use of our websites, apps, services or products, social media, your personal preferences and comments, and responses to promotional offers and surveys. 

We stress that it is not obligatory for you to provide the Data to us. However, if you elect not to provide the Data, we may not be able to supply or continue to supply you with the relevant information, services or products.



3.  Purposes for which the Data are Collected and Used

3.1  Depending on (i) the nature of your relationship with CCG Hearts and (ii) the specific types of services, products, facilities, or privileges as requested by or provided to you, CCG Hearts and CCG may use the Data for one or more of the following purposes from time to time:

a.  To provide you a valid CCG Hearts membership;  

b.  To support CCG Hearts daily operations (including the provision of benefits, perks, redemptions products, offers and other membership related functions); 

c.  to process your application or request, for example, participation for a Quest, event or privileges usage; 

d.  to provide services, products, facilities or privileges to you, and handle the necessary arrangements and matters (including legal, administrative and other matters) for maintaining and managing such services, products, facilities or privileges. These services, products, facilities or privileges may relate to the sale, purchase or leasing of property units or car parking spaces, and may include membership clubs or reward or loyalty programmes; 

e.  to verify your identity upon redemption or benefits usage; 

f.  to calculate any amount payable by you or to you in connection with the relevant services, products, facilities or privileges; 

g.  to enforce the terms of any contract or arrangement between you and any Chinachem Group member and to take suitable action to protect or preserve the rights or benefits of any Chinachem Group member; 

h.  to communicate with you and for overall relationship management and maintenance; 

i.  to investigate, handle and respond to any comments, messages, requests, enquiries, complaints or incidents made by you, made against you or involving you in any manner; 

j.  to design, arrange, provide or procure services, products, facilities, privileges, activities or events for you or for customers generally, through our websites or other telecommunications channels or electronic means; 

k.  to conduct survey, research and analysis to facilitate the provision of services, products, facilities, privileges, activities or events to you or to customers generally; 

l.  to market and promote services, products, development projects, facilities, events and/or activities offered or organised by any CCG Hearts or Chinachem Group member or any business partner (including any joint venture companies in which any Chinachem Group member has an interest) or selected company that has made any co-branding or cooperative arrangement with any Chinachem Group member; 

m.  to comply with any obligations or requirements for using or disclosing personal data that are imposed on any Chinachem Group member by any law or regulations, or by any governmental agency, regulatory authority, law enforcement agency, court or judicial body, whether in or outside of Hong Kong existing currently or in the future; 

n.  to comply with any policies and measures for using or disclosing personal data implemented by the Chinachem Group for prevention or detection of money laundering, terrorist financing or other unlawful activities; 

o.  to match or compare the Data held by any Chinachem Group member from time to time in order to or intending to produce or verify data which may be used for taking adverse action against you; 

p.  (where any Chinachem Group member believes in good faith that use or disclosure of personal data is necessary) to protect the rights or properties of any Chinachem Group member, or to identify, contact or bring legal action against any person who may be causing damage to or interference with the rights or properties of any Chinachem Group member (whether intentionally or otherwise), or when any other person could be harmed by such activities; 

q.  to enable actual or potential purchasers or assignees of any Chinachem Group member or its business and assets (or any part of them including any mortgage loans granted by the member), in each case to evaluate the purchase or assignment in question; and 

r.  to fulfill other purposes directly related to any of the above purpose or other purposes which you may agree from time to time. 

3.2  We will not knowingly or intentionally use, disclose, sell or rent the Data provided to us for purposes other than or that are unrelated to those set out above without your consent.



4.  Disclosure and Transfer of Data

4.1  CCG Hearts and CCG will keep the data confidential but may disclose or transfer the data to one or more of the following classes of persons from time to time for the purposes set in part 3 above: 

a.  any other Chinachem Group members in connection with the provision of services, products, facilities or privileges; 

b.  any agents, sub-agents, suppliers, contractors, sub-contractors or service providers (including their employees, directors, officers, agents and service providers) who provide services or support to CCG Hearts in connection with the sale or marketing of properties or with its business or operations in general. These services or support may include sales and marketing, data storage, data processing, administrative, telecommunications, or computer services. These agents, sub-agents, suppliers, contractors, sub-contractors or service providers may or may not be Chinachem Group members; 

c.  any person to whom any Chinachem Group member is under any obligation or requirement to disclose personal data in compliance with law, regulation or court order, or in response to lawful request by any governmental agency, regulatory authority, law enforcement agency, court or judicial body, or in case any Chinachem Group member believes in good faith that disclosure is necessary for (including but not limited to) protection of its rights or properties, or to identify, contact or bring legal action against any person who may be causing damage to or interference with its rights or properties (whether intentionally or otherwise), or when any other person could be harmed by such activities; 

d.  any person to whom any Chinachem Group member is required to disclose personal data by any policies and measures implemented by the Chinachem Group for prevention or detection of money laundering, terrorist financing or other unlawful activities; 

e.  any person who owes a duty of confidentiality to any Chinachem Group member, including accountants, auditors, legal advisers and other professional advisers; 

f.  any independent contractor or agent appointed by CCG Hearts or any Chinachem Group member to conduct assessment and investigation of your ability to perform your obligations and, where appropriate, your credit worthiness, financial status and repayment ability; 

g.  any debt collection agency, where you default in paying any amount or indebtedness; and 

h.  any actual or potential purchaser or assignee of any Chinachem Group member or its business and assets (or any part of them including any mortgage loans granted by the member). 

4.2  The Data may be transferred in or out of Hong Kong to any of the persons set out above. By providing the Data to any Chinachem Group member, you agree that Chinachem Group may transfer the Data outside Hong Kong. 

Where the Data is transferred outside Hong Kong, we will take reasonably practicable steps to ensure that the Data transferred outside Hong Kong is protected by standards in line with the requirements of the Ordinance, subject to any other requirements and limitations applicable in the relevant overseas jurisdiction.



5.  Data Retention 
 
The Data you provide to us will be kept by us only for as long as it is necessary to fulfill the purposes set out in part 3 above. The Data after which it will be destroyed in accordance with the Ordinance after the purposes have been fulfilled. 



6. Use of Cookies

In order to provide you with better user experience and customizable and personalized services on our websites, “cookies” may be created and saved on your computer. Cookies are small text files that are automatically created and stored on your web browser in your computer or other access device (e.g. a smart phone or tablet) which can be retrieved by our websites. Cookies will store information about your site preferences (e.g. if you inquire about rates and availability, the site might create a cookie that contains the details you entered), navigation pattern, your login name, etc and be used to track visits to our websites but will not collect or store any information by accessing the rest of your computer. For example, our websites cannot determine your name, address, telephone number or any similar information unless you choose to type it on any of our websites. Most web browsers automatically accept cookies, but if you prefer, you can at any time disable the cookies in your web browser. However, by disabling the cookies, you will be unable to use some of the features of our websites. 



7. Log Files 

We may also collect information regarding your IP address, browser type, domain name and access time ("Log Files"). Log Files are primarily used for our own research purposes and are kept separately from the Data. In certain circumstances permitted by the Ordinance, IP addresses may be used to assist in investigating, deterring and/or preventing abusive or criminal activity on our websites.



8. Our Commitment to Data Security

To maintain the accuracy of the Data, as well as preventing unauthorised access and ensuring the correct use of the Data, we have carried out appropriate measures to safeguard and secure the Data we collect. We use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Data. 

We install a firewall on our websites to protect the Data against unauthorised or accidental access. However, complete confidentiality and security is not possible over the Internet, and data privacy cannot be absolutely assured in your communications with us. You acknowledge and accept the risk of unauthorised or accidental access of the Data. This may result in, among others, you receiving unsolicited messages from other parties. We are not responsible in any manner for direct, indirect, special or consequential damages that you may incur or suffer caused by or arising from your communications with us. You are advised to take precautionary measures against unauthorised.



9.  Our Commitment to Children's Data Privacy 

We treat data privacy of children seriously. We will not knowingly collect personal data from persons who are under 14years of age without prior consent from a parent or guardian. If you are under 14 years of age, you should consult your parent or guardian before providing any personal data to us.



10. Other Websites 

10.1  Our websites may contain links to external third party websites ("external websites"). Your access to and use of an external website is at your own risk and subject to the terms and conditions, and privacy policies and practices applicable to the external website. 

10.2  All external websites are independent from our websites. Chinachem Group has no control over the external websites, their contents or the terms and conditions governing their use, or their privacy policies and practices. We do not give any warranty or representation for the quality or security of any external websites. You should therefore be fully aware that the provision of the link to an external website does not constitute an endorsement, approval, recommendation or any form of cooperation or association by or with any Chinachem Group member. You should therefore remain alert when you click on a link to leave any of our websites and enter an external website, and you should read the terms and conditions and privacy policies of that external website. 



11.  Use of the Data in Direct Marketing 

11.1  CCG Hearts & each Chinachem Group member that collects the Data intends to use the Data in direct marketing and that member requires your consent for this purpose. Please note the following: 

a.  Types of Data to be used

That Chinachem Group member may use the following types of Data that is held by it from time to time in direct marketing: 

i.  your name, address, telephone number, email address and other contact information (e.g., social media account); 

ii. pattern and behaviour relating to your use, purchase or consumption of services, products and facilities (including services and products portfolio information and spending habits); and 

iii.your demographic and social media profile data; 

b. Classes of services, products and subjects to be marketed

That CCG Hearts and CCG may market one or more of the following classes of services, products and subjects: 

i.  CCG Hearts’ offers, privileges, perks, Quest and other related programme news; 

ii.  CCG Hearts’ partnerships and other programme development; 

iii. CCG Hearts’ promotions with participated hotels, cinemas, malls, and other participated 3rd party merchants and partners;  

iv.  CCG real estate properties or property developments offered for sale and/or leasing by that member or any other Chinachem Group member singly or jointly with any other developer or person from time to time; 

v.  CCG mortgage loan and other credit facilities; 

vi.  hotel, conferencing facilities and services, restaurants, food and beverages, amenities and entertainment which under CCG portfolio;  

vii.  CCG donations or contributions for charitable or non-profit making purposes and related activities or events; and 

viii.  CCG healthcare and related products or services. 

c.  Providers of services, products and subjects to be marketed

The above services, products and subjects may be provided by one or more of the following classes of persons: 

i.  that Chinachem Group member; 

ii.  other Chinachem Group members; and 

iii.  Group Partners (and the names of these Group Partners can be found in the application form or information leaflet relating to the relevant services, products and subjects). Group Partners may include real estate developers, financial institutions, retail merchants, service providers, charitable bodies, healthcare product or service providers and non-profit making organisations. 

11.2  You always have ultimate choice and control over the type of information you would like to receive from us. When you use our online services or receive our promotional materials, you will have the chance to indicate your choice to receive, or not to receive in future, promotional materials from us. Should you decide not to receive any updates from us, feel free to cancel your subscription to these services by contacting us via the contact information provided on the websites or as indicated in the relevant materials. 



12.  How to Access or Correct Your Data or Contact Us 

12.1  You are entitled to ascertain whether we hold your Data, request access to your Data and correction of any of your Data which is inaccurate. If you wish to obtain a copy of any of your Data or to correct your Data, please issue a request in writing to our Data Protection Officer at crm@ccghearts.com or at the following address: 
 
CCG Hearts Data Protection Officer 
Chinachem Group (Attention to CRM Department) 
37th Floor, Nina Tower, 
8 Yeung Uk Road 
Hong Kong 

12.2  In accordance with the provisions of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request. 



13.  Access to Data Privacy Policy Statement 

13.1  You may access and obtain a copy of this notice, as amended from time to time from our websites, or from the address set out in part 12 above. 

13.2  Nothing in this notice shall limit your rights as a data subject under the Ordinance.  

This notice 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 notice, the English version shall prevail. 

Data Privacy and Security Policy Statement of Chinachem Group- Addendum
 
This Addendum (“Addendum”) is made for compliance with the Personal Information Protection Law of the People’s Republic of China, and shall form an integrate part of the Data Privacy and Security Policy Statement of CCG Hearts and the Chinachem Group (“Privacy Policy”). However, it shall apply only to people who resided in or who are in Mainland China and use the website, service or product of Chinachem Group ("we", "us" or "our"). In case of any discrepancy between any provision herein and any other provision in the Privacy Policy, the provision herein shall prevail.
 
Before providing your personal data to us, please ensure that you have carefully read this Addendum.

1. Collection, Disclosure, Sharing, Transfer and Publication of Personal Data

1.1 Collection of Sensitive Personal Information

The personal data that we may collect in order to provide the service or product you have purchased may contain your sensitive personal information, which means any personal information that once disclosed, provided illegally or misused, may endanger your personal or property safety and may extremely easily lead to any harm to your reputation or health in body and mind or any other discriminatory treatment. When it becomes necessary to collect any sensitive personal information from you, we will solicit your consent in advance.

1.2 Disclosure and Sharing of Personal Data

1.2.1 Except otherwise provided for in any applicable law or regulation or required by any competent regulatory authority, we will only disclose to or share with any third party your personal data, as necessary for the related service, in the circumstances set forth in Section 4 of the Privacy Policy. We will enter into a non-disclosure agreement with such third party, under which the third party should be required to process your personal data pursuant to the Privacy Policy and its Addendum and other related confidentiality and security measures. Such third party shall not be entitled to subject the personal data to any other purpose than specified in the Privacy Policy and its Addendum. We will solicit your consent by means of a written agreement or a pop-up window, pursuant to any applicable law or regulation or standard and with your explicit consent, will provide to or share with the third party your personal data.

1.2.2 If you need to know any company, organization or individual who is involved in the circumstances under the Privacy Policy, please send an email to crm@ccghearts.com, noting “Third-Party Data Inquiry” in the subject line, to which we will respond within 15working days of receiving the email.
 
1.3 Transfer of Personal Data

We will not transfer your personal data to any third party, unless:

1.3.1 Your prior explicit consent or authorization has been obtained.

1.3.2 It involves any merger, acquisition, or insolvency and liquidation proceedings, where, if the transfer of your personal information is involved, we will require that any succeeding third party that comes to hold your personal data continue to be bound by this Privacy Policy and its Addendum; otherwise, we will require that such third party resolicit your authorization or consent.
 
1.4 Public Disclosure

We will not disclose your personal data to the public, unless:

1.4.1 Your prior explicit consent has been obtained (for example, in any public event organized by us, we will not disclose to the public the personal data of the winner unless and until the explicit authorization and consent from the winner is obtained).

1.4.2 We do so pursuant to any mandatory requirement of any applicable law or regulation, legal proceeding or competent government authority.



2. Protection and Storage of Personal Data

2.1 Protection of Personal Data

2.1.1 We will protect your personal data in strict compliance with Section 8 of the Privacy Policy, and ensure that no personal data unrelated to the use of our service or product shall be collected. In the event of any personal data breach, we will promptly inform you of the breach and its possible consequence, the action we have taken or will take, and any action you may take, pursuant to the applicable law or regulation. We will promptly notify you by email, regular mail, telephone or push notification and if it is too difficult to reach all the owners of the personal data, we will make a public announcement in a reasonable and effective manner.



3. Your Rights

Pursuant to applicable laws, regulations and standards of the People’s Republic of China and any other national or regional practice, you may exercise the following rights to your personal data:
 
3.1 To access your personal data

You may do this by sending an email to crm@ccghearts.com, noting “Personal Information Inquiry” in the subject line. We will respond to your inquiry within 15 working days.
 
3.2 To correct your personal data

You may do this by sending an email to crm@ccghearts.com, noting “Personal Information Correction Request” in the subject line. We will respond to your correction request within 15 working days.
 
3.3 To delete your personal data

3.3.1 You may require that your personal data be deleted by contacting us in the way specified in Section 12 of the Privacy Policy, to which we will respond within 15working days to confirm your deletion request, if:

3.3.1.1 Our processing of your personal data violates any applicable law or regulation;

3.3.1.2 We have collected and used your personal data without first obtaining your consent;

3.3.1.3 Our processing of your personal data breaches any agreement with you;

3.3.1.4 You cease using our product or service, or cancel your member account with us (if applicable); or

3.3.1.5 We ceases providing you with product or service.

3.3.2 If we decide to respond to your deletion request, we will also inform any entity who receives your personal data from us to delete your personal data in timely manner, unless otherwise provided for in any applicable law or regulation or if such entity has independent authorization from you.

3.3.3 When your personal data is removed from our service system, we may not immediately delete the same from our backup system until the related backup is updated.
 
3.4 To change or withdraw the scope of your authorization

Different personal data may be required in order for us to provide certain service or product. You may change the scope of personal data you have agreed for us to use or process, or withdraw your authorization or consent, with respect to any service or product, by sending an email to crm@ccghearts.com. We will respond within 15working days to confirm your request. When you withdraw your consent, we will cease processing your personal data concerned and may be unable to continue to provide relevant service or product for you, which, however, will not affect any previous processing of your personal data on the basis of your consent.
 
3.5 To cancel your member account (if applicable)
You may require that your member account be canceled with our website, by contacting us in the way specified in Article 12 of the Privacy Policy, to which we will respond within 15working days to confirm your cancellation request. After your member account is canceled, we will cease providing the related service or product for you, stop collecting your personal data, and if you so request, delete your personal data under the member account, unless:

3.5.1 It is otherwise provided for in any applicable law or regulation;

3.5.2 Your member account cannot be canceled under the relevant requirements of the competent administrative, judicial or other authority; or

3.5.3 While using any of our service or product, you have seriously violated any law, regulation or contract and/or any policy or terms and conditions that we formulate for the service or product.
 
3.6 To obtain a copy of your personal data

You may request a copy of your personal data by contacting us in the way specified in Article 12 of the Privacy Policy, to which we will respond within 15working days. 
 
3.7 To restrict the Information System in automated decision-making

For certain services, we may make decisions solely on the basis of nonhuman automatic decision-making mechanisms, including the Information System or algorithms. If any of your legal rights or interests is significantly affected, you may require an explanation or refuse to accept our decisions made by the automated decision-making system, by contacting us in the way specified in Article 12 of the Privacy Policy, to which we will respond within 15working days.
 
3.8 To respond to your requests hereinabove

3.8.1 For security reasons, we may require that you should provide a written request or identify yourself in any other way. We may also require that your identification be verified before your request may be processed. We will respond to you within 15working days of receiving your request.

3.8.2 We will not charge you, in principle, if you have raised a reasonable request, but may ask you to pay for the cost, depending on the situation, if the same request has been raised for multiple times or the reasonable extent is exceeded. We may reject any request that is unreasonable and filed repeatedly, that require us to offer any technical means that we cannot reasonably offer (for example, to develop a new system or fundamentally change the existing practice), or that brings any risk to any legal right or interest of any other person, or that is too hard to be feasible (for example, to create a backup copy for the information stored on the magnetic tape). 

3.8.3 Also, if it is so required under any special provision of any applicable law or regulation, or pursuant to any legitimate requirement of any administrative, judicial or other competent authority, we may not be able to respond to your request.



4. Personal Data of Minors

4.1 If you are a minor under 14 years of age, you should obtain the written consent of your parent or guardian before using our service or product and providing your personal data, otherwise we may refuse to provide such services or product to you.
 
4.2 The personal data of a minor that we have collected with the consent of the parent or guardian will not be shared, transferred or disclosed publicly, unless it is allowed under the applicable law, the explicit consent of the parent or guardian is obtained or it is necessary to do so in order to protect the minor.
 
4.3 If we discover that we have collected the personal data of any minor without first obtaining the verifiable consent of the parent or statutory guardian, we will delete such personal data as soon as practicable pursuant to the applicable law.
 
4.4 If you are the guardian of a minor and you have any question regarding the personal data of the minor, please contact us in the way specified in Article 12 of the Privacy Policy.



5. Language

In case of any discrepancy between the English and Chinese version contained herein, the Chinese version shall prevail.