Effective date: 25/03/24
Last update: 25/03/24
INTRODUCTION
This Personal Data Privacy Notice (the “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 whole and in part, in the future will be posted on this page with or without prior notice so please check this page regularly. We will ensure that any changes posted without prior notice will adhere to the same purpose, scope, method and extent of processing already disclosed in this Privacy Notice; otherwise, the changes shall be with prior notice and retaking of your consent, where applicable.
For the purpose of applicable data protection laws, Wharf Hotels Management Limited is the data/personal information user or data/personal information 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 SAR, the Personal Information Protection Law of China and, where feasible, internationally recognised standards of personal data privacy protection.
OUR COMMITMENT TO PROTECT PERSONAL DATA PRIVACY
This Privacy Notice applies to personal data (defined as data, whether recorded in a material form or not, from which the identity of a living individual is apparent or a living individual is reasonably 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 Privacy 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 (“Wharf Hotels”). References to “Marco Polo Hotel”, “Niccolo Hotel”, “Maqo Hotel”, “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 Privacy 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 programme memberships or online profile,
(vi) Meeting for sales calls/appointments, attending of trade and road shows or requesting for proposals via our procurement team; or
(vii) Submitting job applications.
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. “Sensitive personal data” refers to personal information that once leaked or illegally used will easily lead to infringement of the human dignity and may harm personal or property safety of a natural person
We may collect the following kinds of personal data about you and the sensitive personal data involved is bolded for your attention:
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. You can inform us about the changes to your personal data by sending an email to communications@wharfhotels.com.
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 our hotels, dining restaurants and services you have viewed and reserved, and information about how you use our website and our Apps;
Technical Data - includes:
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.
HOW WE USE YOUR PERSONAL DATA
Below are the ways we will use your personal data to fulfil our contractual obligations to you, for our legitimate business interests, and/or where you have provided your consent to processing for specific purposes.
Please note that when we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
We may use your personal information to: | How do we use personal information for this purpose? | What is the legal basis for us processing your information in this way? |
Process your reservations and manage your booking at one of our hotels, including taking payment, responding to enquiries and requests and any after-sales services such as amendments or cancellations. | We will need to use your personal information (such as your name, email address, phone number and credit card details) to set up and manage your booking (for example by sending you reminders about upcoming hotel stays or processing payment for your booking). |
We need to process your information in this way in order to perform our contractual obligations to you in relation to your booking or other services. |
Manage and conduct our competitions and promotions, or to manage and analyse survey entries we receive from you, including post-stay experience surveys. | We will need to use your personal information (such as your name, email and phone number) to manage and process your entries to our competitions or promotions, and to inform you if you have won a prize. We will also use your information in order to process, manage and/or aggregate data from surveys. |
We will ask for your consent at the time at which you enter a competition/promotion, or provide responses to our surveys, before processing your information in this way. |
Process and administer your online and/or membership profile with Wharf Hotels and/or DISCOVERY programme provided you have signed up with us and consented to this. |
We will use your personal information (such as your email address or other contact details) to manage your online profile provided this is in line with your online preferences. | We will only process your information in this way if you have provided consent. |
Deliver direct marketing, advertising and updates to you to inform you about forthcoming offers, products, features and updates and information about us, and to make suggestions and recommendations to you about our goods or services that may interest you. | We will use your personal information (such as your email address or other contact details) to send you information and promotional material about Wharf Hotels, Marco Polo Hotels, Niccolo Hotels and/or Maqo Hotels provided this is in line with your marketing preferences. | We will only send marketing communications to you if you have expressly consented to receive direct marketing emails and/or pushed messages, telephone calls or SMS from us, whether via our website, Apps or in person at any of our hotels. There are certain types of promotional material that we will only send if you have specifically consented to this, for example if we send you promotional materials about products and services offered by third party organisations. |
Measure and analyse the effectiveness of advertising we serve to you. We will use your personal information to analyse our marketing practices to ensure that we can provide you with a more personalised marketing experience. | We will analyse information on your recent visits to our site (such as [browsing patterns]) and your past purchases to measure and understand the effectiveness of any advertising we may serve to you and others. | It is in our legitimate business interests to track the effectiveness of our marketing and online advertising practices. |
Administer, analyse and assess the performance and usability of our website and Apps. | We use technical information about your visits to our website and Apps, and information about your behaviour on our website (such as the services you have searched for and the length of time spent browsing) to improve our website and Apps. | It is in our legitimate interests to administer, analyse and assess our website and Apps to ensure that they are functioning properly, and to enhance our users' experience. |
Comply with legal requirements. | We may sometimes need to process personal information to comply with legal requirements to which we are subject (for example tax or financial reporting requirements). | It is in our legitimate interests to process personal information for the purposes of complying with legal requirements to which we are subject. |
Protect and secure our website and Apps against cyber crime including fraudulent transactions. | We may need to process your personal information (including financial information) in order to protect and secure our website and Apps, including to keep your payments secure, and to protect against fraudulent transactions. | It is in our legitimate interests to process personal information to keep our customers' payments secure and comply with legal requirements aimed towards preventing cybercrimes, including fraudulent transactions. |
Where you have consented to this, we may publish customers' reviews and feedback in the testimonial section of our website, which were received via email, social media, online travel review platforms or the Wharf Hotels guest comment card. | We will use your personal information when publishing your customer review, in accordance with your preferences (e.g., via a pseudonym or fully-anonymised), which enables us to be honest and transparent with our customers regarding the nature and quality of our services. | We will ask for your consent before processing your information in this way. |
WHO WE SHARE YOUR PERSONAL DATA WITH
Name | Address/ Contact detail | Purpose | Types of Personal Information Involved |
https://support.google.com/analytics/gethelp?sjid=14960462493936554563-AP | To measure user interaction |
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Triptease | Email: data-privacy@triptease.com | To retarget ads based on Triptease’s algorithms |
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Brightcove | Email: privacy@brightcove.com Tel: +1 617 500 4947 Address: Brightcove Inc. Attn: Privacy Team 281 Summer Street Boston, MA 02210 |
The Brightcove Services give our Customers the flexibility to choose the type of personal information Brightcove will collect on its behalf. Such information may include personal information. |
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Cookie Name | Type | Description | Expiry Duration | Expiry Unit |
ab_bid | Third Party | This cookie is set by Baidu. The company provides advertising technology and services. | 68 | Years |
ab_jid | Third Party | This cookie is set by Baidu. The company provides advertising technology and services. | 68 | Years |
BMAP_SECKEY | First Party | This cookie is set by Baidu. The company provides advertising technology and services. | 1 | Month |
OptanonAlertBoxClosed | First Party | This cookie is set by websites using certain versions of the cookie law compliance solution from OneTrust. It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a one year lifespan and contains no personal information. | 1 | Year |
OptanonConsent | First Party | This cookie is set by the cookie compliance solution from OneTrust. It stores information about the categories of cookies the site uses and whether visitors have given or withdrawn consent for the use of each category. This enables site owners to prevent cookies in each category from being set in the users browser, when consent is not given. The cookie has a normal lifespan of one year, so that returning visitors to the site will have their preferences remembered. It contains no information that can identify the site visitor. | 1 | Year |
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.
Cookie Name | Type | Description | Expiry Duration | Expiry Unit |
OptanonAlertBoxClosed | First Party | This cookie is set by websites using certain versions of the cookie law compliance solution from OneTrust. It is set after visitors have seen a cookie information notice and in some cases only when they actively close the notice down. It enables the website not to show the message more than once to a user. The cookie has a one year lifespan and contains no personal information. | session | session |
SECKEY_ABVK | First Party | Ensures the functionality, operation and login to internal tools such as CMS, internal gateways and portals. | session | session |
c) Performance cookies
Performance cookies help us 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 analyse 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/anonymise 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 in the website. That 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.
Cookie Name | Type | Description | Expiry Duration | Expiry Unit |
_ga | First Party | This cookie name is associated with Google Universal Analytics - which is a significant update to Google's more commonly used analytics service. This cookie is used to distinguish unique users by assigning a randomly generated number as a client identifier. It is included in each page request in a site and used to calculate visitor, session and campaign data for the sites analytics reports. By default it is set to expire after 2 years, although this is customisable by website owners.To generate statistical data on how the visitor uses the Service | 1 | Year |
_ga_xxxxxxxxxx | First Party | To generate statistical data on how the visitor uses the Service | 1 | Year |
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.
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.
We also use or may use the following advertising cookies:
Cookie Name | Type | Description | Expiry Duration | Expiry Unit |
__sharethis_cookie_test__ | First Party | Tracks which pages are being shared and by whom | session | session |
__stid | Third Party | Randomly generated unique identifier - used for interest profiling for advertising | 1 | Year |
__stidv | Third Party | This domain is owned by Share This. The main business activity is: ShareThis provides web widgets that site owners embed into their pages or other content, to enable visitors to create and share links to the content across social networks. They also make use of the data collected to provide advertisers and marketers with profile information for targeted, behavioural advertising. | 1 | Year |
ab_sr | Third Party | This domain is owned by Baidu. The company provides advertising technology and services. | session | session |
BAIDUID | Third Party | This domain is owned by Baidu. The company provides advertising technology and services. | 1 | Year |
fpestid | First Party | Fpestid is a ShareThis cookie ID set in the domain of the website operator. | 1 | Year |
pxcelBcnLcy | Third Party | This domain is owned by Share This. The main business activity is: ShareThis provides web widgets that site owners embed into their pages or other content, to enable visitors to create and share links to the content across social networks. They also make use of the data collected to provide advertisers and marketers with profile information for targeted, behavioural advertising. | session | session |
pxcelPage_default_c010_B | Third Party | This domain is owned by Share This. The main business activity is: ShareThis provides web widgets that site owners embed into their pages or other content, to enable visitors to create and share links to the content across social networks. They also make use of the data collected to provide advertisers and marketers with profile information for targeted, behavioural advertising. | 1 | Month |
sa-user-id | Third Party | These third party advertising / targeting cookies record information about your website activity, such as the pages you’ve visited and the locations you’ve viewed to enable us to provide you with interest based content and personalised adverts on external websites. | 1 | Year |
sa-user-id-v2 | Third Party | These third party advertising / targeting cookies record information about your website activity, such as the pages you’ve visited and the locations you’ve viewed to enable us to provide you with interest based content and personalised adverts on external websites. | 1 | Year |
sa-user-id-v3 | Third Party | Third-party advertising/targeting cookies that track your website activity — such as the pages you’ve visited and the locations you’ve viewed — so we can suggest personalized content and adverts on external websites. | 1 | Year |
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., customised 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.