Introduction
Shangri-La International Hotel
Management Limited ("Shangri-La") respects the privacy of all its
customers and business partners, and treats personal information provided by
you as confidential. The information we gather is processed and stored in Hong
Kong. We pledge to meet fully in complying with the requirement of the Personal
Data (Privacy) Ordinance of Hong Kong and, where possible, internationally
recognised standards of personal data privacy protection. We use your personal
data and information in order to fulfill our commitment to providing you with
distinctive Asian standards of hospitality service.
The
Application of this Policy
This Privacy Policy (the
"Policy") applies to personal data and information regarding guests
and other individuals with whom we do business and to the management of that
data and information in any form, whether electronic or written.
This Policy gives effect to our
commitment to protect your information and has been adopted by all of the hotel
and resort properties owned, managed and/or operated by Shangri-La or its
affiliated or associated companies. References to "Shangri-La",
"we", "our" and "us" hereinafter, depending on
the context, collectively refer to those separate and distinct properties or
entities.
Types
of Personal Information We Collect
The term "personal data"
in this Policy refers to personal information which is capable of identifying
you as an individual. You can visit our website without providing any personal
data or information. When we need to collect personal data from you to provide
you with a particular service, we will ask you to voluntarily supply us with
the information we need. We may also ask for personal data to verify your
identity and to protect confidentiality of your information when you contact
our Customer Service Centre.
The types of personal data that we
process (which may vary by jurisdiction based on applicable law) include:
- your
personal details, passport and visa information;
- guest
stay information, including [the hotels where you have stayed, date of arrival
and departure, goods and services purchased, special requests made,
observations about your service preferences, telephone numbers dialled and
faxes and telephone messages received];
- your
credit card details, Golden Circle Programme ("GC") Member
information, online user account details, profile or password details and any
frequent flyer or travel partner programme affiliation;
- any
information necessary to fulfill special requests (for example, leisure, travel
and guest preferences);
- information
collected through the use of closed circuit television systems and other security
systems; and
- information
relating to the credit of customers.
How
We Use Personal Information
We may use and disclose relevant
portions of your personal data and information in order to:
- in
the case of GC applicants and Members, process your application and administer
your GC Membership;
- process
and/or confirm hotel arrangements;
- provide
and charge for the hotel accommodations and other goods and services you
purchase;
- provide
privileges, benefits and services to you and for GC Members, rally and arrange
for the same to be provided by any Participating Hotels, Airline Partners and
Partners of GC;
- provide
you with a better, more personalized level of service;
- fulfill
contractual obligations to you, anyone involved in the process of making your
travel arrangements (e.g. travel agents, group travel organisers and your
employer) and vendors (e.g. credit card companies, airline operators and other
loyalty programmes);
- conduct
market analysis, market research, customer satisfaction and quality assurance
surveys, direct marketing and sales promotions;
- respond
to requests for information and services;
- provide
for the safety and security of guests;
- administer
general record keeping;
- facilitate
marketing, promotional and customer management purposes, including sending you
sales promotional communications or special offers;
- matching
for whatever purpose with other personal data;
- disclosing
the winner of contests and lucky draw competitions conducted by us or on our
behalf; and
- meet
legal and regulatory requirements.
Disclosures
of Your Personal Information
From time to time, we may disclose
and transfer your personal data and information (whether within or outside of
Hong Kong) to Shangri-La Group of hotels and resorts, travel-related companies
(for example, airline companies, car rental companies and excursion tour
companies), partners of GC, trusted service providers who provides
administrative, telecommunications, computer or payment services to any of the
Shangri-La Group of hotels and resorts, fulfillment houses, mail houses and
contractors for limited purposes, including fulfilling customer reservations;
offering certain products and services to you, facilitating communication of
news and information about such services and products and completing credit
card transactions. Such disclosees are contractually prohibited from using
personal data and information for any purpose other than for the purpose
Shangri-La specifies.
We reserve the right to disclose any
personal data and information we have concerning you if we are compelled to do
so by a court of law or requested to do so by a governmental entity or if we
determine it is necessary or desirable to comply with the law or to protect or
defend our rights or property. We also reserve the right to retain information
collected and to process such information to comply with accounting and tax
rules and regulations.
Except as described herein, we do
not permit the sale or transfer of personally identifiable information to
entities outside of the Shangri-La group of companies and hotels.
Centralised
Data Processing
Like most international businesses,
we have centralised certain aspects of our data processing activities, which in
many instances will result in the transfer of your personal information from
one country to another. For example, if you make a reservation and/or stay at a
Shangri-La hotel or resort outside of the Hong Kong, the personal data and
information gathered in that process will be transferred to and processed in
Hong Kong. The jurisdictions where those data and information will be processed
may or may not have laws that seek to preserve the privacy of personal data.
Nevertheless, whenever your personal data is transferred within the Shangri-La
Group, your personal data will be processed in accordance with the terms and
conditions of this Policy.
Cookies
To enhance your experience on our
website, some of our web pages may use "cookies". Cookies are text
files that we place in your computer's browser to store your preferences.
Cookies, by themselves, do not tell us your email address or other
personally-identifiable information unless you choose to provide such
information to us by, for example, registering for one of our services.
However, once you choose to furnish the site with your personally-identifiable
information, this information may be linked to the data stored in the cookie.
We use cookies to understand site
usage and to improve the content and offerings on our sites. For example, we
may use cookies to personalize your experience on our web pages (e.g. to
recognise you by name when you return to our site), save your username and/or
password in password-protected areas, and to offer you products, programmes, or
services.
Our
Commitment to Data Security
To maintain the accuracy of your
personal data, as well as preventing unauthorised access to and ensuring the
correct use of your personal data, we have carried out appropriate physical,
electronic and managerial measures to safeguard and secure the personal data we
collect. Nevertheless, such security measures cannot prevent all loss, misuse
or alternation of personal data and information and we are not responsible for
any damages or liabilities relating to any such incidents.
Minor
Children
Our website do not sell products or
services for purchase by children. If you are under the age of 18, you may only
use our website with the involvement of a parent or guardian.
Choice
You may always choose what personal
data and information (if any) you wish to provide to us. However, if you choose
not to provide certain details, some of your experiences with us may be
affected (for example, we cannot take a reservation without a name).
If you provide us with your contact
details (e.g. postal address, email address, telephone number, fax number), we
may contact you to let you know about the products, services, promotions and
events offered that we think you may be interested in. We may also share your
personal information with carefully selected reputable third parties in the
travel-related industry and with whom Shangri-La has a strategic marketing
relationship because they offer products or services that we believe would be
of interest to you, who may communicate directly with you. You can always
choose whether to receive any or all of these communications by contacting us
as described in "How to Access or Correct Your Data" Section below or
following the "unsubscribe" instructions contained in the
communications.
If you are a Golden Circle Member,
we ask you to indicate your communication preferences at the time you apply for
Membership or when you create your user profile. We may also ask you to
indicate how you would like to receive any offers, marketing and promotional
information (e.g. via email, regular mail) and whether you would be willing to
participate in surveys. Once you have indicated your preferences, you can
always change your mind. You can amend your choices in the Profile Update pages
after logging into the Members Area or you may contact Golden Circle Member
Services via email golden.circle@shangri-la.com to unsubscribe to
such communications.
We will abide by any request from
you not to send you direct marketing materials. When such a request is
received, your contact details will be “suppressed” rather than deleted. This
will ensure that your request is recorded and retained unless you provide a
later consent that overrides it.
How
to Access or Correct Your Data
You are entitled to access and make
changes to any personal data relating to your profile held in our database. You
should update the personal data held by us whenever there is a change. If you
have any questions about this Policy, or if you would like to submit a request
for access to or change of the personal data and information that we maintain
about you, please contact Golden Circle Member Services by sending an email
to: golden.circle@shangri-la.com;
or via fax to: (852) 2331 6603. You can also write to us at the following
address: Golden Circle Member Services, c/o Kowloon Shangri-La, Hong Kong, 64
Mody Road, Tsim Sha Tsui East, Kowloon, Hong Kong. We reserve the right to
charge a reasonable fee for the processing of any such request. As indicated
above, all requests for access to your personal information must be submitted
in writing. When communicating your request, please be sure to include your
full name, address and telephone number so we can ascertain your identity, and
specify clearly the type of enquiry. For Golden Circle Members, for privacy and
personal data security reasons, your Golden Circle Membership number, email
address and password are required to gain access or make changes to your
personal profile.
Changes
to the Policy
Just as our business changes
constantly, this Policy may also change. To assist you, this Policy is dated at
the end of this document.
For Golden Circle Members, we will
post on our website at www.goldencircle.shangri-la.com any changes to
this Policy so that you are always informed of the way we collect and use the
personal data.
Miscellaneous
This Policy is written in 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
Policy, the English version shall prevail.
