PERSONAL DATA PRIVACY POLICY
 
Introduction
 
Marco Polo Hotels Management Limited and its hotels respect the privacy of all our customers and business partners, and treats all personal information as confidential.  We pledge to fully comply with the requirements of 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 Policy (the “Policy”) applies to personal data and information regarding guests and 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 Policy gives effect to our commitment to protect your personal information and has been adopted by all the hotel properties owned, managed and/or operated by Marco Polo Hotels Management Limited or its affiliated or associated companies. References to “Marco Polo Hotels”, “we”, “our” and “us” hereinafter, depending on the context, collectively refer to those separate and distinct properties or entities.
 
Collection of Personal Information
 
The term “personal data” in this Policy refers to personal information which we, in the process of providing you with a particular service, may ask you to voluntarily 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)  Purchasing our products or services,
(iii) Registering for programme memberships,
(iv)  Meeting for sales calls/appointments, attending of trade and road shows or requesting for proposals
(v)   Submitting job applications and
(vi)  Facilitating communications.
 
Types of Personal Information We Collect
 
The types of personal data that we collect may include:
 
name, title, gender, contact details (including but not limited to email address, mailing address, mobile phone number, telephone number and fax number etc.); date and place of birth, nationality, passport number, identification number and visa information; credit card information including name of cardholder, credit card number and expiry date; Discovery programme (loyalty programme of Global Hotel Alliance) membership 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 on hotel arrangement; information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers; information collected through the use of closed circuit television systems, card key and other security systems; contact and other relevant details concerning the employees of corporate accounts and vendors and other individuals with whom we do business (e.g., travel agents or meeting and event planners); and in limited cases, 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:
 
provide, manage and administer our products and services; administrate loyalty programmes such as and not limited to the Discovery programme, Marco Polo Rewards (MPR) and Marco Polo Dining Experience (MPDE); provide you with customer service and respond to your requests;
enable us to operate our business efficiently and sustainably; improve marketing and promotional efforts and product and service offerings; provide you with information, materials and newsletters relating to Marco Polo Hotels, Niccolo By Marco Polo and its affiliated hotels products and services; conduct market research, customer satisfaction and quality assurance surveys; provide for the safety and security of staff, guests and other visitors; process credit applications.
 
If you do not wish us to use your data mentioned above, you may exercise your opt-out right by writing to the Marketing Office at: Marco Polo Hotels Management Limited, 5/F., Marco Polo Hongkong Hotel, Harbour City, 3 Canton Road, Tsim Sha Tsui or at corporate@marcopolohotels.com.
 
Direct Marketing
 
We will not use your personal data for direct marketing or transfer your personal data and information (whether within or outside Hong Kong) to any third parties for direct marketing purpose without obtaining your consent.
 
Processing of Personal Information
 
We may transfer your personal information outside of the country in which it was collected (including to countries where we have hotels under development or operation).  For example, if you make a reservation and/or stay at a Marco Polo hotel, Niccolo hotel outside of Hong Kong, the personal data and information gathered in that process may be transferred to and processed in Hong Kong or other jurisdictions.  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 Marco Polo Hotels, Niccolo By Marco Polo your personal data will be processed in accordance with the terms and conditions of this Policy.
 
Disclosure 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 Marco Polo Hotels or its affiliated hotels, travel-related companies and business partners who provide services to Marco Polo Hotels, Niccolo by Marco Polo for the uses provided under “How we Use Personal Information”.  The recipients of any such data are under obligation to protect your personal information.
 
We reserve the right to disclose any personal data or information to comply with the law, or accounting and tax rules and regulations, or to protect or defend our rights or properties.
 
We also reserve the right to use any information in emergency situations and informing your immediate family members of the situation.
 
The personal data which we collect will not be sold to any third party at any time.
 
Your Privacy Online
 
Visitors to our website should be aware that information and data may be automatically collected through the standard operation of our internet servers and through the use of "cookies". For our online privacy statement on the use of cookies, please refer to Policy on “Cookies” below.
 
How to Access or Correct Your Personal Information
 
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 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 corporate@marcopolohotels.com.
 
We reserve the right to charge a reasonable fee for the processing of any such access 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 indicate your full name, address and telephone number so we can ascertain your identity, and specify clearly the type of enquiry and the original source of data collection.
 
Changes to the Policy
 
Marco Polo Hotels Management Limited reserves full rights to amend or update this Policy unilaterally from time to time as it sees fit. Any changes to this Policy will be posted to our website so that you are always informed of the way we collect and use your personal data.  Updated versions of our Policy will include the date of the version at the end of this Policy so that you are able to check when the Policy was last emended.
 
Any changes to our Policy will become effective upon posting of the revised Policy on the website. Use of the website following such changes constitutes your acceptance of the revised Policy then in effect.
 
Miscellaneous
 
This Policy is governed by and shall be construed in accordance with the laws of Hong Kong Special Administrative Region.
 
This Policy is written in English. In the event of any inconsistency between the English version and any translated version of this Policy, the English version shall prevail.
 
Effective date: May 2013
 
Policy on "Cookies"
 
Visitors to our website should be aware that information and data may be automatically collected through the standard operation of our internet servers and through the use of "cookies".
 
"Cookies" are small text files a web site can use to recognise repeat users, facilitate the user's ongoing access to and use of the site and allow a site to track usage behaviour and compile aggregate data that will allow content improvements and targeted advertising. 
 
Cookies are not programmes that come onto a system and damage files.  Generally, cookies work by assigning a unique number to each customer / visitor that has no meaning outside the assigning site.  Cookies cannot be used by themselves to identify you. 
 
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.
 
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.    You may opt out of this ad serving on Google’s opt out page HERE