Personal Information Collection Statement
This Personal Information Collection Statement (this “Statement”) is made by Discovery Park Commercial Services Limited (“DPCSL”, “we”, “us”, or “our”), and applies between us and you (“you”, or “your”). This Statement should be read together with the Terms and Conditions (if any) of any mobile applications (including without limitation the “D·PARK” mobile application, the modular page for DP Club in K11 HK mobile application, digital wallets, and/or other device(s) or application(s) (whether developed by us and/or our Affiliates) that may be introduced and used from time to time in connection with our management and operation of DP Club, (the “Application”) our official website at https://www.dpark.com.hk/en (the “Website”) (the “Terms and Conditions”), provided that, in the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data that are handled by us, this Statement shall prevail.
DPCSL is part of the New World group of companies including New World Development Company Limited (“NWD”) and its affiliated or related companies from time to time (as listed here: https://www.nwd.com.hk/pics) (the “New World Group”, or “NWG”) whose activities include real estate (sale, leasing and investment), mortgage services, retail, property management, facilities management, activity planning and management, infrastructure, shopping malls, loyalty programmes, department stores, jewelleries and luxury products, e-commerce, hospitality services, food and beverages, convention and exhibition centres, sports and recreational facilities, education, health care and senior care, other health and wellness products and services, financial services and insurance, transportation, sustainability programmes and products, TMT (Technology, Media and Telecom), corporate innovation, accelerator and incubation programmes, organization of competitions, conferences and events, start up and social innovation programmes and charitable pursuits including sports, recreation, art and cultural programmes, relief of poverty, advancement of education, advancement of religion, and other purposes that are beneficial to the community (the “Goods and Services”) (the New World Group and joint venture companies together referred to as “Affiliates”).
In order to enable us to perform the Purposes (as defined in the “Purposes for using personal data collected” section below), you are required to provide all the requested/mandatory personal data in the application form for DP Club membership and/or other relevant forms or documents that we may use in connection with our management, administration and operation of DP Club, any DP Club-related pages of the Application and/or Website, your DP Club membership and applicable reward campaigns (as the case may be). If you do not provide the required personal data, then we may not be able to perform the Purposes and/or provide the relevant Goods and Services to you.
Kinds of personal data collected
For the avoidance of doubt, if/where applicable, we will indicate which kind of personal data is mandatory or optional for you to provide at the relevant time of data collection, e.g. when you register your membership account(s) with the relevant club(s)/loyalty programme(s) operated by us.
We do not collect any personal data of any minors (i.e. data subjects under the age of 18).
Purposes for using personal data collected
The personal data to be collected from you and/or from other sources as mentioned below in this Statement will be used and retained by us (and/or our Affiliates and/or our Marketing Partners as defined in the “Direct Marketing” section below, as applicable) for the following purposes (as may be applicable from time to time) (together, the “Purposes”):
AI Engine and AI Use-Cases
We and/or our Affiliates will also develop or procure, train and use artificial intelligence (AI) systems and related technologies (“AI Engine”) for the business operations for or relating to the relevant clubs/loyalty programmes managed or operated by us and/or Our Affiliates (as the case may be).
To develop, train, calibrate or otherwise improve the AI Engine, we will anonymize your personal data as aggregate anonymous data to train the AI Engine. Otherwise, subject to your opt-in to the personalized recommendation feature on the Application, we will use your relevant personal data that you have supplied to us and/or our Affiliates (including but not limited to gender, age group, nationality, marital status, family status, membership tiers, interest tags, purchasing history and/or browsing data) for the purposes of (a) providing you with customized/personalized recommendations and more relevant content, advertisements and/or direct marketing (subject to your consent, see the below section entitled “Direct Marketing” for more details), (b) facilitating precision marketing, lead generation and enhance conversion with tailored and personalized recommendations, and (c) facilitating and enhancing your user experience under or across your various account(s) and/or designated club(s)/loyalty programme(s)’ website(s), app(s) and/or app platform(s) managed or operated by us and/or our relevant Affiliates (as the case may be) (“AI Use-Cases”). If/where applicable, likewise subject to your opt-in to the personalized recommendation feature on the Application, we may transfer your personal data and/or analytics data generated from or relating to the deployment of the AI Engine to our relevant Affiliates for their use for the aforesaid AI Use-Cases for or in connection with the management and operation of their club(s)/loyalty programme(s) of which you may also be a member of. For the avoidance of doubt, your interaction and/or transactions with the AI Engine’s recommended content, advertisements and/or direct marketing (if you have so consented) will be tracked, which will enable us and/or our relevant Affiliates (as the case may be) to learn more from your preferences, interests and behaviour, and thus further improving the relevant personalized recommendations and suggestions to provide you with more tailored content, advertisements and/or direct marketing.
You may, at any time and without charge, opt-out from the AI Use-Cases by toggling to disable the personalized recommendation feature on the Application. For the avoidance of doubt, your choice to disable such feature will only constitute as your opt-out from the AI Use-Cases, but does not further extend to constitute as your opt-out from direct marketing generally (i.e. direct marketing conducted without involvement or deployment of the AI Engine). Further, if you would like us to correct any inaccurate personal data processed by the AI Engine, you can make a request to our Personal Data Privacy Officer - please refer to “Your rights” section below for the relevant contact details. Once such request has been received, the AI Engine will automatically conduct the corresponding update, and thus the personalised recommendation feature on the Applications will also be updated accordingly. If and where necessary, we and/or our relevant Affiliates may from time to time implement the relevant technical measures to re-calibrate the AI Engine with a view to minimize potential errors and/or improper decision-making.
Those with whom we share personal data
We may engage agents, contractors, suppliers and service providers (whether within or outside the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”)) in connection with the Purposes and/or the provision of the Goods and Services, including but not limited to, e.g. IT/software solutions/technology services providers, marketing agents, social media, research companies, customer support outsourcing or customer relationship management service providers, credit card and electronic/digital payment companies, banks, and service providers of development and maintenance, administrative, data processing, digital storage, or other similar services, and may transfer to or share your personal data with them for the Purposes within or outside Hong Kong. We may also share your personal data (subject to your consent, if/where applicable) with our Affiliates, our Marketing Partners (see below) and the social media platforms that we and/or our Affiliates/our Marketing Partners (see below) use for such Purposes. Where we are required by the law of any country or place or requested by any court, regulatory body or governmental body of any country or place, we may also disclose your personal data as required. In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our Affiliates or our Affiliates' businesses, your personal data may be transferred to the new entity as part of the transaction, provided that the new entity abides by this Statement and continues to exercise the same level of care, in respect of your personal data, as we would. You will be notified of such event and you may decide to withdraw your consent to the use of your personal data.
Your personal data may be stored by us in physical locations and/or servers located within or outside Hong Kong and/or shared with our Affiliates and/or our Marketing Partners (see below) located within or outside Hong Kong. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the country or place in which it is stored, and we procure by contract or use our reasonable endeavours to ensure that our Affiliates and our Marketing Partners (see below) do the same.
Subject to your consent, we may use your personal data to send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, email, telephone, text message, or other media whether now known or available in the future.
Subject to your consent, we may also use your personal data for, or provide your personal data to, our Affiliates and/or our Marketing Partners (see below) so that they may send you direct marketing (including, but not limited to, special offers, news, information and marketing) about us, our Affiliates and/or our Marketing Partners (see below) in relation to the Marketing Subjects (see below) whether by in-app messages and/or notifications and/or push notifications to your mobile device, post, email, telephone, text message, and/or other media whether now known or available in the future.
Our “Marketing Partners” include property developers, banks, financial and investment institutions, credit card and electronic/digital payment companies, insurance companies, private clubs, concierge and customer service providers, retail outlets and online businesses (for various products and services including but not limited to fashion and beauty, accessories, hair dressing and grooming, health and personal cares, luxury, home and living, food, wine and beverage, electronics, books and stationery, cigarettes and cigars, baby and children, veterinary and pet care, outdoor equipment), shopping malls, loyalty programmes, department stores, watches and jewellers (such as Chow Tai Fook Jewellery Group Limited), hotel chains, restaurants and lounges, catering services providers, healthcare and senior care, services and/or products providers including but not limited to body care, medical/pharmaceutical, health and wellness, art and culture, advertising and marketing, consultancy, gallery and exhibition, event management, green and nature, sports and recreation, travel and accommodation, leisure and entertainment, housekeeping, agriculture, installation and repair, engineering, architectural, transportation and logistics, telecommunication, media and information technology, business management, corporate innovation, accelerator and incubation programmes, competitions, conferences and events, legal, charities, education, pre-school, primary, secondary and/or tertiary education institutions. Without prejudice to the generality of the foregoing descriptions, our Marketing Partners may include Other Participating Companies that we may collaborate with from time to time and/or Other Participating Companies of our Affiliates of which you are also a member of their relevant club(s)/loyalty programme(s).
As we may share your personal data with our Affiliates and/or our Marketing Partners, we may also receive your personal data from them. Subject to your consent given to our Affiliates and/or our Marketing Partners, we may also use such personal data to send you direct marketing about us, our Affiliates and/or our Marketing Partners in relation to the Marketing Subjects (see below).
The types of products, services, events and charitable initiatives that we, our Affiliates and/or our Marketing Partners may market to you include the following (together, the “Marketing Subjects”):
If you have enabled the personalized recommendation feature on the Application, your personal data will also be handled for the AI Use-Cases in the manner as stated above.
We cannot use or provide your personal data for direct marketing purposes and/or provide your personal data to third parties (whether to our Affiliates and/or our Marketing Partners) for their direct marketing purposes unless you consent. Even if you give your consent, you can opt out of direct marketing - at any time (or you may request that we cease to provide your personal data to third parties, at which point we will cease to do so), free of charge, by writing to our Personal Data Privacy Officer at 4th Floor, Tsim Sha Tsui Centre, 66 Mody Road, Tsim Sha Tsui East, Kowloon, Hong Kong (marked Confidential).
Apart from your right to opt out of direct marketing as mentioned above, you have the following additional rights to:
If you would like to make a request in relation to the above (or make any general enquiries), please contact our Personal Data Privacy Officer at 4th Floor, Tsim Sha Tsui Centre, 66 Mody Road, Tsim Sha Tsui East, Kowloon, Hong Kong (marked Confidential). In accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “PDPO”), we have the right to charge you a reasonable fee for the processing of any personal data access request.
Inconsistency or conflict
If there is any inconsistency or conflict between the English and Chinese version of this Statement, the English version shall prevail.
This Statement may be updated from time to time to reflect changes to our policy with respect to personal data protection and/or changes to personal data/data privacy laws and regulations. Where there are significant changes, we will notify you and obtain your acceptance of the changes, consents, and/or opt in (as necessary or applicable). If you do not accept the changes and/or provide your consent, then we may not be able to perform the Purposes and/or provide goods or services to you. You are advised to check the Application and/or the Website (as the case may be) for updates to this Statement on a regular basis.
Nothing in this Statement shall limit your rights under the PDPO.
If you are:
This Statement shall be governed by, and construed in accordance with, the laws of Hong Kong.
Version Date: 28 Nov 2023