Grand Emperor Hotel Privacy Policy Commitment

Introduction and the application of this Policy This Privacy Statement (“Statement”) describes how we and our affiliated, subsidiaries, and associated companies (collectively "the Group", "we", "us" or "our") collect, use, and disclose your personal information in connection with any website, application, or other services that refer to or link to the Statement (collectively, our “Services”). Please read the Statement carefully before you use our Services. 1. Age Restriction It is illegal in Macau for people under 16 years of age, mentally incapacitated, deprived or to be deprived of their rights to manage their properties by legal orders, or those who are prohibited to enter into and stay inside gaming premises by legal orders, court verdicts or executive orders to enter into and stay inside gaming premises. Grant Emperor Hotel website www.grandemperor.com (hereinafter referred to as "This website") may contain information about gaming premises. If you belong to any of the above described groups, please leave this website immediately. 2. Intellectual Property Rights Contents of this website, including but not limited to text, article, graphic, photograph and trade mark are protected by Grand Emperor Hotel or other related parties under copyrights, trade mark and / or other intellectual property rights. It is not allowed to write down, copy, transmit, backup, modify, change, publicly display or distribute the website's contents completely or partially for any purpose without prior written agreement from us or the involved third parties. 3. Protecting your privacy We are dedicated to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) and other relevant regulations where applicable. Before using and providing your Data for the purposes as set out in this Privacy Policy Statement, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use your Data in the manner as specified. If you are a minor or under 16 years old or a person who are mentally incapable, you must obtain express consent from your parents or guardian before providing any personal data to us. If you do not accept the following terms of this policy, please stop accessing, browsing or using this website/our e-services. 4. Type of Personal Information we collect Grand Emperor Hotel collects personal information from customers through several means. The term “Personal Information” in this Policy refers to information which does or is capable of identifying you as an individual. Types of Personal Information Grand Emperor Hotel collect include: (a) Your name, gender, home and work contact details, business title, date and place of birth, nationality, Hong Kong Identity card, passport and visa information; (b) Telephone numbers dialed, faxes sent/received or receipt of telephone messages when connected to the telephone services we may provide guests during their stay; (c) 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 (including room, holiday preferences, amenities requested, facilities or any other services used); (d) Your credit card details, online user accounts details, profile or password details and any frequent flyer or travel partner program affiliation; (e) Any information necessary to fulfill special requests (e.g. health conditions and preference that require specific accommodations, purchase of goods and services); (f) Information you provide regarding your marketing preferences or in the course of participating in surveys, contests or promotional offers; (g) Information collected through the use of closed circuit television systems, card key and other security systems; (h) 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). Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents, airlines or similar providers). For example, if we know your name and postal address, we may request your email address from your travel agent. Occasionally, you may be requested to provide personal information about others to us (for example, individuals for whom you are making a reservation). In such cases, we rely on you to obtain such other persons' consent for disclosing their information to us which we will use in accordance with the terms of this Policy. You may always choose what personal information (if any) you wish to provide to us. If you choose not to provide certain details, however, some of your transactions with us may be impacted. Should you be under the age of 16, please consult your parents or guardians before providing your personal data. 5. How we collect your information (a) Our reservation system; (b) Stay at Grand Emperor Hotel; (c) Our loyalty programme; (d) Travel agencies; (e) Franchisees; (f) Other third parties such as related entities, business partners, other customers, or your representatives with appropriate consent from you; (g) When you submit your Data through our websites or WeChat; (h) Publicly available sources; (i) When we are legally required to do so; (j) Your browser type and operating system; (k) IP address and device identifiers; (l) Your browsing behavior on our Services, such as the amount of time spent viewing our online Services and the links you click within our online Services; and (m) Whether you have opened or forwarded our e-mails or connected to offers or links that we send you. 6. How We Use Personal Information We may collect, retain and use your Data for the following purposes: (a) to verify your identity; (b) to process your application of our membership program; (c) to administer your membership; (d) to fulfil your hotel reservation, including sending your information prior to the hotel stay or post-stay communications and satisfaction surveys to get feedback on your experience. (e) Better service your account and preferences by keeping you informed of your account status and activities through printed or electronic policy; (f) manage our accounts and records; (g) send service related communications, including announcements and administrative messages such as order confirmation; (h) undertake credit checking, prevention of fraud and other prohibited or illegal activities as part of our efforts to keep our platforms and services secure; (i) to carry out matching procedures, as defined under the Ordinance; (j) to verify your eligibility to our offers and/or promotions or other events; (k) to provide, activate and/or renew Services and/or membership program; (l) to provide you with promotional benefits, updates, offers and invitation to events; (m) to promote and market our Services to you; (n) to provide suitable advertisement and website contents to you; (o) to provide suitable products or services to you; (p) to tailor our products or services to your preferences; (q) to provide anonymous report and to send member notice to us or our clients; (r) to respond to complaints or compliments received; (s) to conduct credit checks and detect fraudulent activities in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) or any other relevant regulations and in relation to other compliance purposes; (t) to perform research or analyses so that we may improve and optimize the Services that can be made available to you; (u) to conduct surveys and marketing, promotional, behavioral scoring for business operations and/or planning purposes; (v) to carry out market and product analyses in order to generate statistical or actuarial reports (containing aggregated data that does not relate to any identified or identifiable individual); (w) to contact you regarding administrative notices and communications relevant to your use of our websites and membership program and to respond to your request. We may also use your information to match user information with third party data (i.e. to compare two sets of personal data collected for different purposes). By registering for membership program, subscribing to our website or by logging-in, you consent to carry out this matching procedure when we deem it is necessary in order to provide our services; (x) to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Services to you; (y) to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems; (z) to maintain, enhance and develop our products and service offerings; (aa) to operate internal control, resolve disputes, troubleshoot problems and enforce our terms of use; (bb) to operate, evaluate and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products and customer base; performing data analystics; and performing accounting, auditing and other internal functions); (cc) to comply with applicable laws in or outside Hong Kong as may be required by applicable government authorities, courts, law enforcement, or regulatory or investigation bodies, in relation to the supply of Services and/or loyalty programs to you, including to assist in the prevention, detection of crime or possible criminal activities; and (dd) to distribute our collection brochures and/or promotional materials as well as those of our business partners and counterparties. In the event that any such Personal Information is not provided, we may be unable to provide you with the services or goods mentioned above. 7. Disclosure of Personal Information We may disclose personal information in the following ways: Grand Emperor Hotel will disclose personal information without your permission when required by law or requested to do so by a government entity, or in good faith belief that such action is necessary to investigate or protect against harmful activities to Grand Emperor Hotel guests, visitors, associates, or property (including our Websites), or to others. We will share your information with the Grand Emperor hotel regarding your reservation. We may also share your information with third-party service providers to provide services related to our business, and to help us improve our products and services, such as market research and data analytics, online advertisement executed by third-party service providers partners on our behalf. In certain instances, subject to local consent requirements, third-party service providers may also assist us with various marketing campaigns. These parties have agreed to comply with our privacy requirements. In relation to the use of your personal data in direct marketing, we will only do so subject to your consent and you have the right to opt-out from such case. Aside from the purposes described above, we do not share your stay information with any other third parties unless we have your consent or under special circumstances, such as: (a) when we believe in good faith that the disclosure is required by law or to protect the safety of hotel guests, employees, the public or The Emperor Group property; (b) when disclosure is required to comply with a judicial proceeding, court order, subpoena, warrant or legal process; or (c) in the event of a merger, asset sale, or other related transaction. 8. Our legal basis for using your Data including how we disclose your Data We have a legitimate interest in properly administering the Services. In addition, our use of your personal data may be necessary for the performance of the Services that you have requested. In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organizations or parties outside of the Group (which may be within or outside of Hong Kong) (collectively, “Organizations”). Your Data is disclosed to these Organizations for the strict purpose of enabling us to supply our Services to you but is not applicable to any Organizations which are not owned by the Group or of which its company policies are not controlled by the Group as well as any persons employed or managed by the Group. In some circumstances as mentioned above, we may need to ask for your consent to use your Special Data where required by law to do so. These Organizations provide support services to our businesses and operations including without limitation: (a) customer enquiries; (b) mailing operations; (c) billing and debt-recovery functions; (d) information technology services; (e) installation, maintenance and repair services; (f) marketing, advertising and telemarketing services; (g) market research; (h) customer usage and behavioral analysis; (i) process management; (j) surveys; and (k) website usage analysis, etc. We take the required steps to ensure that these Organizations are bound by appropriate confidentiality and privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing). In addition, we may disclose your Data: (a) to your authorized representatives and/or your legal advisers when requested by you to do so; (b) for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties: (i) telecommunications network operators; (ii) our affiliates, overseas offices, assignees, transferees and representatives; (iii) our professional advisers, including our accountants, auditors, lawyers and insurers; (c) to banks, hotels, insurance companies, billing agents and various business collaborators for reward redemption purposes and benefits applicable to members of our membership program; (d) to third party providers for the purposes of providing online and other payment services, handling credit checks and fraud prevention, and any other services required in order for us to use your information for the purposes specified in this Privacy Policy Statement; (e) to any third party that purchases, or to which we transfer, all or substantially all of our assets and business sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information is safe; (f) to government and regulatory authorities and other organisations, as required or authorized by law; (g) to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business; and/or (h) to charities or non-profit organizations, etc. 9. Transfer of Data outside Hong Kong At times it may be necessary and/or prudent for us to transfer and/or store your Data to places outside of Hong Kong, for instance, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data were collected. In the event that we do transfer your Data outside of Hong Kong, we will do so in compliance with the prevailing requirements of the Ordinance, other relevant regulations and the GDPR where applicable. 10. Cookies and IP Address Grand Emperor Hotel and our third party marketing partners may use cookies, invisible pixels, local shared objects (i.e., persistent cookies) and web beacons to obtain information about Websites users. Cookies are small text files that are placed on a computer or mobile device when you visit a website or use an app. Our Websites may receive and store certain information automatically based on your browser settings, which may include your browser type and operating system, the web pages viewed, IP addresses or unique device identifiers associated with mobiles devices, and sites visited before or after visiting our Websites. You can set your computer to warn you each time a cookie is sent or turn off all cookies (except Flash cookies) through your browser. Check your browser's Help menu or your built-in mobile device settings to find out how. Some mobile devices store cookies not only in areas connected to the browser, but also in areas that are app-specific, which cannot be controlled by the browser settings. Check your app settings options on your mobile device to find out how to manage or delete cookies that may be stored in these other areas. If you do not accept cookies, some features, services or activities that are available on our Websites may be adversely affected and you may be unable to perform certain transactions, use certain functionality, and access certain content. We use the following types of cookies on our Websites and apps: (a) Session cookies which are automatically deleted once you close your browser. (b) HTTP request header information in order to make our Websites function correctly and to personalize content presented to you, better understand how visitors use our Website and how we can better meet your needs. (c) Throughout the online reservation process to remember dates used in hotel searches, check room availability and fulfill the reservation. (d) Measure usage of various pages on our Website to help us make our information more personalized and easily accessible. (e) Provide functionality such as online reservations and other functionality that we believe would be of interest and value to you. (f) Track customer response to Grand Emperor Hotel advertisements and website content. (g) Determine your browser’s ability to receive HTML email messages to determine the appropriate format for you to receive and read email. (h) Know how many users open an email and allow our service provider to compile aggregated statistics about an email campaign for us. (i) Serve ads through third-party advertising technology when you visit our Website and sites upon which we advertise. In the course of serving our advertisements to you, unique third-party persistent cookies, clear gifs or beacon gifs may be placed on your computer or device, provided by our ad-serving providers, to help manage our online advertising and which recognize when a device visits our Websites, to learn which banner ads bring users to our Websites and to track whether a reservation is made. The information our ad-serving providers and we collect through this technology is not personally identifiable but is used to create a profile which allows the ad-serving provider to serve adverts targeted towards you and your interests across the ad-serving network. Grand Emperor Hotel and its third-party service providers use web beacons and pixel tags to: (a) Track customer response to Grand Emperor Hotel advertisements and Website content; (b) Determine users ability to receive HTML-based email messages and know how many users open an email and allow our service provider to compile aggregated statistics about an email campaign for us; and (c) Allow us to better target interactive advertising, enhance customer support and site usability, and provide offers and promotions that we believe would be of interest to you. 11. Marketing Communications Our intention is that you should only receive email communications that will be useful to you and that you want to receive, so we provide you the ability to define and modify your mailing preferences online at any time including unsubscribing from all marketing communications, offers and promotions and research surveys. 12. Security of Personal Information We treat the personal information you provide to us as confidential and take reasonable steps, including standard industry safeguards to protection your personal information from accidental deletion or loss and unauthorized access, disclosure or modification. When you submit personal information to us via our Websites, it is transferred over a Secured Sockets Layer (SSL) connection, provided you are using a SSL enabled browser or device. 13. Updating or Accessing Your Personal Information With some limited exceptions, you have rights to access and update personal information held about you. If you want to inquire about any personal information we may have about you, you can do so by sending us a written request by letter or email to the addresses set out in Section 15 below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal information regarding you, or in case we need to contact you to obtain any additional information, we may require to make that determination. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially. You may request that we correct, cancel, and/or stop processing personal information that we hold about you. If we agree that the personal information is incorrect, or that the processing should be stopped, we will delete or correct the personal information. If we do not agree that the personal information is incorrect we will tell you that we do not agree and record the fact that you consider that personal information to be incorrect in the relevant file(s). 14. Linked Websites This Website may contain hyperlinks to other websites operated by third parties. These linked websites are not under our control and therefore we are not responsible for the contents of any such linked website and/or any hyperlink contained therein. These hyperlinks are provided as a convenience only, and the inclusion of any hyperlink does not imply any endorsement of the linked website by us. Linking to any such website is at your own risk. If you wish to have any hyperlink to this Website, you must first obtain our prior written consent which may or may not be given and/or may be subject to such conditions as we deem appropriate. Unless otherwise approved by us in writing, all permitted hyperlinks to this Website shall be connected to the front page of this Website. 15. Right for Access to personal information, questions, complaints, correct or delete You have a right of access and correction with respect to personal data as provided for in sections 18 and 22 and Principle 6 of Schedule 1 of the Personal Data (Privacy) Ordinance. Your right of access includes the right to obtain a copy of your personal data provided by you during the registration. We are committed to ensuring that all personal data is handled in accordance with the relevant provisions of the Personal Data (Privacy) Ordinance. Enquiries concerning the personal data provided, including the making of access and corrections, should be addressed to Data Protection Officer at enquiry@grandempeoror.com We take all reasonable precautions to ensure that the Data we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that Data depends to a large extent on the Data you provide. You have a right to request access to, and correction of, your Data and we recommend that you: (a) let us know if there are any errors in your Data; and (b) keep us up-to-date with changes to your Data. If you have any questions about this Policy, or any concerns or complaints with regard to the administration of the Policy, please contact us in writing at: Grand Emperor Hotel No. 288 Avenida Comercial De Macau Attention to: Data Protection Officer or via email to: enquiry@grandempeoror.com 16. Changes to Policy We reserve the right to change, add, delete and/or amend, without notice, at any time and from time to any provisions of this Policy. To assist you, this Policy has an updated date set out at the end of this Policy. 17. Governing Law These Terms and Conditions are governed by and shall be construed in accordance with the laws of the Hong Kong Special Administrative Region ("Hong Kong") and you hereby agree to irrevocably submit to the exclusive jurisdiction of the courts of Hong Kong in relation to any legal actions or proceedings arising out of and/or in connection with this Policy. 18. Data Retention We will retain your Data in accordance with our internal policies. Our policies are in compliance with the Ordinance, the GDPR and other relevant laws where applicable, and cover the following principles: (a) Data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and (b) Data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures. 19. Security of Personal Information We treat the personal information you provide to us as confidential and take reasonable steps, including standard industry safeguards to protection your personal information from accidental deletion or loss and unauthorized access, disclosure or modification. When you submit personal information to us via our Websites, it is transferred over a Secured Sockets Layer (SSL) connection, provided you are using a SSL enabled browser or device. 20. Sensitive Data Unless specially required or requested by us, please do not send or publish any personal sensitive data (e.g. contents in relations to race, political views, religious or other beliefs, health record, criminal record or chamber membership, etc.) to us or through our websites or social media platforms. If we specially required or requested your provision of sensitive data, we must obtain your prior express consent. 21. Privacy Policy Statement We pledge to meet fully recognized standards of personal data privacy protection in complying with the requirements of the Personal Data (Privacy) Ordinance (PDPO). In doing so, we will ensure compliance by our staffs with the strictest standards of security and confidentiality. All information collected will be treated in strictly confidential and will not be sold, reused, rented, disclosed, or loaned. 22. Responsibility The Grand Emperor Hotel gives no explicit or implicit guarantees and assumes no responsibility for the use of this information. The user has sole responsibility for the use of this information. The Grand Emperor hotel reserves the right to edit this information at any time. 23. Language This Policy can be translated into other languages which are provided for reference only. In the event of any inconsistency between the English version and any translated versions, the English version shall prevail. We keep our privacy policy statement under regular review. This privacy policy statement was last updated in September 2018.