We want you to be familiar with how
we collect, use and disclose Personal Information (as defined below). This Privacy Policy
describes our practices in connection with Personal Information that we collect through websites
operated by us or our affiliates from which you are accessing this Privacy Policy (the
“Websites”), through the software applications made available by us for use
on or through computers and mobile devices (the “Apps”), through our social
media pages and apps, if any, through HTML-formatted email messages that we send to you that
link to this Privacy Policy, as well as through your offline interactions with us where notice
is legally required (collectively, including the Websites, Apps, Social Media Pages and offline
interactions, the “Services”). By using the Services, you agree to this
Privacy Policy.
1.
Personal Information
“Personal
Information” is information that identifies you as an individual or relates to an
identifiable individual, including:
- Name
- Postal address (including billing and
shipping addresses)
- Telephone
number
- Email address
- Credit and debit card
number
- Profile
picture
- Social media account
ID
- Travel information, including trip flight
information
- Date of
birth
- Gender
- Air ticket number and Asia Miles
Membership Number (for Cathay Pacific customers
only)
Collection of Personal Information
We and our service providers may collect Personal Information in a
variety of ways, including:
- Through the Services: We may
collect Personal Information through the Services, e.g., when you sign up for a
newsletter or make a purchase.
- Offline: We may
collect Personal Information from you offline, such as when you visit our
stores, attend one of our trade shows, place an order over the phone or contact
customer service.
- From Other Sources: We may
receive your Personal Information from other sources, such as our affiliates,
public databases, joint marketing partners, social media platforms (including
from people with whom you are friends or otherwise connected) and from other
third parties. In addition, if you elect to connect your social media
account to your Website account, certain Personal Information from your social
media account will be shared with us, which may include Personal Information
that is part of your profile or your friends' profiles.
We may use a
third-party payment service to process payments made through the Services. If you
wish to make a payment through the Services, your Personal Information may be collected
by such third party and not by us, and will be subject to the third party’s
privacy policy, rather than this Privacy Policy. We have no control over, and are
not responsible for, this third party’s collection, use and disclosure of your
Personal Information.
If you submit any
Personal Information relating to other people to us or to our service providers in
connection with the Services, you represent that you have the authority to do so and to
permit us to use the information in accordance with this Privacy Policy.
How We May Use Personal Information
We and our service providers may use Personal
Information:
- To respond to your inquiries and fulfill your
requests, such as to
complete your transactions and provide you with related customer
service.
- To send administrative information to
you, such as changes to our terms, conditions and policies, as well as marketing
communications that we believe may be of interest.
- To personalize your experience on the
Services by presenting products and offers tailored to you and to facilitate
social sharing functionality.
- To allow you to participate in
sweepstakes, contests, loyalty programs and similar promotions and to administer
these activities. Some of these activities have additional rules
containing additional information about how we use and disclose your Personal
Information.
- For our business purposes, such as data
analysis, audits, fraud monitoring and prevention, developing new products,
enhancing, improving or modifying our Services, identifying usage trends,
determining the effectiveness of our promotional campaigns and operating and
expanding our business activities.
Disclosure of Personal Information
Your Personal Information may be
disclosed:
- To our
affiliates for the purposes described in this Privacy
Policy.
- To our
third-party service providers who provide services such as website hosting, data
analysis, payment processing, order fulfillment, information technology and
related infrastructure provision, customer service, email delivery, auditing and
other services.
- To third
parties, to permit them to send you marketing communications, consistent with
your choices if you have opted into such sharing.
- To third-party
sponsors of sweepstakes, contests, loyalty programs and similar
promotions.
- By you, on
message boards, chat, profile pages and blogs and other services to which you
are able to post information and content (including, without limitation, our
Social Media Pages). Please note that any information you post or disclose
through these services will become public and may be available to other users
and the general public.
- To your
friends associated with your social media account, to other website users and to
your social media account provider, in connection with your social sharing
activity. By connecting your Services account and your social media
account, you authorize us to share information with your social media account
provider, and you understand that the use of the information we share will be
governed by the social media provider's privacy
policy.
Other Uses and
Disclosures
We also may use and
disclose your Personal Information as we believe to be necessary or appropriate: (a) to
comply with applicable law, which may include laws outside your country of residence, to
respond to requests from public and government authorities, which may include such
authorities outside your country of residence, to cooperate with law enforcement, or for
other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our
rights, privacy, safety or property, and/or that of our affiliates, you or others.
We may furthermore
use, disclose or transfer your information to a third party in the event of any
reorganization, merger, sale, joint venture, assignment, transfer or other disposition
of all or any portion of our business, assets or stock (including in connection with any
bankruptcy or similar proceedings).
We may also use and
disclose Personal Information collected through the Services in other ways, with your
consent.
2. OTHER
Information
“Other
Information” is any information that does not reveal your specific identity or
does not directly relate to an identifiable individual, such as:
- Browser and device
information
- App usage
data
- Information collected through cookies,
pixel tags and other technologies
- Demographic information and other
information provided by you that does not reveal your specific
identify.
- Information
that has been aggregated in a manner that it no longer reveals your specific
identity.
If we are required to
treat Other Information as Personal Information under applicable law, then we may use
and disclose it for the purposes for which we use and disclose Personal Information, as
detailed in this Policy.
Collection of Other Information
We and our service providers may collect Other Information in a variety
of ways, including:
-
Through your browser or
device: Certain information is collected
by most browsers or automatically through your device, such as your Media Access
Control (MAC) address, computer type (Windows or Macintosh), screen resolution,
operating system name and version, device manufacturer and model, language,
Internet browser type and version and the name and version of the Services (such
as the App) you are using. We use this information to ensure that the
Services function properly.
-
If applicable, through your use of the
App: When you
download and use the App, we and our service providers
may track and collect App usage data,
such as the date and time the App on your device accesses our servers and what
information and files have been downloaded to the App based on your device
number.
If you do not want information collected through
the use of cookies, most browsers allow you to automatically decline cookies or be given
the choice of declining or accepting a particular cookie (or cookies) from a particular
website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html.
If, however, you do not accept cookies, you may experience some inconvenience in your
use of the Services. You also may not receive advertising or other offers from us
that are relevant to your interests and needs.
-
Using pixel tags and other
similar technologies: Pixel tags (also known as web beacons and
clear GIFs) may be used to, among other things, track the actions of users of
the Services (including email recipients), measure the success of our marketing
campaigns and compile statistics about usage of the Services and response
rates.
We use services of Google Analytics, which uses
cookies and similar technologies to collect and analyze information about use of the
Services and report on activities and trends. This service may also collect
information regarding the use of other websites, apps and online resources. You
can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and opt out
of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout,
We also use the services of Emarsys to track and
gather certain information on this website that helps us to better understand our
visitors’ needs related to our website, our services and/or our products.
You can learn about Emarsys’s practices by going to
https://www.emarsys.com/en-hk/privacy-policy/, and opt out of them by using the
“unsubscribe” link at the bottom of any email that may send you, or by
emailing unsubscribe@emarsys.com.
-
IP
Address: Your IP address is a number that
is automatically assigned to your computer by your Internet Service Provider
(ISP). An IP address may be identified and logged automatically in our
server log files whenever a user accesses the Services, along with the time of
the visit and the page(s) that were visited. Collecting IP addresses is
standard practice and is done automatically by many websites, applications and
other services. We use IP addresses for purposes such as calculating usage
levels, diagnosing server problems and administering the Services. We may
also derive your approximate location from your IP address.
-
Physical/Site
Location: We may collect the physical
location of your device by, for example, using satellite, cell phone tower or
WiFi signals. We may use your device’s physical location to provide
you with personalized location-based services and content. We may also
share your device’s physical location, combined with information about
what advertisements you viewed and other information we collect, with our
marketing partners to enable them to provide you with more personalized content
and to study the effectiveness of advertising campaigns. In some
instances, you may be permitted to allow or deny such uses and/or sharing of
your device’s location, but if you do, we and/or our marketing partners
may not be able to provide you with the applicable personalized services and
content.
Uses and Disclosures of Other Information
We may use and disclose Other
Information for any purpose, except where we are required to do otherwise under applicable
law. In some instances, we may combine Other Information with Personal Information.
If we do, we will treat the combined information as Personal Information as long as it is
combined.
3. THIRD
PARTY SERVICES
This Privacy Policy does not
address, and we are not responsible for, the privacy, information or other practices of any
third parties, including any third party operating any website or service to which the Services
link. The inclusion of a link on the Services does not imply endorsement of the linked
site or service by us or by our affiliates.
In addition, we are not responsible
for the information collection, use, disclosure or security policies or practices of other
organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app
provider, social media platform provider, operating system provider, wireless service provider
or device manufacturer, including with respect to any Personal Information you disclose to other
organizations through or in connection with the Apps or our Social Media Pages.
4. THIRD-PARTY
ADVERTISING
We may use third-party advertising
companies to serve advertisements regarding goods and services that may be of interest to you
when you access and use the Services and other websites or online services, based on information
relating to your access to and use of the Services and other websites or online services on any
of your devices, as well as on information received from third parties. To do so, these
companies may place or recognize a unique cookie on your browser (including through the use of
pixel tags). They may also use these technologies, along with information they collect
about your online use, to recognize you across the devices you use, such as a mobile phone and a
laptop. If you would like more information about this practice, and to learn how to opt
out of it in desktop and mobile browsers on the particular device on which you are accessing
this Privacy Policy, please visit http://www.networkadvertising.org/managing/opt_out.asp
and http://www.aboutads.info/.
You may download the AppChoices app at www.aboutads.info/appchoices to opt out in
mobile apps.
5.
security
We seek to use reasonable
organizational, technical and administrative measures to protect Personal Information within our
organization. Unfortunately, no data transmission or storage system can be guaranteed to
be 100% secure. If you have reason to believe that your interaction with us is no longer
secure, please immediately notify us in accordance with the “Contacting Us”
section below.
6.
CHOICES AND ACCESS
Your choices regarding our use
and disclosure of your Personal Information
We give you choices regarding our
use and disclosure of your Personal Information for marketing purposes. You may opt-out
from:
- Receiving
electronic communications from us: If you
no longer want to receive marketing-related emails from us on a going-forward
basis, you may opt-out by: following the unsubscribe link in any
marketing communication and by contacting us at contact.hk@americantourister.com.
Similarly, to stop receiving
SMS text messages, you will have to send an email to
contact.hk@americantourister.com to unsubscribe the SMS contact.
- Our sharing of
your Personal Information with affiliates for their direct marketing
purposes: If you would prefer that we not
share your Personal Information on a going-forward basis with our affiliates for
their direct marketing purposes, you may opt-out of this sharing by:
contacting us at contact.hk@americantourister.com.
- Our sharing of
your Personal Information with unaffiliated third parties for their direct
marketing purposes: If you would prefer that we not
share your Personal Information on a going-forward basis with unaffiliated third
parties for their direct marketing purposes, you may opt-out of this sharing by:
contacting us at contact.hk@americantourister.com.
We will try to comply with your
request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving
marketing-related emails from us, we may still send you important administrative messages, from
which you cannot opt-out.
How you can access, change or suppress your
Personal Information
If you would like to review,
correct, update, suppress/restrict or delete Personal Information that you have previously
provided to us, or if you would like to transfer your Personal Information to another company
(to the extent this right to data portability is provided to you by applicable law), you may
contact us by writing to contact.hk@americantourister.com or call
us on (852) 2422-2611.
In your request,
please make clear what Personal Information you would like to have changed, whether you
would like to have your Personal Information suppressed from our database or otherwise
let us know what limitations you would like to put on our use of your Personal
Information. For your protection, we may only implement requests with respect to
the Personal Information associated with the particular email address that you use to
send us your request, and we may need to verify your identity before implementing your
request. We will try to comply with your request as soon as reasonably
practicable.
Please note that we may need to retain certain
information for recordkeeping purposes and/or to complete any transactions that you
began prior to requesting a change or deletion (e.g., when you make a purchase or enter
a promotion, you may not be able to change or delete the Personal Information provided
until after the completion of such purchase or promotion). There may also be
residual information that will remain within our databases and other records, which will
not be removed.
7.
RETENTION PERIOD
We will retain your Personal
Information for the period necessary to fulfill the purposes outlined in this Privacy Policy
unless a longer retention period is required or permitted by law.
8. use of
Services by MINORS
The Services are not directed to
individuals under the age of eighteen (18), and we do not knowingly collect Personal Information
from individuals under 18.
9.
Jurisdiction and CROSS-BORDER
TRANSFER
The Services are controlled and
operated by us from the United States and are not intended to subject us to the laws or
jurisdiction of any state, country or territory other than that of the United States. Your
Personal Information may be stored and processed in any country where we have facilities or in
which we engage service providers, and by using the Services you consent to the transfer of
information to countries outside of your country of residence, including the United States,
which may have data protection rules that are different from those of your country. In
certain circumstances, courts, law enforcement agencies, regulatory agencies or security
authorities in those other countries may be entitled to access your personal
information,
If you are located in the EEA:
Some of the non-EEA countries are recognized by the European Commission as providing an adequate
level of protection according to EEA standards (the full list of these countries is available
here a hyperlink to EU Commission’s adequacy list online: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.With
regard to transfers to other countries, we have put in place measures, such as [standard contractual clauses
adopted by the European Commission and binding corporate rules to protect your Personal Information. You may
obtain a copy of these measures by contacting European Commission https://ec.europa.eu/info/about-european-commission/contact_en or
by following this link: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.
10.
SENSITIVE INFORMATION
we ask that you not send us, and you not disclose,
any sensitive Personal Information (e.g., social security numbers, information related to
racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or
genetic characteristics, criminal background or trade union membership) on or through the
Services or otherwise to us.
11.
RATINGS AND REVIEWS
The Services include the “Ratings and Reviews” feature on our Websites, which you may choose to use for the purpose of leaving a rating for product and sharing product reviews. Therefore, we may collect your Personal Information, and we will collect Other Information, through your use of such “Ratings and Reviews” feature, should you choose to use it. For your Personal Information, if collected by us through the “Ratings and Reviews” feature, the above sections of this Privacy Policy on Personal Information shall apply accordingly. For Other Information collected by us through the “Ratings and Reviews” feature, in addition to the above sections of this Privacy Policy on Other Information being applied accordingly, we may also use and disclose such Other Information for reviews-specific purposes including but not limited to administering ratings and reviews directly by us or with the use of third party service providers, syndicating ratings and reviews across Websites operated by us, our affiliates and our authorised distributors or business partners, in other countries. You can request that we remove content or information that you have posted through the “Ratings & Reviews” feature. To do so, please submit a written request as per instructions within this Privacy Policy. Please note that we may request for further information from you in order to ascertain your identity and the nature of your request, as well as to process, fulfil or otherwise deal with your request. Please note that while we will endeavour to honour your request, our removal of your content or information does not ensure complete or comprehensive removal of that information from Websites operated by us, our affiliates and our authorised distributors or business partners, or the internet. For example, historical copies, or “caches” may remain.
12. UPDATES TO THIS PRIVACY
POLICY
We may change this Privacy
Policy. The “Last
Updated” legend at the top of this Privacy Policy indicates when this
Privacy Policy was last revised. Any changes will become effective when we post the
revised Privacy Policy on the Services. Your use of the Services following these changes
means that you accept the revised Privacy Policy.
13.
CONTACTING US
You can contact us at contact.hk@americantourister.com.
If you have any questions about
this Privacy Policy, please contact us at contact.hk@americantourister.com
Because email communications are not always secure, please
do not include credit card or other sensitive information in your emails to
us.