It is the policy of the Data User (Andara Resort & Villas) to comply with General Data Protection Regulation. In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.
Andara safeguards all information provided by our Customers and Website users (“Users”). We do not collect any personally identifiable information (“PII”) from Users during their browsing of our Website. When Users visit our Website we record their visit only as a ‘hit’ and do not collect any PII from them. We will however make a record of the visit that shows only the domain name server (DNS) address, part of their e-mail address, and of the pages visited. We use such information only for preparing general statistics on the usage of our web sites.
If PII are collected in the process of making enquires or submitting applications for services provided by different operations within Andara, Users will be informed via the Personal Information Collection Statement of our websites of such purposes and uses, including the extent of their transfer and disclosure; and the right of access to and correction of the collected PII.
We set out our general policy and practices in respect of our collection and use of your data.
The Data User, in complying with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR, is committed to safeguarding your privacy on-line, and notify you of certain matters when collecting information from you. This statement may change from time to time, so please check back periodically. By subscription to our newsletter and every time you visit this Website or to use our services, you agree to be bound by this statement at that time in force.
At the time of subscription to our newsletter and at other times when using the Website, you may be asked to provide us with personally identifiable information, such as your name and e-mail address. It is necessary for us to collect your information for providing you with the various services and activities offered on this Website. You are not obliged to provide the information but if you fail to provide the requested information, we will not be able to provide you with the services and activities available on this Website. Certain non-personally identifiable information which does not identify you, may also be collected when you use this Website, including the type of browser and operating system you use, your IP address, other navigational clickstream data, etc.
We do not knowingly collect or use data relating to children below the age of 16, unless parental consent is provided for any collection and processing of PII in relation to children aged 16 or below. If you sign up for our newsletter on the Website, you confirm that you have reached the age of majority in your country of residence.
Purpose and Use of Data
We use and process the PII we collected through this Website with lawful justifications, including legal basis such as your prior explicit consent, to comply with a legal obligation, for performance of a contract, or in our legitimate interests as a business (such as in connection with the conducting and developing of our business and marketing activities), but only where such are not overridden by your interests and fundamental rights.
We describe below how we plan to use your PII, and upon which of the legal basis we rely to do so. Where appropriate, we also identify our legitimate interests as a business.
Lawful basis for processing including basis of legitimate interest
To respond to your inquiry for more information through email to us and to share with you our newsletters, news, updates and reports in response to your inquiries
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to address enquiry from visitors of our Website and to develop our business)
To collect data for identity verification and records and to maintain contact lists for correspondence
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to address enquiry from visitors of our Website)
(c) Your prior explicit consent
To compile aggregate statistics about our users and to analyze site usage
(a) Necessary for our legitimate interests (to keep our records updated and to study the performance of our Website and topics of interest to visitors)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)
(b) Necessary to comply with a legal obligation
To deliver information to you that we believe you may have interest in, such as targeted banners, new services and products and other promotions and marketing materials
(a) Necessary for our legitimate interests (to study how visitors use our Website, to grow our business and to customize experiences and preference viewing of the Websites)
To contact you regarding administrative notices and communications relevant to your use of this web site and to respond to your request
(a) Performance of a contract with you
(b) Our legitimate interest in keeping our members updated about our services
We may from time to time send direct marketing materials promoting products and services to Users. Suitable opt-out facilities will be provided during the direct marketing process.
If we add new features or services that might require the sharing of your personal information with an additional advertiser or sponsor, we will provide you with notice and the opportunity to opt-out to receive these offers. We will also get your explicit opt-in consent before we share your personal information with any third-party for marketing purposes.
With your explicit consent, we will send you updates via email about all the latest news and / or offers on our Website. You can unsubscribe at any time by clicking the link provided in any email. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. You can also contact us directly.
Transfer of Data
Your information will not generally be disclosed or transferred to any other party in a form that would identify you except in the following circumstances:
- If we use third-party suppliers or service providers to facilitate our services, we will have to provide your information to these suppliers or service providers offering such services where you choose to use these services.
- We may disclose or access account information when we believe in good faith that the law requires it.
- We may also disclose or access account information for administrative and other purposes that we deem necessary to maintain, service, and improve our services.
In addition, your information will be accessed by, disclosed or transferred to any person or bodies corporate or division within Andara for legitimate interests to our business for purposes set out above.
As the parties mentioned above may have places of business outside Hong Kong, your information may be transferred out of Hong Kong. By subscribing to our Website, you agree to us transferring your information to these parties outside Hong Kong. These parties adhere to their own privacy customs and policies and your information will be subject to said customs and policies.
Your Legal rights
You have the following rights with respect to your personal information: right of access, rectification and erasure (right to be forgotten) of your personal information we hold about you, right to object and restrict of processing of personal information, right to withdraw consent and right to data portability, which includes requesting for migration of your personal information in a structured electronic format to a third-party of choice. You may directly contact us if you wish to exercise these rights.
PII collected will be maintained securely in our system. We will only retain such data for as long as it is required to fulfill the purposes for which it was collected. Only authorized staff will be permitted access to such PII, and we shall not release such PII to any external parties except those parties set out in our Personal Information Collection Statement without User’s prior explicit consent.
Third Party Links and Policies
Last update: 26 Nov 2018
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Last update: December 12, 2018