We, L'hotel Management Company Limited (including its parent company, subsidiaries and affiliated companies, collectively the "L'hotel Group") are committed to protecting your privacy. As part of our commitment, we have thus adopted certain measures in relation to the collection, use, retention, disclosure, transfer, security and accessibility of your personal data in order to comply with the requirements laid down in the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region ("the Ordinance").

This Privacy Policy (the "Policy") applies to personal data and information regarding guests and other individuals with whom we do business and to the management of that data and information in any form, whether electronic or written.

Whilst we make every effort to protect your personal data, no security measures can guarantee that your personal data and information will not be subject to interference, misuse or hacking and we shall not be responsible for any loss, misuse or alteration arising as a result of such incidents.

1. Types of Personal Information We Collect
   When we need to collect personal data from you to provide you with a particular membership or service, we will ask you to voluntarily supply us with the information we need. The information collected includes but is not limited to:
   1. For Hotel eNewsletters (eNews subscription)
      1. Prefix
      2. Name
      3. Email address
      4. Mobile phone no.
   2. For Vivva Membership Program correspondence
      1. Prefix
      2. Name
      3. Email address
      4. Mobile phone no
      5. Contact phone no
      6. Country/District of residence
      7. Correspondence address
      8. Social media account
      9. Birthday
      10. Marketing channel preference for promotional materials; and
      11. Service preference
2. Purpose of Personal Data Collection
   You acknowledge and agree that such personal data will be used by us for the following purposes:
   1. The provision of any goods and /or services offered by L’hotel Group
   2. The analysis, verification and /or checking of your credit, credit history and payment;
   3. The ensuring of your on-going credit worthiness;
   4. The processing of any payment instructions, direct debit facilities and / or credit facilities you requested;
   5. The determination of the amount of debt owed to or by you and / or the processing and / or collection of amounts outstanding from you and those providing security for your obligations;
   6. For Vivva applicants and members, to process your application and administer your Vivva Membership;
   7. To provide privileges, benefits and services with regards to the Vivva memberships and L'hotel Management Company Limited (including its parent company, subsidiaries and affiliated companies, collectively the "L'hotel Group");
   8. To conduct market analysis, market research, customer satisfaction and quality assurance surveys;
   9. To respond to requests for information and services;
   10. For general administration and record keeping;
   11. To facilitate direct marketing, promotional and customer management purposes, including sending you sales, promotional communications or special offers from L'hotel Management Company Limited (including its parent company, subsidiaries and affiliated companies, collectively the "L'hotel Group") if you have consented to receive them by the channels which you have agreed to receive;
   12. For disclosing the winner of contests and lucky draw competitions conducted by us or on our behalf;
   13. To facilitate matching for whatever purpose with other personal data;
   14. To facilitate analysis, verification and/or checking of your credit, credit history and payment;
   15. To meet legal and regulatory requirements; and
   16. For any other purposes relating to the above.
3. Disclosure and Transfer
   1. We reserve the right to disclose any personal data and information we have concerning you if we are compelled to do so by a court of law or requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property. We also reserve the right to retain information collected and to process such information to comply with accounting and tax rules and regulations.
      In addition, we may share your personal data to:
      1. any agent, contractor, credit provider, financial institution, third party service provider, and their respective professional advisors;
      2. any of the affiliates and the parent company of L'hotel Group, and any company in which the same has a direct or indirect interest or with which it is in joint venture or co-operation with or their respective successors and assigns;
      3. any actual or proposed assignee or transferee of L'hotel Group; and
      4. any other person under a duty of confidentiality to L'hotel Group
   2. We may share aggregated demographic information with business partners, affiliates or other entities. This aggregate information is not linked or traceable to any personally identifiable information about you.
   3. Except as described herein, we do not permit the sale or transfer of personally identifiable information to third parties.
4. Direct Marketing
   1. L'hotel Group intends to use your data including the following to send you marketing communications materials in the areas of hotel, serviced apartments, food & beverage, banquet and conference services, leisure and lifestyle, travel and property by email, mail, phone call, SMS message and social media message.
      1. For Hotel eNewsletters (eNews subscription)
         1. Prefix
         2. Name
         3. Email address
         4. Mobile phone no.
      2. For Vivva Membership Program correspondence
         1. Prefix
         2. Name
         3. Email address
         4. Mobile phone no
         5. Contact phone no
         6. Country/District of residence
         7. Correspondence address
         8. Social media account
         9. Birthday
         10. Marketing channel preference for promotional materials; and
         11. Service preference
   2. We may not use your personal data for direct marketing purpose without your consent. We seek for your permission before we use your personal information for direct marketing during the Vivva application process. You may opt-out from receiving marketing communications at any time with no additional charges, by:
      1. Following the "opt-out" instructions contained in the communications;
      2. Amend the marketing materials preference from time to time through choices in the Profile Update pages after logging into the Vivva Members Area
      3. Contacting Vivva Member Services team by mail, email or phone
         CRM Team
         L’hotel Management Company Limited
         a: 38th Floor, Tower 2, Nina Tower, 8 Yeung Uk Road, Tsuen Wan, Hong Kong
         e: [email protected]
         t: (852) 3968 8383
         w: https://member.lhotelgroup.com
         (Please indicate “Opt-out from receiving marketing communications”)
   3. When your opt-out request is received, your contact details will be “suppressed” rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.
5. Data Retention and Security
   1. You further acknowledge and agree that the personal data will be retained by us for the purposes as mentioned aforesaid as well as for other purposes that may be agreed between you and us or required by law from time to time.
   2. We will take all practicable steps to ensure the data held by us are protected against unauthorized or accidental access, process, erasure or other use.
6. Changes to the Policy
   1. The Privacy Policy will be modified from time to time. Any changes to this policy will be posted to Vivva website so that you are always informed of the way we collect and use your personal data.
   2. Any changes to our Policy will become effective upon posting of the revised policy on the website. We encourage you to periodically review our privacy policy to ensure familiarity with our most current version.
7. How to Access or Correct my Personal Data
   Under and in accordance with the Ordinance, you have the right to:
   1. check whether we hold of your personal data;
   2. require us to correct any personal data which is inaccurate; and
   3. ascertain our policies and practices (from time to time) in relation to the personal data and to be informed of the kind of personal data held by us