Personal Data (Privacy) Ordinance

1.Notice relating to the Personal Data (Privacy) Ordinance (the "Ordinance")
1.1In order to become a Member of the Program (“the Program”), you need to provide to Swire Resources Limited (“Swire Resources”) from time to time your personal data. If you are unable or unwilling to provide such personal data, Swire Resources may not be able to process your membership application or provide or continue to provide the services, products and privileges under the Program to you.
1.2Personal data provided by you and all information generated, compiled or held by Swire Resources relating to your membership under the Program ("Personal Data") may be used and retained for the following purposes:
a.processing your application for the VIP Program membership;
b.providing you with services, products and privileges under the VIP Program;
c.marketing of services and products offered by Swire Resources and its holding companies, subsidiaries or affiliated companies ("Swire Resources Group") and/or persons or entities that are partners of Swire Resources Group in connection with the VIP Program ("Our Partners");
d.providing you with selected offers, promotions and benefits from Swire Resources Group and/or Our Partners that are likely to be of interest to you. Swire Resources Group and Our Partners may process and analyze your Personal Data to better understand your lifestyle and buying behaviour and characteristics and needs. The result of such analysis may be shared amongst members of Swire Resources Group and Our Partners;
e.conducting matching procedure (as defined in the Ordinance) with your Personal Data to produce or verify data for taking actions against you where appropriate or circumstances require;
f.providing regular communications about the VIP Program;
g.managing, operating, administering and maintaining the VIP Program;
h.designing new or improving existing services, products and privileges provided by Swire Resources Group and/or Our Partners and conducting related research;
i.investigating customer complaints and suspicious transactions;
j.preventing or detecting criminal activities;
k.complying with legal, legislative or regulatory requirements to disclose data; and
l.purposes relating to any of the purposes described above.
1.3Your Personal Data held by Swire Resources will be kept confidential but Swire Resources may disclose and transfer your Personal Data to any of the members of Swire Resources Group, Our Partners, agents, contractors, telecommunications service or other service providers engaged by Swire Resources, any other persons and entities that are under a duty of confidentiality to Swire Resources and any actual or proposed assignees or transferees of Swire Resources’s rights or obligations in connection with the VIP Program or its business (whether within Hong Kong or abroad).
1.4Use of Personal Data in direct marketing
a.Swire Resources is allowed to use your Personal Data in direct marketing in the following manner:
(i)to use your name, contact details, services and products portfolio information, and lifestyle and buying behavioral information held by Swire Resources from time to time in direct marketing;
(ii)to market the following classes of services and products offered by Swire Resources, other members of Swire Resources Group and/or Our Partners from time to time:
(1)consumer goods; and
(2)footwear, apparels and the accessories
(iii)to provide your Personal Data described in (i) above to any members of Swire Resources Group and/or Our Partners for their use in direct marketing the classes of services and products described in (ii) above.
b.If you do NOT wish Swire Resources to use your Personal Data in direct marketing, please tick the box in front page to exercise your opt-out right.
c.You may also write to Swire Resources at the address set out in paragraph 1.6 below quoting your name and membership number to opt out from direct marketing at any time.
1.5You have the right to:
a.check whether Swire Resources holds any of your Personal Data;
b.request access to your Personal Data held by Swire Resources;
c.request correction of any Personal Data which is incorrect;
d.ascertain Swire Resources's policies and practices in relation to personal data; and
e.opt out from receiving direct marketing materials.
1.6In accordance with the Ordinance, Swire Resources has the right to charge you a reasonable fee for processing and complying with your data access request. All requests for access to or correction of Personal Data or information regarding our policies and practices in relation to personal data should be in writing and addressed to :
 Swire Resources Limited
The Kooples Customer Services Department
12/F, Kingston International Centre,
19 Wang Chiu Road, Kowloon Bay, Kowloon.

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Email: thekooples_cs@swire-resources.com