Privacy - The Hong Kong Jockey Club

About HKJC

Privacy Policy Statement

The Hong Kong Jockey Club

The Club's Commitment to Protect Your Privacy

The Hong Kong Jockey Club and where applicable, each of its subsidiaries (together "the Club"; each a "Club Entity"), are committed to ensuring the privacy and security of the Personal Data (as defined below) they hold. The Club aims to meet this commitment by implementing the principles and requirements of the Personal Data (Privacy) Ordinance ("the Ordinance") of the Hong Kong Special Administrative Region of the People’s Republic of China ("Hong Kong"). This Privacy Policy Statement is intended to explain the Club's privacy practices.

For the purpose of this Privacy Policy Statement, "subsidiaries" of The Hong Kong Jockey Club refer to the "subsidiaries" of The Hong Kong Jockey Club as set out in the annual report of The Hong Kong Jockey Club.

Collection of Personal Data

From time to time and for the purpose of carrying on the Club's businesses and operations, including the provision of facilities, goods and services to you, you may be requested to supply data that may directly or indirectly identify you or other person(s) as an individual ("Personal Data") such as, but not limited to, the following:

Information about you such as your full name, date of birth, gender, nationality, marital status, educational background, professional qualifications, employment history, public appointments, awards and recognitions and community services;
Photographs and other images of yours and biometric data, such as your voice, voice ID, thumb ID and facial recognition data;
Contact details such as email address, mailing and residential address, telephone/mobile number, and fax number;
Unique identifiers or personal identifiers for the membership and other programmes managed and/or operated by the Club, including but not limited to the membership number, betting account number, and identifiers/account numbers for horse ownership programme and any other loyalty / reward programmes and initiatives managed and/or operated by the Club (as applicable) and the relevant login credentials;
Your usage, transactional and activity records of the facilities, goods and services and provided and/or operated by the Club, including but not limited to those under your membership, horse ownership programme, betting account, loyalty / reward programmes and/or other initiatives (as applicable);
Information collected in your application for the Club’s membership (“Membership”), Membership number and details of use of product and services under your membership account;
Information provided in your application for horse ballot and registration as an Owner and details of your use of services in relation to horse ownership;
Information collected in your application for a betting account, betting account number and details of transactions conducted under your betting account;
Information for verification of identity, including identification type and identification number (such as your Hong Kong Identity Card and passport number) and other related information;
Payment information such as card holder name, your credit or debit card number and expiry date, information about your bank account or other payment services, billing address and other information;
Your interests, preferences and opinions and your responses to market surveys and contests conducted by the Club or on its behalf;
Details of other transactions or purchase or use of product or services with the Club or a Club Entity or their respective business partners;
Information the Club collects about you when you use the Club’s websites (“Websites”), mobile applications (“Apps”), web pages (including social media pages) (“Web Pages”) and systems , e.g. general diagnostic and usage data, geographic location of your device, details about your device, technical information (e.g. IP address, your log-in information, browser type and version, any unique device identifiers etc.), information about your visit (e.g. the full URL, clickstream to, through and from the Club’s Websites, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and browsing history, etc.);
Any other Personal Data and/or information provided by you, acquired and/or came into existence during the establishment or maintenance of business relationship for the performance of contracts or for compliance with laws, regulations, regulatory requirements and/or any Club’s rules and bye-laws.

Supply of Personal Data to the Club is non-obligatory, but failure to do so may result in the Club being unable to process your application(s) or to provide facilities, goods and services to you.

Occasionally, you may need to provide Personal Data about other individuals to the Club (e.g. spouse, children or guests). In that event, to comply with the Ordinance and any other applicable laws, regulations and requirements, you are required to have first obtained the authorisation of such individuals before using, disclosing and transferring their Personal Data, including giving consent on their behalf to the Club's possible use, disclosure and transfer of their Personal Data. You agree to, upon the Club’s request, provide any supporting documents which may be necessary to prove such authorisation. You also agree to procure and ensure that they have made access to this Privacy Policy Statement and advise them that the Club can be contacted for further information.

Use of Personal Data

Your Personal Data may be used for the following purposes:-

Providing facilities, goods, services and support or performing transactions and administration work related to the following operations of the Club, including but not limited to:

the Club's core operations of racing, betting and membership;
racecourses, clubhouses, catering, hospitality and entertainment;
charitable or non-profit making causes including art, community services, conservation, culture, education, environmental protection, healthcare, music, recreation and sports ("Charitable or Non-profit Making Causes"); and/or
facilities, services, programmes and/or initiatives in relation to the above, such as loyalty / reward programmes and customer support services (whether provided and/or offered online or offline).

Operating and managing any membership and loyalty / reward programmes, including but not limited to:

the enrolment and management of memberships and accounts;
the identification, verification and determination of eligibility for earning, accumulating and redeeming the privileges and benefits;
the processing, distribution and usage of privileges (whether through the Club, Club Entities and/or any other third party partners under the relevant programme);
the handling of the associated transfer, migration and synchronisation of data (including Personal Data) across accounts in the membership programmes, loyalty / reward programmes and the like operated by the Club, any Club Entities and/or business partners; and/or
the operation, maintenance, administration, customer data analysis thereof and all incidental matters.

Processing your application, subscription, order, request and/or enquires for, or in relation to the Club's facilities, goods and services as set out in paragraph 1;
Contacting you for the purpose of and/or in relation to the provision of the Club’s goods, services and facilities as set out in paragraph 1, and addressing any enquiries and complaints related thereto;
Conducting assessments and checks regarding eligibility for membership, horse ownership, facilities, goods, or services;
Verifying your identity;
Monitoring, managing and controlling the use and access to the Club's premises which are not open to public;
Matching (as defined in the Ordinance) your Personal Data with other data collected (by the Club or third parties) for other purposes and automated decision processing (including profiling), in relation to, the provision of facilities, goods and services to you, the performance of any transactions and administration work related to the Club's operations and tailoring and personalising product and services and offers as set out below;
Conducting data analysis (e.g. analysing trends, usages and other user behaviours) and commercial exploration of big data applications;
Marketing and advertising of any facilities, goods and services to you by the Club and its subsidiaries, such as sending you offers and promotions (please see further details in "Direct Marketing" below);
Conducting marketing services and events, and tailoring and personalising the Club’s products and services and offers that the Club and its business partners provide to you. The Club may also tailor its communications to you and tailor what the Club presents to you to better match your preferences and interests;
For the purposes of improving or designing new products, services and facilities, including to ensure that the Club’s Websites, Apps and Web Pages function correctly and in accordance with your preferences and circumstances;
Maintaining and developing the Club's business systems and infrastructure, including testing and upgrading of these systems;
Meeting any obligations, requirements or arrangements, whether compulsory or voluntary, or establishing, exercising or defending any legal rights of the Club, in connection with:

any law, regulation, judgment, court order, sanctions regime, within or outside Hong Kong existing currently and in the future;
any guidelines, guidance, demand or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities within or outside Hong Kong;
any of the Club's rules or bye-laws relating to the Club's core operations; or
any other agreements between you and the Club.

Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information of the Club and/or any other use of data and information in accordance with any programmes for compliance with client due diligence, sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
Prevention, detection or investigation of anomalies and preventing and/or remediating fraud or other potentially criminal, prohibited or illegal activities or otherwise protecting the integrity of the Club and its subsidiaries;
Facilitating communications between you and the Club;
Responding or taking part in legal proceedings, including seeking professional advice; and
All other legitimate business purposes and purposes directly related to or incidental to the above.

The Club may also use from time to time aggregate non-identifying information about its customers to better design and improve the Club's facilities, goods and services that it offers. This information will not identify any individual in particular.

Direct Marketing

Subject to the Club having obtained the relevant consent from you, we may use Personal Data for direct marketing carried out by the Club or a Club Entity for marketing and promotion of the following classes of facilities, goods, services, support and related events and activities offered or arranged by the Club or a Club Entity or their respective business partners:-

racing, betting and membership;
racecourses or clubhouse operations, catering, restaurants, hospitality, events and entertainment;
affinity cards, smart or stored value cards issued by or co-branded with the Club;
loyalty / reward programmes; and/or
Charitable or Non-Profit Making causes or events.

For such purposes, your Personal Data held by a Club Entity may be provided to other Club Entities and/or their respective business partners for use for direct marketing subject to your consent. The Club or a Club Entity or their respective business partners may also conduct such direct marketing via or jointly with third party services providers including social medial platforms, which may involve sharing Personal Data the Club or a Club Entity or their respective business partners hold about you with them.

You can always opt-out free-of-charge by following the opt-out instructions contained in the relevant communications or contacting the Club's Data Privacy Compliance Officer if you no longer wish any of your Personal Data to be used in and/or be transferred for any of the described direct marketing purposes.

Please note that if you choose to opt-out of direct marketing, the Club may still send you communications which are of administrative nature. For example, where you are a Member, betting account holder or member of a loyalty / reward programme operated by the Club, the Club may send you communications on administrative matters in relation thereto, such as account summaries and statements, annual reports.

The Club may create indirect group profiling by way of analysing your preference characteristics manifested in the information the Club has about you (e.g. your preferences, details of transactions conducted using your account, etc.).

Disclosure of Personal Data

Personal Data supplied to the Club will be kept confidential. However, the Club may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Personal Data was collected, provide such Personal Data to the following parties:

any Club Entities for fulfilling the purposes for which it was collected (subject to any consent requirement relating to "Direct Marketing" above), and to the Club's business partners for direct marketing use as described in "Direct Marketing" above;
any person or company who is acting for or on behalf of the Club, or jointly with the Club, in respect of the purpose or a directly related purpose for which the data was provided;
any other person or company who is under a duty of confidentiality to the Club and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information;
the Club's agents, contractors, suppliers and any third party service provider who provides administrative, marketing and research, distribution, data processing and analytics, telemarketing, telecommunications, computer, payment or other services to the Club in connection with the operations of its business;
the Club’s insurers and their reinsurers, brokers and agents;
government and regulatory authorities, investigative bodies, courts, law enforcement agencies and other organisations, as required or authorised by law, orders or requests;
any financial institutions or payment services providers necessary to establish and support the payment of any facilities, goods and services provided to you; and
your authorised representatives or your legal advisers when requested by you to do so.

The Club may also disclose your Personal Data to third parties: (i) when required by law, by court order or in response to a search warrant or other legally valid inquiry; (ii) pursuant to the Club's good faith belief that disclosure is required by law or otherwise necessary to the establishment of legal claims or defences, to obtain legal advice, to exercise and defend the Club's legal rights or to protect the life, body or property of any individual; or (iii) for enforcement of Club’s rules and bye-laws or prevent unauthorised access to Club premises. This also applies when the Club has reason to believe that disclosing the Personal Data is necessary to identify, contact or bring legal action against someone who may be causing interference with the Club's rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by activities causing such interference.

The Club may also transfer any information it holds about you as an asset in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of the Club or as part of a corporate reorganisation or other change in corporate control.

The Personal Data that the Club collects or obtains may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. By submitting Personal Data to the Club or using any of the Club's facilities, goods and services, you understand and consent to such transfer.

Links to Third Party Websites

The Club's Website, Apps and Web Pages may contain links to other sites and pages which are operated by third parties. You understand and acknowledge that the Club has no control over and does not endorse the content of the linked websites or the way in which the operators of those websites deal with your Personal Data. You should review the privacy policy for those third party websites to understand the ways in which your Personal Data may be used by those third parties.

Use of Cookies

By using any of the Websites, Apps and/or Web Pages, you agree that the Club can store and access cookies, IP addresses, domain names, URLs and use other methods in order to collect your usage data on the Websites, Apps and/or Web Pages and improve your on-line experience.

Cookies are small files that are placed on your computer, mobile phones or other devices by websites or mobile applications that you visit/use or certain emails you open. They are widely used in order to make functions on the websites, mobile applications and/or emails properly, as well as to provide business and marketing information to the owners of the websites, mobile applications and/or emails.

The Club uses cookies on its Websites, Apps and/or Web Pages to track visitor preferences. These cookies allow the Websites, Apps and/or Web Pages to remember information that changes the way the Websites, Apps and/or Web Pages behave or looks, such as your preferred language. These cookies can also assist you in changing text size, font and other parts of the Websites, Apps and/or Web Pages that you can personalise. You may refuse to accept cookies by altering the settings on your internet browser, mobile phone or device but it should be noted that if you choose not to permit cookies, some areas of the Websites, Apps and/or Web Pages may not function properly.

Data Retention

All Personal Data that has been collected from you will only be stored for a duration that is reasonably necessary to fulfil the purposes for which it was collected as outlined under this Privacy Policy Statement. In some circumstances, the Club may retain your Personal Data for longer periods of time, for instance, where the Club is required to do so to meet legal, statutory, regulatory, tax or accounting requirements.

Commitment to Data Security

The Club is committed to protecting the security of your Personal Data. It uses a variety of physical, technological and organisational measures to help protect your Personal Data from unauthorised or accidental access, processing, erasure or other use.

The transmission of information via the Internet or mobile network is not completely secure. The security measures described above do not preclude the Club from the possibility of fraud, cyber-attacks, such as hacking, spyware and viruses, and the Club does not warrant that its servers or network will be immune from such attacks.

Although the Club will implement security measures to protect your data, the Club cannot guarantee the security of the data transmitted via Internet or mobile network. You agree that the Club shall not be liable for any loss or damage arising from risks relating to any transmission.

Changes to this Privacy Policy Statement

The Club may update this Privacy Policy Statement from time to time which will be posted on its website at www.hkjc.com, so as to inform you what information the Club gathers, how it might use that information and whether it discloses such information to anyone. You are also advised to check the latest Privacy Policy Statement posted on the Club’s website at www.hkjc.com on a regular basis. Where there are significant changes, we will notify you and obtain your acceptance and/or consents (as necessary or applicable). If you do not agree with this Privacy Policy Statement (as revised), please do not use or cease to use the facilities, goods or services of the Club and do not give us any of your information. By remaining as a member or continuing to use the facilities, goods or services of the Club after the changes come into effect, you agree to the revised Privacy Policy Statement.

Access to and Correction of Personal Data

You are entitled to request access to Personal Data held by the Club about you and to correct such data. The Club may charge a reasonable fee for the processing of such data access request.

You may direct your request in writing to:

Data Privacy Compliance Officer
Jockey Club Headquarters
1 Sports Road
Happy Valley Hong Kong

Interpretation

This notice is written in English language and may be translated into Chinese and other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.