Last Updated: [Please insert actual date, e.g., October 27, 2024]
ALOHA Asia Pacific Limited (“we”, “us”, or “ALOHA”) is deeply committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our official website [insert website URL] (the “Site”), use our services, or are a guest at our hotels and resorts.We develop this policy in accordance with the Hong Kong Special Administrative Region’s Personal Data (Privacy) Ordinance (PDPO) and other applicable data protection laws. Please read this policy carefully to understand our practices.1. Collection of InformationWe collect information you provide directly to us and information collected automatically during your interactions with us.1.1 Information You Provide Directly
- Bookings and Stay Information: When you make a reservation through our website, phone, or third-party platforms, we collect your name, contact details, payment information, passport/ID number, check-in and check-out dates, fellow guest information, and preferences (e.g., room type, bed type, dietary preferences).
- Website Enquiries and Communication: When you contact us via website forms, email, or phone, we collect your name, email address, phone number, and the content of your communication.
- Loyalty Program Registration: When you enroll in our loyalty program, we collect the personal information you provide to manage your account and points.
- Events and Surveys: When you participate in our promotions, market research, or satisfaction surveys, we collect the information you provide.
1.2 Information Collected Automatically
- Device and Usage Data: When you visit our Site, we automatically collect your IP address, browser type, operating system, access times, pages viewed, and the referring website address through cookies and similar technologies.
- Information from Technical Services within Hotels: As part of our hotel services and security, our properties may process information through:
- CCTV: For the safety and security of our guests and employees, we operate CCTV cameras in public areas.
- NEXT SMS AIoS® System: Our intelligent AI management system processes video streams for real-time security analysis (e.g., behavior recognition, anomaly detection). This system employs cutting-edge anonymization techniques (e.g., real-time semantic segmentation models) to automatically mask irrelevant personally identifiable information (e.g., faces of passersby, license plate numbers) during analysis. Unless a security alarm is triggered, we do not store or view personally identifiable information from unanonymized raw video streams. The system may also process encrypted metadata (e.g., device status, passenger flow count).
2. Use of Information
We use your information for the following purposes:
- To process your bookings, provide accommodation, and related services.
- To manage communications with you and respond to your inquiries and requests.
- To manage your loyalty account and provide membership benefits.
- To improve our website, services, and guest experience.
- To conduct market research and analysis to improve our products and services.
- For the safety and security of our hotels, fraud detection and prevention.
- To send you promotional information and marketing materials, with your separate consent.
- To fulfill our legal obligations and comply with regulatory requirements.
3. Sharing and Disclosure of Information
We only share your information under the following circumstances:
- Within our Group: To provide unified services, your information may be shared within our affiliated companies.
- Service Providers: We may share information with third parties who provide services to us, such as payment processing, data analysis, customer service, email delivery, hosting services, and security monitoring. These service providers are contractually bound to use your information only to provide services to us and must protect its confidentiality.
- Business Transfers: In the event of a merger, acquisition, asset sale, or bankruptcy, your information may be transferred as part of the transaction assets.
- Legal Requirements: We may disclose your information to comply with applicable laws, regulations, subpoenas, court orders, or other legal processes, or in response to lawful requests from government authorities.
- Protecting Rights and Safety: We may disclose information when necessary to protect the rights, property, and safety of ALOHA, our employees, guests, or the public, including for fraud protection and credit risk reduction.
4. Cross-Border Data Transfers
Our operations span the Asia-Pacific region. Your information may be transferred to and processed on servers located outside of your jurisdiction, including countries/regions where our affiliates and service providers are located. The data protection laws of these countries/regions may differ from those of your jurisdiction.When making such transfers, we will implement appropriate safeguards (e.g., executing Standard Contractual Clauses, obtaining your explicit consent) to ensure that your information receives a level of protection consistent with this policy and the requirements of applicable laws.
5. Data Security
We have implemented reasonable administrative, technical, and physical safeguards designed to protect the information you provide against unauthorized access, use, disclosure, alteration, and destruction. These measures include encryption (e.g., TLS, AES-256), access controls, and security audits. Please note that despite our best efforts, no method of transmission over the Internet or electronic storage is 100% secure.
6. Your Privacy Rights
Under applicable laws (such as the Hong Kong PDPO), you may have the following rights:
- Access and Correction: The right to request access to the personal information we hold about you and to correct inaccurate information.
- Withdraw Consent: The right to withdraw consent you have previously given regarding our collection, use, or disclosure of your personal information.
- Deletion: The right to request the deletion of your personal information.
- Object to Processing: The right to object to our processing of your personal information for direct marketing purposes.
To exercise these rights, please contact us using the contact details provided in Section 11. We may need to verify your identity before processing your request.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this policy and to comply with our legal, tax, accounting, and reporting obligations. For example, booking information is typically retained for a period after your last stay, while CCTV recordings may be retained for a specific shorter period based on legal requirements.
8. Children’s Privacy
Our website and services are not intended for children under the age of 16. We do not knowingly collect personal information from children under 16. If we become aware that we have inadvertently collected such information, we will delete it as soon as possible.
9. Cookie Policy
Our website uses cookies and similar technologies to enhance user experience, analyze site traffic, and for marketing purposes. You can refuse or manage cookies through your browser settings. Please note that disabling cookies may affect the functionality of certain features of the website.
10. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be effective when the revised policy is posted on our website. We encourage you to review this policy periodically for the latest information.
11. Contact Us
If you have any questions, comments, or requests regarding this Privacy Policy or our privacy practices, please contact us at:
Email: privacy@alohaasiapacific.com