Privacy Policy (the “Policy”)

1. Personal Data (Privacy) Ordinance

The Ladies’ Recreation Club (“LRC” or “we” or “us”) are committed to safeguarding the privacy, confidentiality and security of the personal data we hold by complying with the principles and requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the "Ordinance"). We are equally committed to ensuring that our staff and any third parties we engage uphold these obligations. You may wish to visit the official website of the Office of the Privacy Commissioner for Personal Data at www.pcpd.org.hk for more information about the Ordinance.

2. Application and Authorisation

This Policy applies to the individuals from whom we directly collect personal data. These individuals include members and non-members (such as members’ guests or a person submitting enquiries to us).

By accessing our website, mobile application or our services in-person at our premises, you consent to the use of your personal data in the manner described in this Policy. Without limiting the generality of the foregoing, you authorise us to transmit your information for the purposes described in this Policy.

We may update the Policy on our website and mobile application from time to time.

3. Purposes of Collection

The types of personal data we collect will depend on the specific type of services and products as requested by, or provided to, you. Personal data provided in any form or document filed with, served on or otherwise sent to us, whether on paper or by electronic means, will be used for the following specific, limited and legitimate business purposes only:

(a) Administering and processing your membership applications, enquiries, and/or other requests for services or benefits;

(b) Verifying your identity in connection with the services or benefits that may be supplied to you;

(d) Processing billing, payment and collection of outstanding fees;

(e) Communicating with you about information of the LRC including our news and events;

(f) Conducting statistical or demographic research and analysis to enhance our services;

(g) Direct marketing (in particular, your name, membership number, company name, and contact details may be used; marketing contents may include discounted goods and services, festive packages, classes, programs, events, functions, partner promotions, special offers organised or provided by the LRC and/or other business associates/organisations jointly or severally and solicitation of donations and contributions for charitable or non-profit making purposes); and

(h) Complying with any laws, rules, regulations, codes or guidelines issued by government authorities.

In general, we will not knowingly collect or maintain personal data from individuals under 16 years old. In case we must collect personal data from them, we will seek prior consent from their parents or guardians.

Providing personal data to us is voluntary. However, if you do not provide us with certain required personal data, we may not be able to process your requests or enquiries.

4. Direct Marketing

As mentioned, we may use your personal data for direct marketing, and we may not do so without your consent. If you have previously consented to such purpose but no longer wish to do so, please send an official request via email to inquiries@lrc.com.hk or by post to us at Ladies’ Recreation Club, 10 Old Peak Road, Hong Kong.

5. Retention of Your Personal Data

Generally, we will retain your personal data only for so long as it is necessary to fulfil the purposes for which it is collected. Certain data may continue to be retained by us to comply with applicable legal and regulatory requirements, to properly resolve disputes, or to troubleshoot problems. In any case, all personal data will only be kept for 7 years. After that time, your data will be erased.

By way of full and frank disclosure, we may not be able to erase some types of person data due to technical constraints, but we will implement procedures to block such data from being further accessed.

6. Disclosure

Your personal data will generally be kept confidential and will not be disclosed to any other person without your consent. However, we may, as and when appropriate, transfer your personal data to the following parties (whether in or outside Hong Kong), for the specific, limited and legitimate business purposes disclosed in this Statement:

(a) Selected staff, authorised officers and specific committee members;

(b) Third-party agents, contractors, or other service providers we engage to facilitate our operations and provisions of services; and

If your personal data is transmitted outside Hong Kong, we will implement necessary measures, including appropriate contractual clauses, to secure the transfer of your personal data.

7. Security

We have installed a security system to ensure your personal data is not subject to unauthorised or accidental access. The system is a secured database stored on a dedicated server hosted by the LRC and residing behind firewalls. We also provide trainings to our staff on the importance of data privacy and protection. We will maintain other commercially reasonable administrative, technical and physical safeguards to protect your personal data where necessary.

8. Your Right of Access to and Correction of Personal Data

You are entitled to request access to the personal data held by the Club about you, and to make corrections if needed. To update your personal details, please visit our website or mobile application and go to the “Members’ Area” section, or contact us at membership@lrc.com.hk. We reserve the right to charge a reasonable fee for processing any data access request.

9. Cookies Policy

Our website and mobile application uses cookies and similar technologies — small files or scripts stored on your device — to provide a customised experience. These technologies cannot access personal data stored on your device unless you provide it. You may browse most of our platforms without accepting cookies, although some functionality may be limited. Most browsers and mobile devices allow you to manage cookie preferences. The following types of cookies and tracking technologies are used:

9.1 Performance cookies

These cookies collect anonymous data on how users interact with our platforms, such as frequently visited pages and error messages. This information is aggregated and used solely to improve site performance.

9.2 Targeting or Advertising cookies

These include third-party advertising and retargeting technologies which help track the effectiveness of our marketing efforts. From time-to-time, third parties track and analyse usage and volume information from individuals who are referred to the site from ads. Third-party advertising networks may collect IP addresses and other information from web beacons, emails, and on third-party websites, in order to provide advertisements about products and services tailored to your interests. You may see these advertisements on other sites.

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