1. Definitions
   1. In the Terms and Conditions, the following words shall have the meaning respectively ascribed to them:
      • '[WOL]' means [Wisdom Living Limited] .
      • 'Program' means the [Ontolo Monthly Marketing Awareness Rewards Program].
      • 'Promotion Period' means the promotion period of the Program, as may be shortened or extended by WOL from time to time.
      • 'Participants' means Referrer and/or Referee (as the case may be).
      • 'Points' means the points stored in the Referrer's account under the Program.
      • 'Referrer' means any person who has agreed to participate in the Program, accepted the Terms and Conditions, and completed the registration procedures of the Program.
      • 'Referee' means any person who has been referred to participate in the Program by a Referrer.
      • 'Rewards' means the goods, products, services, coupons, offers, etc. specified by WOL from time to time for the Program, for which a Referrer may redeem by using certain number of Points specified by WOL from time to time in accordance with the Terms and Conditions.
      • 'Tasks' means the tasks specified by WOL from time to time for the Program.
      • 'Terms and Conditions' means the terms and conditions of the Program, as may be amended, revised, deleted and supplemented by WOL from time to time.
      • 'Website' means the website maintained by WOL for the Program (i.e. http://Beyondjustrewards.wisdomofliving.com).
2. Promotion Period
   1. The Promotion Period is from 9 September 2020 (12:00noon) to 10 October 2020 (12:00am).
   2. WOL reserves the absolute right to shorten or extend the Promotion Period, and to alter, revise, cancel or suspend the Program from time to time without any prior notice and liability to any Participant.
3. Eligibility
   1. WOL has absolute discretion to determine the eligibility of a Participant to participate in, or his entitlement to use, the Program.
   2. The employees of WOL and its affiliated companies or any person who is under the age of 18 shall not, participate in, or be entitled to use, the Program.
   3. The Referrer and the Referee shall not be the same person.
4. How to earn Points
   1. Referrer can gain Points through completing the Tasks together with Referee. For details, Referrer may refer to the Website.
   2. A Referee referred by the Referrer must also complete the registration procedures of the Program to the satisfaction of WOL.
   3. All Points cannot be transferred or assigned to any third party and are neither refundable nor exchangeable for cash nor refund for whatever reason.
   4. Participation in the Program is subject to there being no abuse/non-compliance by the Referrers and/or Referees as finally determined by WOL in its sole discretion, otherwise WOL will deduct the Points without notice and/or take action to reclaim the redeemed Rewards.
   5. WOL has the absolute right to change, update, and amend Point earning mechanism without prior notice. WOL may timely review Point earning mechanism.
   6. In the event that the Referrer's account or Points is lost or stolen, WOL will not be responsible or liable for the loss of Points, or Rewards or related benefits or entitlements.
   7. Points cannot be transferred or for sale or exchanged for cash, discount and /or in kind unless expressed in any specific redemption activity.
   8. Any sale or barter of Points or Rewards or other related benefits or entitlements by the Referrer is prohibited and will result in the forfeiture of all Points or Rewards or related benefits or entitlements and the termination of user right. Referrer shall indemnify and hold WOL and the merchants harmless from any liability and claims resulting from selling or bartering of Points or Rewards or other related benefits or entitlements.
   9. Referrer who engages in fraudulent activity or conduct to obtain Points or Rewards or related benefits or entitlements will result in immediate cancellation or suspension of all related Points or Rewards or related benefits or entitlements without prior notice.
   10. Points are only valid for accumulation during a calendar month in which the Points are gained. All Participants’ Points balances will be reset to zero in the beginning of each calendar month during the Promotion Period. No restoration of Point or extension of expiry date will be allowed.
   11. WOL reserves the right in its sole discretion to change, suspend or terminate the Points and the terms at any time without prior notice.
5. Redeeming Rewards
   1. There are different types of Rewards that can be redeemed based on different Tasks. There are primarily two types of Rewards that can be redeemed on a weekly basis and on a calendar monthly basis.
   2. Rewards can be redeemed on a first come, first served basis and in accordance with the terms and conditions set out in the Website.
   3. Rewards available for redemption would be displayed in the Website.
   4. Each Reward is subject to its respective terms and conditions.
   5. For weekly Rewards: the Referrer can automatically redeem the weekly Rewards that are available and displayed in the Website upon completing the relevant Tasks displayed in the Website. Once the Referrer has redeemed his/her Rewards, no alteration or cancellation is allowed.
   6. For calendar monthly Rewards, the Rewards redemption is calculated using Points. Referrer who has accumulated the most amount of Points in a calendar month during the Promotion Period can redeem the calendar monthly Rewards that are available and displayed in the Website. Once the Referrer has redeemed his/her Rewards, no alteration or cancellation is allowed.
   7. Reward will be delivered to the relevant Referrer by either of the following methods after the redemption transaction has been confirmed:
      • By Post - Reward will be mailed to Referrer's correspondence address within 60 working days after receiving Referrer's request to redeem.
      • Electronic – E-coupons will be stored in the Referrer's account. Referrer can present the E-coupon in to claim the Rewards at designated collection points. If Referrer loses his/her coupon, WOL will not take any responsibility for this, any claim of the coupons, payment or compensation. No return or restoration of Points used for redeeming the coupons is allowed.
   8. If Referrer fails to satisfy the eligibility requirement of the Program, WOL will not be responsible for any obligation, claim, payment or compensation arising out of or resulting from the disqualification or forfeiture. No return or restoration of Points used for redeeming the Reward is allowed.
   9. Rewards cannot be changed, refunded, resold, and/or exchanged for cash. No refund, replacement and compensation will be allowed for any unused Reward and/or entitlement and/or loss or damage of Reward.
   10. WOL reserves the right to change, suspend or terminate any redemption and its mechanism and terms at its sole discretion at any time without prior notice and compensation.
   11. WOL is not supplier of any products, goods or services of the Rewards. The respective suppliers are solely responsible for all obligations and liabilities in relation to the relevant products, goods or services.
   12. To the extent permitted by law, WOL accepts no responsibility for, nor does WOL guarantees defect-free, complete, accurate, or timely of any product, goods and services of the Rewards. Participants are at their sole discretion to use or try the products, goods and services of the Rewards at their own risk for any damage and loss arising out of or resulting from usage or trial of such product, goods and services at any time or under any circumstances. WOL takes no liability for any defect or deficiency in any such products, goods and services.
   13. Redemption of goods, products, services, vouchers, coupons or other benefits and entitlements at a participating merchant is subject to the merchant's policy and the terms and conditions specified by the merchant.
6. Referrer's Responsibilities
   1. Referrer must ensure that all information provided should be true, accurate, complete, updated and not misleading without any omission of material aspects, and promptly keep the information true, accurate , complete,  updated and not misleadingwithout any omission on material aspects and fraud on submission of information, or false submission of information of others. Referrer shall be responsible for any loss, damage or liability arising out of or in connection with any fraud on submission of information, or false submission of information of others, and indemnify and hold WOL and the relevant party harmless for any loss, damage, claim arising out of or in connection with any fraud on submission of information, or false submission of information of others.
   2. Referrer agrees to indemnify, defend, and hold harmless WOL, and its parent, affiliates, directors, officers, employees and agents from and against any claim, liability, cost, damage or loss WOL may incur (including, without limitation, legal fees) as a result any violation by Referrer of his/her obligations under the Terms and Conditions.
7. Termination
   1. If Referrer provides any information that is untrue, inaccurate, misleading or with material aspect(s) omitted, or WOL has reasonable grounds to suspect that such information is untrue, inaccurate, misleading or with material aspect(s) omitted, WOL has the absolute right to suspend or terminate the Referrer's participation or use of the Program and to cancel any related benefits and entitlements and the Referrer will not be entitled to all current or future participation or use of the Program (or any portion thereof).
   2. WOL may at its sole discretion to suspend or terminate the Referrer’s participation and use of, the Program and to cancel the Referrer’s any related benefits and entitlements if the Referrer commits misconduct, fraud, misuses of the Program benefits and offers in any way with unacceptable content (including any content that incites hatred or discrimination, whether racial, social or political, or any unlawful, harmful, threating, abusive, harassing, tortuous, defamatory or otherwise objectionable content), or fail to comply with the Terms and Conditions.
   3. WOL may terminate any Participant's participation and any use of the Program immediately without prior notice if it is of the reasonable opinion that the Participant has already violated the Terms and Conditions.
   4. WOL may, at its absolute discretion, terminate or suspend this Program or any part thereof, without prior notice. In the event that the Program or any part thereof is terminated or suspended under this clause, WOL will terminate or delete all Participants' accounts under the Program and all related information immediately.
   5. In the event that any termination or suspension made under the Terms and Conditions, all Points and related benefits and entitlements (both current and unused) will be cancelled without compensation.
8. Disclaimers
   1. Nothing in the Program shall constitute or shall be regarded as any sale or offer to sale of any immovable properties.
   2. Participant agrees that under no circumstances shall WOL be liable for any direct, indirect, incidental or any other type of loss or injury resulting from Participant's use or downloading of any content on the Website. This includes, but is not limited to, loss or injury caused in whole or in part by WOL's negligence or by contingencies beyond WOL's control in creating or delivering any portion of the contents on the Website.
   3. Nothing in the Terms and Conditions excludes or limits WOL’s liability for (i) death or personal injury caused by its proven negligence or that of its employees and agents; (ii) fraud or fraudulent misrepresentation (if any) by its employees or agents; or (iii) any other liability that, by law, may not be limited or excluded. Subject to the foregoing, WOL, its employees, agents, parent and affiliates will not be liable for any economic loss including without limitation loss of profits or anticipated savings, or any special, indirect, consequential or exemplary losses a Participant may incur.
   4. WOL shall not be responsible for any matters or disputes relating to the offers, promotional discount goods, products or services provided by the respective merchants under any circumstance.
   5. If, for any reason, WOL is not capable of conducting or implementing the Program as planned, including due to infection by computer virus, bugs, tampering, unauthorised intervention, fraud, technical failure or any other causes beyond the control of WOL, which corrupt or affect the administration security, fairness or integrity or proper conduct of the Program, WOL reserves the right in its sole discretion to take any action that may be available and appropriate.
9. Miscellaneous
   1. Participants are bound by the Terms and Condition.
   2. WOL reserves the right of final decision relating to any dispute arising from the Program, the Rewards, the Points and/or the Terms and Conditions.
   3. WOL has the absolute right to amend, revise, delete or supplement any of the Terms and Conditions in its sole discretion, and to change, suspend or terminate the Program at any time without giving prior notice to the Participant in its sole discretion.
   4. Except as otherwise expressly stated in the Terms and Conditions, no person who is not a party to the Terms and Conditions shall have any rights under the Contracts (Rights of Third Parties) Ordinance (Cap. 623) of Hong Kong to enforce any term of the Terms and Conditions.
   5. If any provision of the Terms and Conditions shall be held to be illegal, void, invalid or unenforceable under the laws of Hong Kong, the legality, validity and enforceability of the remainder of the Terms and Conditions in Hong Kong shall not be affected.
   6. The English version of the Terms and Conditions shall prevail wherever there is a discrepancy between the English and the Chinese versions.
   7. The Terms and Conditions are governed by and construed in accordance with the laws of Hong Kong.

DISCLAIMER

Your use of this Wisdom Living Limited website ("Site") is subject to the following terms and conditions.

1. The contents of this Site are for your general information only. No representation or warranty (express or implied) is given with regard to their accuracy, completeness, reliability and suitability. No information on this Site shall constitute an invitation to invest in Wisdom Living Limited or an advice of whatever nature. Neither Great Eagle Group (as defined below), Wisdom Living Limited nor any directors, agents or employees of any member of Great Eagle Group shall be liable for any loss, damage or expense arising out of or in connection with the contents or use of this Site, including any loss of profit.
2. Both Great Eagle Holdings Limited and its subsidiaries (which include Wisdom Living Limited) (collectively, “Great Eagle Group”) make no representation on the information provided by any other websites, which may be accessed through this Site, and expressly disclaims any liability for any loss, damage or expense, arising from the use of or in reliance upon any part of the contents contained in such sites. The inclusion of any link to other websites does not necessarily imply Great Eagle Group’s or Wisdom Living Limited’s recommendation or endorsement of the views expressed therein.
3. This Site may contain materials in which third parties have proprietary rights, including without limitation logos or brand names, which are the trademarks of third parties. Both Great Eagle Group and Wisdom Living Limited grant no license regarding their use and disclaims any liability with regard to infringement of any third party rights.
4. Unless otherwise stated, the contents of this Site are subject to the copyright of, and may not be reproduced without the approval of, Great Eagle Holdings Limited, except that you may reproduce extracts by printing or downloading to a hard disk from this Site for non-commercial, informational and personal uses only. However, none of the contents of this Site may be copied or otherwise incorporated into or stored on or in any other website, electronic retrieval system, publication or other work in any form (whether hard copy, electronic or other). No links to this Site may be included in any other website without the written authorization from Great Eagle Holdings Limited.

PRIVACY POLICY

1. Our Commitment to Protect Your Privacy
   1. We are committed to safeguard your personal and data privacy. To ensure that you can make informed decisions and feel confident about sharing certain personal information with us, please read this Privacy Policy to understand whom we share your personal data with and for what purpose, and the choices you have concerning how your personal data are collected and used by us. By providing personal information to us, you agree and consent to the collection, use, disclosure, transfer and retention of your personal information as outlined in this Privacy Policy.
   2. This Privacy Policy will be continuously assessed against new technologies, business practices, compliance requirements and your needs. As we update and diversify our products, services and businesses, this Privacy Policy may evolve from time to time. We reserve the right, at our discretion, to change, modify, add or remove any parts from this policy at any time without any prior notice. You are encouraged to review this Privacy Policy from time to time for updates periodically. Your continued use of the Services after such revisions are posted means you elect to accept these changes.
   3. Certain personal data are required for specific services and if you fail to supply such personal data as requested from each specific service, we may be unable to provide you the services in full.
   4. If you are under the age of 18, consent from your parent or guardian is required before you provide us with any personal data.
   5. If you are a citizen of the European Union (EU) or European Economic Area (EEA) and are using our Services, we will maintain your personal data as outlined in the GDPR Addendum of this Privacy Policy 
2. Introduction
   1. This Privacy Policy described how Great Eagle Holdings Limited (“Great Eagle”) and its subsidiaries (collectively, “Great Eagle Group”, “we”, “us” or “our”) collect, use and process information you provide on the websites or social media platforms managed and operated by us or our affiliates (the “Site”), our mobile applications (the “App”), the services available through our Site and App, and when you are entering into a contractual or investment relationship with us or our affiliates (collectively, the “Services”). It covers personal data shared by you through our Services, including personally identifiable information and anonymous information.
   2. This policy serves also as the guidelines to be observed by all business divisions operated and/or managed by Great Eagle Group and its affiliates.
3. Collection of personal data
   1. Information you voluntarily provide to us when you sign up for and use the Services - We will collect some personal data from you directly. The provision of personal data to us is on a voluntary basis. If you fail to provide sufficient information, we may not be able to provide relevant Services. If you provide us with information about other individuals, you should have already obtain authorisation from those individuals and let them know where they can find a copy of this Privacy Policy. We collect personal data (including where applicable sensitive personal data) you provide directly to us. By virtue of your provision of personal data, you consent to such personal data being collected, used, disclosed, transferred, and retained by us as described in this Privacy Policy. Subject to circumstances, this type of information may include:
      1. your personal information such as your first name/last name, title, contact details (e.g. mobile phone number, physical address and e-mail address), gender, occupation, location, job title, billing information, purchase history and other demographic information;
      2. username and password that you will use to access to our Services;
      3. a record of any interactions and correspondence between us such as email, telephone, mobile short messaging service (SMS), multimedia messaging services (MMS), cross-platform mobile messaging application (e.g. smartphone messaging application) or postal correspondence, any interactions you have with our staff or representatives and any interactions with us or posts that refer to us on social media;
      4. information that we collect about your interests, preferences and opinions;
      5. your feedback, opinions about our Services and your responses to market surveys and contests conducted by us;
      6. information collected through the use of closed circuit television systems and other security systems;
      7. any other personal data you choose to provide to us; and
      8. for investor or shareholder of any of the listed platformsNote(1) controlled or managed by us, your full name, postal address, percentage of share and vote, other personal data strictly in connection with the investment and, if appropriate, copy of your identification document, either directly from you or from the share registrars and transfer offices of these listed platforms. Note (1) They include Great Eagle Holdings Limited (Hong Kong Stock Exchange (“HKEx”) Stock Code: 41), Champion Real Estate Investment Trust (HKEx Stock Code: 2778) or Langham Hospitality Investment and Langham Hospitality Investments Limited (HKEx Stock Code: 1270).
   2. Information we collect automatically when you use our Services - When you access or use our Services, we automatically collect information about your visit to our Sites, your usage of our Services and your web browsing. That information may include your IP address, your operating system, your browser ID, your browsing activity, and other information about how you interacted with our Site and other websites. We may collect this information as a part of log files as well as through the use of cookies or other tracking technologies. Cookies used in any part of our Site will not be deployed for collecting personal data. For your information, Cookies are small computer files that can be stored in web surfers’ computers for the purposes of obtaining configuration information and analysing web surfers' viewing habits. They can save you from registering again when re-visiting a website and are commonly used to track your preferences in relation to the subject matter of the website. You may refuse to accept Cookies by modifying the relevant internet options or browsing preference of your computer system, but to do so you may not be able to utilise or activate certain available functions in our websites. Our Site may bar users who do not accept Cookies.
   3. Information from your use of the Services – We may receive information about how and when you use the Services, store it in log files or other types of files associated with your account, and link it to other information we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the application. This type of information helps us to improve our Services.
   4. Information from other sources – We may, from time to time, collect other personal data from third parties including: (a) our service providers and agents; (b) the third parties that we partner with in connection with us; (c) our third party joint marketing and research partners; (d) providers of third party websites, apps and social media platforms; and (e) public databases. Examples of the information we may receive from other sources include demographic information, company information, device information, location, and online behavioural data. We use this information, alone or in combination with other information (including personal information) we collect, to enhance our ability to provide relevant marketing and content to you and to develop and provide you with more relevant products features, and services.
4. Purposes for Collection and Use of personal data
   1. Our primary purpose in collecting personal data from you is to give you an enjoyable customised experience. Specifically, we may use data for the following purposes:
      1. to administer and provide our Services to you (including identity verification, system security and maintenance, billing and payment) and to fulfil our obligations to you;
      2. to tailor and personalise services which may be of interest to you;
      3. to provide customer support and to improve the efficiency and quality of our Services;
      4. for marketing and promotion purpose, subject to your rights to opt-in and optout of receiving certain marketing communications. For example, membership clubs, loyal and reward programmes and redemption of shopping/dinning privileges or offers of us or our affiliates. For more details on marketing, please see Section 6 below;
      5. for internal record keeping of information of our tenants, customers, employees, consultants, contractors, investors, shareholders, other service providers, business transactions and communications;
      6. to enable us to contact and interact with you whether online or otherwise in connection with our Services or marketing campaigns, promotion programmes or other offerings;
      7. for improvement of customer services and staff training;
      8. for designing new and/or enhancing our existing services, products and activities;
      9. for managing and providing for the safety and security of our guests, customers, visitors, employees or users;
      10. to protect or comply with our legal rights and obligations and to prevent, detect and investigate wrongdoing or crime and analyse and manage any risks or irregularities; and
      11. for any other purposes incidental to the above and for any other purpose to which you may from time to time agree.
   2. To fulfil the above purposes, you may be contacted via email, telephone, mobile short messaging service (SMS), multimedia messaging services (MMS), cross-platform mobile messaging application (e.g. smartphone messaging application), mail or other means that are allowed by local authorities.
   3. We may also from time to time use aggregate non-identifying information about our customers to better design our Site and/or to improve our Services. This means we may provide this information to third parties. This type of data may include, but is not limited to, the browser type and version, operating system, IP address and/or domain name. However, this information will never identify any single member of the programme in particular.
5. Who We Share Your personal data with
   1. We may disclose and transfer personal data to and use personal data with our service providers, and other persons who we consider appropriate, in connection with our services and products provided to or requested by you. We may disclose this information to facilitate communication of news and information about such services and products and otherwise for the purposes mentioned above, under the section 4 above.
   2. The entities with whom we may share your personal data include but are not limited to any agent, contractor or third party service provider who provides administrative, marketing and research, data processing, telecommunications, computer or other services to us and/or our affiliates.
   3. We may disclose your personal data to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products and services. Subject to obtaining appropriate consent from you, we may also disclose your personal data to our third party marketing partners in order that they may market their products and services to you.
   4. We may disclose your personal data to governments and regulatory authorities and bodies and to other individuals, bodies and organisations such as dispute resolution, prosecution and law enforcement agencies, regulatory bodies and/or legal advisers for compliance with applicable laws, rules, regulations, codes, and/or guidelines and/or any person or entity to whom we are under a binding obligation to make disclosure under the requirements of any law, rule, regulation, code and/or guideline and/or order of any competent court of law, law enforcement agencies and/or regulatory bodies, but such disclosure will only be made under proper authority.
   5. We will permit our third party service providers, including agents, contractors and our affiliates, to use your personal data on our behalf for the purposes set out in section above. Example of such third parties include our contractors under a duty of confidentiality to us who provide administrative, telecommunications, computer, data processing or other services to us in connection with management, operation and maintenance of the system and our data center in or outside Hong Kong.
   6. We may also transfer any information we have about you that may be considered as an “asset” in connection with a merger or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or any part of Great Eagle Group or as part of a corporate reorganisation or stock sale or other change in corporate control.
6. Marketing
   1. We may use your personal data for marketing and promotional purposes, including (a) for sending or showing you updates on latest news, offers and promotions in connection with our products and services; (b) for sending or showing you joint marketing offers, events and promotions; or (c) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our Site.
   2. We may also use personal data to analyse our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products, offers and services that we present to you. This may involve us combining personal data that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about other customers in order to derive these insights and establish market trends. We may provide these insights to our third party partners for their marketing and promotional purposes. We also use advertising services and products provided by third party service providers (such as marketing agencies and social media platforms) for marketing and promotional purposes, which may involve us sharing personal data that we hold about you with them.
   3. We may communicate marketing and promotions to you by email, telephone, mobile short messaging service (SMS), multimedia messaging services (MMS), cross-platform mobile messaging application (e.g. smartphone messaging application), mobile application or online (including via internet banner advertisement and links) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.
   4. We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us as set out in section 8 below.
   5. Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about the Services we provide to you.
7. Transmission, Storage and Security of Your personal data
   1. Security - No data transmission over the Internet, a website, mobile application or via email or other message service or by mail can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic and procedural safeguards to protect your personal data in accordance with the requirements of data protection legislation. All personal data we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your personal data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you.
   2. Exporting your personal data - Your personal data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.
   3. Retention period - To the extent permissible by applicable law, we generally only keep your information for as long as reasonably required for (a) the purposes for which that personal information was provided; (b) ongoing business need, including record keeping, fraud prevention, or if we reasonably believe there is a prospect of litigation; and (c) as necessary to meet legal, regulatory, tax or accounting needs. We take reasonable steps to safely and securely delete, dispose of, anonymise and/or block personal information when we no longer need it.
8. Your Rights and Contacting Us
   1. General rights - You have the right (subject to various exceptions and in accordance with data protection legislation in your country) to access certain personal data held about you and correct any inaccuracies by contacting our Data Protection Officer. We may charge a reasonable fee for the processing of any data access request. You also have the right to raise a complaint about our processing by contacting our Data Protection Officer.
   2. Right to opt out of direct marketing - You have the right to ask us not to process your personal data for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your personal data. You can also exercise the right at any time after we have collected and used your personal data for direct marketing purposes by (a) following the opt-out instructions contained in the relevant communications; or (b) contacting our Data Protection Officer.
   3. Right to refuse us to transfer or disclose their personal data to our contractors - You can exercise your right to refuse us to transfer or disclose your personal data to our contractors by contacting our Data Protection Officer at any time. Your personal data will be either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.
   4. Updating personal data - We will take reasonable steps to try to ensure that your personal data is accurate. You can update your personal data at any time by (a) mobile applications; or (b) contacting our Data Protection Officer.
   5. Contacting Data Protection Officer - You have the right to send your request to our Data Protection Officer at any time with any of the following methods to fulfil the above purposes set out in this section:
      • By email (please send your registered username (if applicable), name, email and mobile number to [email protected]); or
      • By post (please send your registered username (if applicable), name, email and mobile number to Data Protection Officer, 33rd Floor, Great Eagle Centre, 23 Harbour Road, Wanchai, Hong Kong).
   6. The English version of this Privacy Policy shall prevail wherever there is any inconsistency or conflict between the English and Chinese version.

Last updated on 12 September 2018

PRIVACY POLICY

GDPR Addendum

This Addendum applies in circumstances where the privacy practices of Great Eagle Holdings Limited (“Great Eagle”) and its subsidiaries (collectively, “Great Eagle Group”, “we”, “us” or “our”) are subject to the EU General Data Protection Regulation (“GDPR”). This will be the case if you are based in the European Economic Area (the EEA) during your interactions with us (other than where you are in the EEA solely for travel purposes).

This Addendum should be read in conjunction with the Privacy Policy of Great Eagle. In this Addendum, we set out further information on our processing activities and details of the rights which you have under the GDPR. We reserve the right, at our discretion, to change, modify, add, or remove any parts from this Addendum at any time. You are encouraged to review this Addendum from time to time for updates periodically. Your continued use of our Services after such revisions are posted means you elect to accept these changes.

1. Why We Collect Your Data the Legal Grounds for Processing
   1. We can collect personally identifiable information about you as more particularly described in section 3 of the Privacy Policy and the purposes for collection and use of these personal data are described in section 4 of the Privacy Policy.
   2. Personal data will only be processed if there is at least one lawful basis as follows:
      1. Consent – where you have given consent to the processing of your personal data for one or more specific purpose. You may withdraw your consent to the use of your personal data by contacting us as set out in section 8 of the Privacy Policy.
      2. Contract performance – where processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request subject prior to entering into a contract.
      3. Legal obligation – where we need to use your personal data to comply with our legal obligations. 1.2.4 Vital interests - where we need to process your personal data in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance.
      4. Public interest - where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
      5. Legitimate interests - where we have a legitimate interest in using your information. We will only rely on this legal ground if we consider that our interest in using your personal data for the relevant purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your personal data.
   3. Occasionally we will collect and handle sensitive personal data, for example, when we handle requests for special requirements relating to personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs and data concerning health. Where we process this category of data, this will be done only on any or more of the following basis:
      1. Consent – where you have given consent to the processing of your personal data for one or more specific purpose. By providing us with this information, you expressly consent to our use of your sensitive person information in accordance with this Privacy Policy. You may withdraw your consent to the use of your personal data by contacting us as set out in section 8 of the Privacy Policy.
      2. Vital interest - where we need to process your personal data in order to protect the vital interests of you or another natural person where you or the other person is physically or legally incapable of giving consent.
      3. Legal claims - where your personal data is necessary for us to establish, exercise or defend any legal claims.
      4. Substantial public interest - where we need to process your personal data for reasons of substantial public interest set out in EU law or the laws of the member state in which you are based.
      5. Public interest in area of public health - where we need to process your personal data for reasons of public interest in the area of public health, such as protecting against serious cross-border threats to health, set out in EU law or the laws of the member state in which you are based.
2. Children’s Data
   1. We do not collect personal data about children under the age of 16. In the event any personal data of children under the age of 16 were collected, we will delete the data when any individual contacts us in accordance with section 8 of the Privacy Policy.
   2. Individuals under the age of 18 must obtain the consent of an individual who holds parental responsibility for them prior to providing us with their personal data.
3. International Transfer
   1. Services on the internet are accessible globally so collection and transmission of person data is not always limited to one country. We may transfer your personal information we collect about you and your personal information may be stored and processed, in countries other than the country in which the information was originally collected that may have less stringent data protection laws than the country in which you initially provided the information. If and to the extent that we do so, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers. However, our collection, storage and use of your personal data will at all times continue to be governed by the Privacy Policy.
   2. By providing any personal information to us, you fully understand and unambiguously consent to the transfer and processing of such personal information. If you object to your personal information being transferred or used in this manner, please do not register with or use our Site and App.
4. Retention Periods
   1. We only retain the personal data collected from you for as long as your account is active or otherwise for a limited period as long as we need it to fulfil the purposes for which we have initially collected it, unless otherwise required by law. We will retain and use information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
5. Your Rights and Contacting Us
   1. the following rights, which apply in certain circumstances and subject to certain restriction, in relation to your personal data:
      1. the right to access your personal data;
      2. the right to request the rectification and/or erasure of your personal data;
      3. the right to restrict the use of your personal data;
      4. the right to object to the processing of your personal data;
      5. where our processing of personal data is based on you having provided your consent or the processing is necessary for the performance of a contract with you, you have the right to receive your personal data, which you provided to us, in a structured, commonly used and machine-readable format or to require us to transmit that data to another controller; and
      6. 1where our processing of your personal data is based on you having provided consent, the right to withdraw your consent to the processing at any time.
   2. If you wish to exercise any of the rights set out above or if you have any questions about this GDPR Addendum, please contact us directly at [email protected].

Last updated on 12 September 2018