INTRODUCTION

Hong Kong Air Cargo Carrier Limited (“HKC” or the “Company”) recognises the importance of personal and data privacy of its customers and treats all personal and private data provided to us as confidential. We are committed to fully implementing and complying with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong (the “Ordinance”) and, where possible, internationally recognised standards of Personal Data privacy protection.

APPLICATION OF THIS STATEMENT

The term “Personal Data” in this Statement refers to personal data which is capable of identifying you as an individual, as defined in the Ordinance. This Privacy Statement (the “Statement”) applies to all Personal Data and information regarding HKC passengers, users of the HKC mobile application, users of HKC services, customers who purchase or accept the Company’s goods and services, as well as visitors to the hkaircargo.com website.

This Statement gives effect to HKC’s policy to protect customers’ personal information and has been adopted by the Company and its subsidiaries and representative offices. References to “HKC”, “we”, “our” and “us” hereinafter, depending on the context, collectively refer to those entities. Nothing in this Statement shall limit the rights of the Data Subjects under the Ordinance.

HOW WE COLLECT PERSONAL DATA

We may collect a variety of Personal Data depending on how you interact with us, including but not limited to our website, mobile application or our services. These Personal Data can be collected using different methodologies.  We will collect and process some or all Personal Data:

• from you directly;
• from third parties, including but not limited to:

1. 1. 1. the third parties that we partner with in connection with us, including but not limited to other airlines, providers travel-related services, finance and insurance partners, etc;
      2. travel agents and/or other persons that interact with us on your behalf;
      3. our business partners;
      4. our third party marketing and research partners;
      5. organisations which conduct credit and fraud checks;
      6. airport authorities, immigration, customs, border security, law enforcement bodies and other government or regulatory bodies; and
      7. providers of third party websites, applications and social media platforms.

• Automated technologies or interactions. When you use our website, mobile application or our services, we may collect certain technical data and information about your computing system and browsing activity. This data is gathered by employing cookies and related tools.

COLLECTION AND USE OF PERSONAL DATA

Prior to collecting Personal Data, you will be asked to voluntarily supply the information we need in order to provide the particular service requested. Personal Data may be collected, used, disclosed and retained to:

• To provide products and services to you;
• Administer, process and/or confirm your freight reservations and other transactions with us;
• verify and/or confirm your identity, and/or to improve our safety and security measurement;
• facilitate your participation in loyalty programmes and travel partner programmes;
• accommodate special requests and provide a more personalised level of service;
• respond to requests for information and services;
• facilitate communications;
• To improve product and service;
• conduct market research, market analysis and quality assurance surveys;
• facilitate marketing and direct marketing;
• Process any job, student internship or scholarship application;
• facilitate matching with other Personal Data;
• prevent illegal activity or to protect our legitimate right and interests;
• carry out anti-money laundering and sanctions checks;
• To ensure the safety and security of all parties, as well as to undertake any necessary activities during emergency events;
• comply with any law, legal or regulatory requirement; or
• comply with governmental, judicial or administrative direction or order.

TYPE OF PERSONAL DATA WE COLLECT

The types of Personal Data that we process include:

• your personal details and contact information;
• your credit card details, loyalty program membership information and online user account details, profile and password details;
• any information necessary to fulfil special requests ;
• information relating to the credit of customers;
• your reviews and opinions about our services;
• activity record of HKC website visits and usage patterns.

DISCLOSURES AND TRANSFER OF YOUR PERSONAL INFORMATION

In providing services to you, it may be necessary for HKC to disclose, transfer, use, process and store your Personal Data to/at our offices, affiliates, operations,  shippment related companies and business partners worldwide. This may be necessary to provide administrative, booking, telecommunications, payment and other services to facilitate your requests and to provide services you require.

In accordance with the Personal Data (Privacy) Ordinance, HKC takes all reasonable steps to ensure third-party service providers protect the personal data entrusted to it and use it for purposes only as specified by HKC.

HKC reserves the right to disclose any Personal Data and information we hold on you if we:

• are compelled to do so by a court of law;
• are requested to do so by a governmental entity;
• determine it is necessary or desirable to comply with the law;
• determine it is necessary or desirable in providing services and facilities to you.

We also reserve the right to retain information collected and to process such information to comply with accounting and tax rules and regulations, as well as, for safety and security assessment as HKC may deem necessary.

We may share aggregated demographic information with business partners, affiliates or other entities.  This aggregate information is not linked or traceable to any personally identifiable information about you.

MARKETING AND DIRECT MARKETING

HKC intends to use your Personal Data (including your name, address, contact numbers, and email addresses) to send you marketing communications in the form of postal mail, email, telephone call and SMS containing news, offers, promotions, and events to be offered by us or by our business partners.

We will not use your personal information for direct marketing without your consent. You may opt out of receiving marketing communications at any time by writing to us at the address provided in the ‘How to Access or Correct Your Personal Information’ section of this document.

ENSURING THE SECURITY OF PERSONAL DATA

HKC retains Personal Data collected for as long as it may be necessary to fulfil the purpose (including any directly related purpose) which the information was initially collected for.

To maintain the accuracy of your Personal Data, as well as preventing unauthorised access to and ensuring the correct use of your Personal Data, we carry out appropriate physical, technical and administrative protective measures to control and safeguard the collection, access and disposal of the Personal Data we collect. These measures are subject to ongoing review and monitoring. Whilst we make every effort to protect your Personal Data, no security measures can guarantee that your Personal Data and information will not be subject to interference, misuse or hacking. HKC shall not be responsible for any loss, misuse or alteration arising as a result of such incidents.

LINKS TO THIRD PARTY SITES

The HKC website may contain links that direct users to third-party sites that are not owned or managed by HKC. Personal Data submitted to or obtained by third parties will not be protected by this Statement. HKC shall not be responsible for any loss, misuse, or alteration arising from access to any third-party-operated sites.

HOW TO ACCESS OR CORRECT YOUR PERSONAL INFORMATION

You are entitled to access, correct or delete any Personal Data relating to your profile held on our database.

Your access to or correction of Personal Data must be submitted in writing and addressed to:

The Data Protection Officer
Hong Kong Air Cargo Carrier Limited
3007-11, 30/F, CDW Building,
388 Castle Peak Road – Tsuen Wan, Tsuen Wan,
New Territories, Hong Kong

When submitting your request, please include your full name, address, and contact number so we can ascertain your identity and address your enquiry. HKC reserves the right to charge a fee to recover the costs and expenses involved in complying with your data access request.

COOKIES

Some of our webpages may use ‘cookies’ to enhance customers’ experience on our website. Cookies are small pieces of information transmitted from our web server and automatically stored on your computer’s browser to record your preferences.

We also use cookies to understand site usage for our own research purposes. Most web browsers automatically accept cookies. You may choose not to accept cookies by changing your browser settings to block them, but if you do so you may find that certain features on the HKC website will not work properly.

MISCELLANEOUS

This Statement may be modified from time to time. Any changes to this  Statement will become effective upon posting of the revised  Statement on the HKC website. Use of the HKC website following such changes constitutes your acceptance of the revised  Statement that is then in effect.

This Statement is governed by and shall be construed in accordance with the laws of the Hong Kong Special Administrative Region.

This Statement is written in English and may be translated into other languages. In the event of any inconsistency, the English version shall prevail.