Privacy Policy

Governing Law and Disputes

We recognize the importance of your privacy and maintaining the confidentiality of your personal information. This Privacy Policy applies to all products and services provided by us and sets out how we may collect, use and disclose your personal information. This Privacy Policy is governed by and observes the requirements of the Personal Data (Privacy) Ordinance (cap.486).

 

Who We Disclose Personal Information To

We will only disclose your personal information in the following circumstances, except as permitted or required by applicable law:

1. From one affiliate to another affiliate to allow affiliates to offer their products and services to you;

2. To our partners and other third-party suppliers, as necessary to provide you with services that you have requested or to fulfill the transactions you have submitted;

3. To third party companies and contractors that provide us with services in the conduct of our business (‘service providers’), such as payment processing services, information technology services for our software applications, advertising, marketing and survey services and other essential similar services, but only as necessary for those service providers to provide services to us;

4. To third parties as we deem necessary or appropriate to prevent, limit or otherwise prosecute fraud;

5. As necessary to meet legal and regulatory requirements;

6. Any other circumstance in which you provide consent to disclose.

 

Service Providers

All service providers are contractually bound to keep your information secure. Our service providers can use, store and disclose your personal information solely for purposes.

 

Business Transactions

We may use and disclose your personal information in connection with the proposed or actual financing, safe or other business transaction involving part or all of our business or assets. Such use and disclosure would be for the purpose of allowing third parties to determine whether to proceed with the proposed transaction, and if the transaction proceeds, for the purpose of completing the transaction. Assignees or successors to our business or assets may use and disclose your personal information for the purposes described in this policy.

 

Accuracy of Your Personal information

We will use commercially reasonable efforts to ensure that your personal information is correct, complete and up-to-date to the extent we are notified of any changes by you. You can review and update your personal information on our sites. You can assist by keeping us informed of any changes, or informing us if you find any errors in our information about you. If we have disclosed inaccurate information about you to a third party that you are aware of, we would be pleased to contact the third party in order to correct the information upon your request.

 

Security and Safety

All reasonable efforts are made to ensure that any personal data held by us is stored in a secure safe place, and accessed only by our authorized employees or Third Party Service Providers.

You should be aware that no system is impenetrable and no information provided over the internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the internet.

We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, authorized disclosure of, or access to your Personal Data.

The program’s website may contain hyperlinks to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites. Once you have left our platform, we cannot be responsible for the protection and privacy of any information which you provide. You should exercise caution and look at the privacy statement for the website(s) you visit.

 

Links to Third Party

We may provide links or references to third party sites whose privacy may differ from those of Key Points Exchange Limited. You may redirect to a site through a link from a partner or other third party site. Key Points Exchange Limited assumes no responsibility for the content or the privacy policies of those partner or third party websites. Please be aware that when you follow any links to another site not owned or operated by Key Points Exchange Limited and submit personal information to any of those sites, you are subject to their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

 

Social Media Features

Our sites include social media features, such as the Facebook button and widgets. These features may collect your IP address, track which page you visit on our site, and may set cookies to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly by our sites. Your interactions with these features are governed by the privacy policy of the company providing it. We encourage you to carefully read the privacy policy of any company that provides the features you choose to interact with.

 

Browsing information collected from you(Cookies)

We use cookies and similar technologies to collect data about you when you visit the Program’s Website and other of our related websites (“Sites”). Cookies are files that store information on your computer hard drive or browser, that means that we can recognise that you have visited our Sites before. We use cookies to give you the best possible experience on our Sites, by evaluating the use of our Sites and reviewing your browsing and shopping habits, personalizing your website experience, evaluating website activity on our Sites and generally making our Sites easier to use.

The types of data we may collect from you when you visit the Sites include: 

1. Information about the type of browser you use; 

2. Details of the web pages you have viewed; 

3. Your IP address;

4. The hyperlinks you have clicked; and

5. The websites you visited before arriving at our page.

You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but to do so you may not be able to utilize or activate all of the functions and services on our Sites. 

 

The Personal Data We Collect

We will collect and process some or all of the following personal data about you :

1. (a) Information about you and your membership :
   Your personal information such as your name, gender, date of birth, nationality, contact details, travel document, your membership number, your username and records of your earning and redemption activities, and details about your redemption group nominees, your parents’/guardian’s names and contact details, photographs and other images, seat and meal preferences, and any information relating to any special assistance that you require from airline partners such as dietary requirements or health issues; 

2. (b) Your payment details :
   Payment details used to redeem awards such as card holder name, credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information;

3. (c) Information we collect in relation to your earning of points :
   Information about your earning of points with our programme partners such as airlines, hotel operators, providers of other travel-related services, finance and insurance partners, restaurants and retailers;

4. (d) Information we collect in relation to your redemption of travel and lifestyle awards :
   Information about your redemption of awards, including your travel itinerary, hotel selection, car rental and other travel-related services, details of your travel companions or persons assisting you, and your choice of other lifestyle and experience awards e.g. events or concerts;

5. (e) Your interests, preferences, habits and opinions :
   Information that we collect about your interests, preferences, habits and opinions, such as your hobbies, destinations and awards including products, services and events you are interested in, your opinion on our offers, your feedback and satisfaction scores regarding your redemption experiences;

6. (f) Our interactions with you :
   Interactions and correspondence between us such as calls made through our call centre, interactions you have with our staff or representatives will be recorded for research (e.g. conversations with research interviewer), and non-research (e.g. Key Points Exchange Limited events) purposes and posts that refer to us on social media;

7. (g) Survey information :
   Your responses to surveys, research and contests (for examples stories, photos, ideas, etc.) conducted by us or on our behalf; and

8. (h) Your use of our website, mobile applications and social media platforms :
   Details of your visit to our website, your use of social media platforms and our mobile applications and other information collected through cookies and other tracking technology including information that you look at. We may also collect information about you that is publicly available online, including your social media profiles.

The services and lifestyle rewards we provide, mostly require certain types of your personal information (especially your payment details, contact information, comprises with receiving address and the details of your travel documents when redeeming certain flight tickets) ; if you failed to provide the required personal information for specific services, we may not be able to send you a full redemption award.