Types of Personal Data We Collect
Infinite Rainbow Limited, at 28/F, Kerry Centre, 683 King’s Road, Quarry Bay, the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong
”) is responsible for using your personal data. For any questions concerning your personal data or other general inquiries, you can contact our customer service team at email@example.com
Information you provide to us: we collect personal data (including where applicable sensitive personal data) you provide directly to us. This includes:
- your full name and contact information (e.g. country of residence, physical address (delivery and billing), email address and phone number);
- your credit card, mobile payment and other payment details;
- your Golden Circle membership information, account details, profile or password details;
- any information necessary to fulfill special requests (for example, leisure, travel and guest preferences);
- your reviews, feedback and opinions about our products and services provided on Shangri-La Boutique; and
- any other personal data you choose to provide to us.
Information We Collect Automatically When You Use Shangri-La Boutique:: when you access or use Shangri-La Boutique, we automatically collect personal data about you, including:
- Log Information: we may collect system log information about your use of Shangri-La Boutique, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to Shangri-La Boutique.
- Device Information: we may collect information about the computer or mobile device you use to access Shangri-La Boutique, including the hardware model, operating system and version, unique device identifiers (such as, IP address, IMEI number, the address of the device's wireless network interface, or mobile phone number used by the device) and mobile network information.
- Location Information: we may collect information about the location of your device each time you access or use Shangri-La Boutique or otherwise consent to the collection of this information. You can turn off location services for a device at any time, but this may turn off some useful features.
- Information Collected by Cookies and Other Tracking Technologies: we and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve Shangri-La Boutique and your experience, see which areas and features of Shangri-La Boutique are popular and count visits. Web beacons are electronic images that may be used in our services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see our Cookies Policy.
How We Collect, Use and Disclose Your Personal Data
Subject to the requirements of applicable law, we may collect, use and disclose your personal data for the purposes set out below.
For the performance of our agreement with you, in order to:
- process, confirm, provide, deliver and charge for orders made on Shangri-La Boutique;
- fulfill contractual obligations to you and vendors (e.g. credit card companies);
- provide you with access to the content on Shangri-La Boutique, and respond to your enquiries and requests for information and services; and
- administer, and disclose the winner of, contests and lucky draw competitions conducted by us or on our behalf.
For our legitimate commercial interests, in order to:
- understand how our products and services impact you, provide you with a better, more personalised level of service, and further develop our products and services, including linking or combining your Golden Circle information, if necessary;
- provide privileges, benefits and services to you, process applications for and administer membership programmes, verify and validate your ability to access and use certain products, services, facilities and information (such as Golden Circle member-only information), and administer Golden Circle membership, including as regards points and rewards redemption;
- monitor your use of Shangri-La Boutique and conduct analysis of the use of Shangri-La Boutique in order to operate, evaluate and improve Shangri-La Boutique and our services, understand your preferences, display customised content to you on Shangri-La Boutique which may be of interest to you and troubleshoot any problems; and
- conduct market analysis, market research, customer satisfaction and quality assurance surveys to improve our products and services offered on Shangri-La Boutique.
For compliance with legal obligations to which we are subject, in order to:
- meet legal and regulatory requirements and administer general record keeping;
- prevent, detect and investigate crime and analyse and manage commercial risks; and
- conduct investigations.
Use of information based on your consent:
- to facilitate direct marketing, promotional and customer management purposes, including sending you promotional communications (including without limitation emails and push notifications) or special offers if you have consented to receive the same. Please see section “Direct Marketing” below; and
- for any other purposes for which we have obtained your consent, in accordance with the requirements of applicable law.
In addition, we collect, use, and disclose your personal data for the following purposes depending on the nature of our relationship:
If you are a purchaser of products and/or services available on Shangri-La Boutique:
- providing customer service and support;
- creating and maintaining customer profiles in our system database;
- administering debt recovery and debt management; and/or
- any other purposes relating to any of the above;
If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by us:
- processing orders or managing the supply of goods and services;
- processing payment of vendor invoices and bills;
- maintaining internal communications; and/or
- any other purposes relating to any of the above.
In order to complete a purchase order, enrol with the Golden Circle programm or make an enquiry, you must provide us with the personal data marked with an asterisk or otherwise indicated as mandatory, otherwise we may not be able to process your request or comply with our legal obligations.
Disclosures of Your Personal Data
Subject to the provisions of any applicable law, we may share your personal data to the following entities and parties, for the purposes listed above (where applicable):
- between and among the Company, Shangri-La and a limited number of Shangri-La affiliates as are relevant for the above purposes and to facilitate the operation of our business, but we shall only do so on a need to know basis;
- with the operator of the hotel or the hub of hotels which you purchase products or services from;
- with third-party payment processors, payment service providers, external banks, credit card companies, IT and marketing support service providers and other consultants, vendors and service providers who need access to such information to carry out work or provide services on our behalf or who help us to provide Shangri-La Boutique to you;
- with third-party vendors or service providers who need access to such information for development and maintenance of Shangri-La Boutique, handling of customers inquiries, providing customer service and support, and delivery of ordered products and services;
- with any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;
- if we believe your actions are inconsistent with our Terms & Conditions, user agreements or policies, or to protect the rights, property and safety of the Company, Shangri-La or its affiliates or others;
- any business partner, investor, assignee, or transferee (actual or prospective) in connection with, or during negotiations of, or to facilitate any business asset transactions (which may extend to any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or any change of management of a hotel);
- with our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
- with any other party at your consent or at your direction or whom you authorise us to disclose your personal data to; and
- otherwise as permitted or required by applicable laws and regulations.
We may also disclose aggregate or de-identified data that is not personally identifiable with third parties, including our commercial and strategic partners.
Overseas Transfers of Your Personal Data
Your personal data will be transferred to, and stored at, locations in Hong Kong and Singapore and in the location of the hotel in which you purchase products and/or services from. It will also be accessed and processed by our personnel and the personnel of our partners, affiliates and third party service providers, who operate outside of Hong Kong and Singapore. Your personal data will only be transferred to locations outside of Hong Kong and Singapore where we are satisfied that adequate or comparable levels of protection are in place to protect personal data held in that jurisdiction or that appropriate safeguards are put in place (including standard data protection clauses for transfer from the EU to outside the EU and for access or transfers outside of Mainland China), and (where we are required to do so) with your consent.
From time to time, we would like to use your name, physical address, email address, mobile phone number, and other relevant contact information to send you either via emails, SMS messages, telephone calls, push notifications, post, or social media (e.g. WeChat and Facebook) information that we think may be of interest to you, including about our products and services, Shangri-La hotels and resorts, news about the membership programme (if you become a member of Golden Circle), satisfaction surveys, events, offers and promotions, but we can only do so with your consent.
We would also like to share (for gain) such data with the operator of the hotel or hub of hotels in which you purchase products or services from so that they may send you information, news updates, special events, offers and promotions as regards their products and services, including travel, transportation, retail, food and beverage, hotel accommodation, credit cards, financial and investment services, real estate, entertainment, publications, fashion and jewellery, leisure and sports, health and wellness, non-profit and charitable activities, social networking, media and public relations, but we will not share your personal data with such operator or use your personal data for direct marketing without your consent.
You may, in accordance with applicable law, choose not to receive marketing communications or opt-out from receiving marketing communications at any time, free of charge, by following the unsubscribe instructions contained in the marketing communications or contacting us in accordance with the section “Your Rights and Contact Us” below. If you opt out of these communications, we may still send you non-promotional communications, such as those about your purchase details or Golden Circle programme members communications, unless we are prohibited from doing so by applicable laws.
Retention of Personal Data
Our Commitment to Data Security
We have in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss or use of your personal data and to keep your personal data confidential. These measures are subject to ongoing review and monitoring. To protect your personal data, we also require our third party service providers to take reasonable precautions to keep your personal data confidential and to prevent unauthorised or accidental access, processing, erasure, loss or use of personal data, and to act at all times in compliance with applicable data protection laws.
We cannot guarantee that Shangri-La Boutique will function faultless and without any interruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.
We recommend that where applicable, you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
Children and Minors
Except where required by local laws, we do not knowingly collect personal data from minors. If you are a minor, you may only use or purchase products or services from Shangri-La Boutique with the permission of your parent or guardian.
If you are in the EU, our online services are not directed at children under the age of 13. If you believe we have collected information about a child under the age of 13, please contact us so that we may take appropriate steps to delete such information. If you are at least 13 but under the age of 16, please get the consent of your parent or legal guardian before giving us any personal data about yourself.
If you are in the People’s Republic of China, our online services are not directed at children under the age of 14. If you are under the age of 14, please get the consent of your parent or legal guardian before giving us any personal data about yourself.
Third Party Sites
Your Rights and Contact Us
Subject to applicable law, you may be entitled to access, rectify, erase, limit the use or transfer the personal data we hold of you. Whenever reasonably possible and required, we will strive to grant these rights within one (1) month or within a reasonable time. You may also withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time. You may also be entitled to appeal and object to important decisions which were made based solely on automated decision-making. You may in certain circumstances ask us to cancel your membership account or delete your personal data, in which case, to the extent permissible by applicable law, we will take reasonable steps to delete or de-identify your personal data. Please note that we may not be able to continue providing services to you if you entirely withdraw your consent or ask us to delete your personal data entirely, and this may also result in the termination of any agreements with the Company.
If you would like us to update the data we maintain about you and your preferences, or if you wish to withdraw your consent to receiving direct marketing communications from us, or if you have any questions or complaints about how we handle your personal data, please contact us by email at firstname.lastname@example.org
or by post at 28/F Kerry Centre, 683 King’s Road, Quarry Bay, Hong Kong.
Last Updated: 27 October 2021