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The Glenrothes Hong Kong Privacy Policy

Last Updated: 30th April 2024

The Glenrothes Hong Kong Privacy Policy

Effective Date: 30th April 2024

This Privacy Policy applies in Hong Kong. If you are based within another jurisdiction, please see the relevant website to locate the applicable Privacy Policy.

WHO WE ARE

The Glenrothes is owned by Highland Distillers Limited, a private limited company (registered in Scotland No. 158731), and our registered office is at 100 Queen Street, Glasgow, Scotland, G1 3DN.  Processing of personal data relating to The Glenrothes as described in this Privacy Policy is also undertaken by other group companies of the Edrington Group Limited (The parent company of Highland Distillers Limited) – details of these companies can be found here.

In this Privacy Policy, Highland Distillers Limited, Edrington Hong Kong Limited and the relevant group companies of the Edrington Group Limited are referred to as The Glenrothes, we, us or our.

The Glenrothes is the data controller (or equivalent data handlers) in relation to the processing of your personal data described in this Privacy Policy. We have a Data Privacy Manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any question about this Privacy Policy, including any request to exercise your rights in relation to your personal data, please contact us at the details set out below.

This Privacy Policy is in a layered format so you can click through to the specific areas set out below.

OVERVIEW

The Glenrothes is committed to protecting and respecting the privacy of its consumers’ personal data and pledged to complying with the requirements of applicable data protection laws (including the Personal Data (Privacy) Ordinance) ("PDPO") (together “Data Protection Laws”).  Looking after the personal data that we collect on our consumers is a priority for us and we want you to be confident that your information is in safe hands.  We’ve developed this Privacy Policy to let you know:

  • What types of personal data we collect;
  • How we collect personal data;
  • The purposes we collect personal data for, including how we use it to make our products better and to offer better services and experiences to our consumers;
  • The circumstances in which we may share your personal data with and/or transfer it to other organisations that support our operations, including the types of organisations involved;
  • Where we store your personal data;
  • How long we keep personal data for; and
  • The rights and choices you have with regards to your personal data.  

It is important that you read this Privacy Policy together with any other privacy policy or fair processing notice we may provide from time to time on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and privacy policies and is not intended to override them, unless expressly specified otherwise. By providing us with your personal data, you acknowledge that our collection, use, disclosure and processing of your personal data will be in accordance with this Privacy Policy, including, for the avoidance of doubt, the cross jurisdictional transfer of your data. If you object to how we will collect, use, disclose, process and/or share your personal data as set out in this Policy, please DO NOT provide any personal data to us.

WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT OUR CONSUMERS?

  • Your name, age/date of birth (including for age verification and due diligence purposes) and home location(s);
  • Your contact details: postal addresses including billing and delivery addresses, contact telephone numbers (including mobile numbers) and email address;
  • Details about payments to and from you and other details of purchases, orders made by you, including your purchase history and ballots you have submitted for the purchase of The Glenrothes’ products. This also includes tracking purchases that you have made on the resale market;
  • When you make a purchase or place an order with us, your payment card details, and details of any payment services used (e.g. Apple Pay, Google Pay, etc);
  • Details of any event or experience invitations or bookings you have made, including details you have provided or we may have collected from you in connection with your attendance at any events or experiences we have arranged with you (such as any accessibility or dietary requirements or other interests related to the event or experience);
  • If we are required to carry out due diligence, details of any criminal convictions or sanctions, illegal activity, adverse media or whether you are a politically exposed person, which is publicly available;
  • Your internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the website (Technical Data);
  • Information about how you use our website, products and services (Usage Data);
  • Your correspondence and communications with The Glenrothes;
  • Personal data, which you have maybe shared via a public platform (such as on The Glenrothes’ Facebook, Youtube channel or Instagram feed);
  • Your preferences in receiving marketing and sales information from us and our third parties (whether within or outside Hong Kong) and your communication preferences;
  • Information which may be collected or generated by our customer engagement personnel and/or representatives, or when you participate in an online experience, such as:
    • preferences regarding our products and offerings including any "wish list" items regarding preferred The Glenrothes products and experiences and how you share your experiences and passion for The Glenrothes with others;
    • lifestyle preferences and interests such as preferred travel destinations, preferred restaurants / cuisines and whisky and drink preferences / collection;
    • social indicators such as your profession and connections;
    • engagement data such as when you open or click on our emails, how long you have been a consumer of The Glenrothes, and when and how you interact with our personnel /representatives;
    • communication channel preferences (e.g. social media handles and app-based messaging) such as LinkedIn, Facebook, Twitter, WeChat and WhatsApp;
    • your behaviours insofar as they may impact The Glenrothes brand, including compliance with our terms and conditions of sale and behaviour at events and online platforms;
  • Information about any experiences, events, gifts, special invitations or benefits made available to you;
  • Your feedback and survey responses; and
  • Online browsing activities on The Glenrothes website.

We also collect, use, disclose, process, transfer and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be generated and derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Sensitive or Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, biometric data).

Where we need to collect your personal data by law, or under the terms of a contract we have or will have with you, or for the purposes for which the data may be used as set out hereunder, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (e.g. to provide you with our products or services). In this case, we may have to cancel the purchase, order or experience you have or will have with us but we will notify you of such cancellation at the relevant time.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect your personal data by different methods, including:

  • Direct interactions: This includes personal data you provide when:
    • You subscribe to receive our newsletter;
    • You create an account on our website or participate in one of our online experiences;
    • You make a purchase or place an order (including online purchase or order) for a Glenrothes product or merchandise;
    • You enter a ballot or competition related to The Glenrothes or one of The Glenrothes’ products;
    • You attend one of our events, visit one of our sites (e.g. our distillery) or you avail of one of our experiences (e.g. whisky tastings, dinning and food, and other bespoke or exclusive experiences);
    • You interact with one of our Private Client Relationship Managers (PCRMs), brand ambassadors or other representatives;
    • You communicate with us through e-mail, post, telephone, text messaging, or any other app-based or social media direct messaging; and
    • You contact us, by whatever means and for whatever reason.
  • Automated technologies or interactions: As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns, and other diagnostic data. We may also gather statistical information on emails sent to you (e.g. opens, clicks, delivery rates, unsubscribes and forwards). This helps us to assess and improve email performance and our engagement with you. We collect this personal data by using cookies, pixels and other similar technologies. Please see our Cookies Policy for further details.
  • Third party sources of information: We may obtain information about you from the following third party sources:
    • Where you interact with a third party acting on our behalf (e.g. a representative of one of our distributors or joint venture partners);
    • Our professional advisors (e.g. lawyers, accountants and bankers);
    • Publicly available sources (e.g. how you share your experiences and passion for The Glenrothes with others on social media and retailers of The Glenrothes); and
    • Where we carry out customer due diligence, we use a third party due diligence screening provider who searches publicly available information.
  • Technical Data: We also collect Technical Data from the following third parties:
  • Analytics providers (such as Google based outside the UK and/or EU);
  • Advertising networks;
  • Search information providers; and
  • Due diligence screening providers.

ONLINE ANALYTICS

We use various types of online analytics, including Google Analytics, a web analytics service provided by Google, Inc. (Google), on our website. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the related activities, and provide other services related to website and app activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website or app. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt-out of tracking of analytics by Google click here.

SURVEYS

From time to time, and subject to your consent where required by applicable local law, we may provide you with the opportunity to participate in surveys, some of which might be sponsored or conducted by a third party. Participation in these surveys is completely voluntary. If you choose to participate, we will request certain personal data from you. If there is a third party sponsor involved in the survey, we may provide certain personal data to the third party sponsor. Please make sure to review the sponsor’s privacy policy and be aware that any surveys offered by us may be governed by specific rules, terms and conditions that are separate from and in addition to this Privacy Policy. By participating in any such survey you will become subject to those rules, terms and conditions, including but not limited to receiving emails containing survey communications.

HOW DO WE USE YOUR PERSONAL DATA?

The purposes for which your personal data may be used by The Glenrothes (and trusted partners and service providers acting on our behalf) are as follows:

  • To provide you with information, products or services that you request from us, or which we feel may interest you (including direct marketing). This is only done when you’ve given your consent to be contacted by us, or where we are permitted to contact you in accordance with Data Protection Laws (such as where you have not opted-out of receiving such information from us at the time of making a purchase from us);  
  • To send you personalised communications based on your preferences, and engagement with The Glenrothes’ products, services or experiences with your consent;
  • To verify your identity and your age;
  • To verify your identity with any credit card acquirer or the issuing bank in connection with any card transaction for your purchase with us, or exchange information with relevant acquirer or bank for such purpose;
  • Where you make a purchase above a certain value or we have or are building a relationship with you, carry out due diligence checks using our third-party due diligence system;
  • For crime and fraud prevention, detection and related purposes;
  • To enable The Glenrothes to manage any customer service interactions with you, which may include performing data analytics and using related technologies to process data;
  • To ensure compliance with our terms and conditions of sale and protection of The Glenrothes brand and products;
  • To ensure that our web content is presented in the most efficient way for you and your computer;
  • To allow you to participate in interactive features on our website, when you choose to do so;
  • For the purposes of The Glenrothes’ legitimate interests set out in the section below entitled "Our Legitimate Interests";
  • Where we have a legal right or duty to use or disclose your information in compliance with laws (for example in relation to an investigation by government, law enforcement agencies or a public authority of any act or attempt to circumvent or violate any laws or in a legal dispute);
  • For advertising and marketing The Glenrothes’ products and services and other subjects (including direct marketing as detailed below);
  • For such purposes that may be informed to you when your personal data is collected; and
  • For other reasonable purposes related to the above.

The Spirit of Rothes

By signing up to the Spirit of Rothes community, you will automatically be assigned preferences to receive email communications on topics such as:

  • Partnerships
  • Product releases
  • Events
  • Experiences
  • Regional communications
  • Distillery updates

You can review what types of communications you have been assigned to receive and update them at any time (e.g. to only receive emails on whisky releases) via the communications preference centre by logging into your account on our website. 

UNDERSTANDING OUR CONSUMERS BETTER

The Glenrothes will also use the personal data that we receive or collect about certain aspects of our consumers to understand our customer profile better and to engage with our consumers more effectively.

This will involve using this personal data to consider our consumer's preferences, characteristics, interests and activities, purchase habits and engagement with The Glenrothes brand and products. In identifying this information we will use it to better understand the habits, preferences and profiles of our most valued consumers and to identify categories of valued consumers that we can better engage with and better tailor their experience of The Glenrothes’ products and brand.

Based on this better understanding of our most valued consumers, The Glenrothes will determine how we can improve the products, services and experiences it makes available to its consumers, how we can improve our interactions and engagement with consumers, and to assess eligibility of our most valued consumers for special invitations, experiences, and other benefits.

This processing may continue so long as you have a relationship with The Glenrothes. This means that the way in which we provide our products and services to you, interact and engage with you, or provide any special invitations, experiences and benefits to you, may change over the course of our relationship with you.

You can ask us at any time to stop sending you marketing communications, or using your personal data for marketing purposes (including profiling) at any time. Please see the section below entitled "What are your rights?" for further details.

USE OF PERSONAL DATA FOR DIRECT MARKETING

In connection with direct marketing, we may use your personal data collected in the section “WHAT TYPES OF PERSONAL DATA DO WE COLLECT ABOUT OUR CONSUMERS?” above for marketing and promotional purposes, including delivering to you information about any good and services, updates on latest news, offers and promotions or marketing materials in connection with our products and services.

If we intend to use your personal data for direct marketing purposes, we will first obtain your written consent (or an indication of no objection) for those purposes.

If you do not wish us to use or provide your personal data to third parties for use in direct marketing as described above, you may exercise your opt-out right by notifying us.

If you decide that you no longer want to receive direct marketing materials after giving us your consent, please let us know by contacting our Data Privacy Manager at [email protected].

WHAT IS OUR LEGAL REASON FOR HOLDING YOUR PERSONAL DATA?

Data Protection Laws require us to state our legal reason for processing your personal data.

Where we have requested your consent, we will rely on this consent to send you marketing communications about The Glenrothes. We may also send you marketing communications about The Glenrothes where you have requested information from us or made a purchase and you have not opted out of receiving such communications.

You can withdraw your consent to, or opt-out of, receiving these communications at any time by using the unsubscribe button included in the communications we send you, by contacting The Glenrothes representative that you provided your consent to, or by contacting our Data Privacy Manager at [email protected]. Where you opt out of receiving marketing communications, this will not remove any personal data provided to us as a result of a purchase that you have made.

The Glenrothes also collects and uses your personal data because it is necessary for:

  • the pursuit of our legitimate interests (as set out below);
  • the purposes of complying with our duties and exercising our rights under a contract for the sale of products or services to a consumer; or
  • complying with our legal and regulatory obligations.

OUR LEGITIMATE INTERESTS

The normal legal basis for processing consumer data, is that it is necessary for the legitimate interests of The Glenrothes, including:

  • selling and supplying products and services to our consumers;
  • protecting consumers, employees and other individuals and maintaining their safety, health and welfare;
  • promoting, marketing and advertising our products, services, events, experiences and brand partnerships with your consent;
  • understanding our consumers’ behaviour, activities, preferences, habits and needs, including through the use of profiling;
  • improving existing products and developing new products;
  • providing experiences, special invitations and other benefits to our most-valued consumers;
  • handling consumer contacts, queries, complaints, or disputes;
  • administrative purposes, e.g. accounting, risk management and record keeping, business research, data, planning and statistical analysis, and staff training; and
  • preventing, investigating and detecting crime, fraud, or anti-social behaviour and prosecuting offenders.  

Where we process your personal data in pursuit of our legitimate interests, you have the right to object to us using your personal data for the above purposes. If you wish to object to any of the above processing, please contact our Data Privacy Manager by email at [email protected] or by post at the address as set out below. If we agree and comply with your objection, this may affect our ability to undertake the tasks above for your benefit.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you require any further information on how the processing for the new purpose is compatible with the original purpose, please contact us by using the details below.

If we need to use your personal data for an unrelated purpose, we will use reasonable means to notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

WHAT ARE YOUR RIGHTS?

Under Data Protection Laws, you will be entitled to certain rights when we process your personal data for some of the purposes identified above in this Privacy Policy. These rights are set out below. However, for certain data collection and processing activities that is solely subject to the data protection laws of Hong Kong, not all of these rights will apply:

  • to access your personal data (commonly known as a "data subject access request") - this enables you to access the personal data we hold about you and receive confirmation of how we are processing it;
  • to have your personal data rectified if it is inaccurate or incomplete - this enables you to have any incomplete or inaccurate personal data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
  • in certain circumstances, to have your personal data deleted or removed – this enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your personal data unlawfully or where we are required to erase your personal data to comply with local law. Please note however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.;
  • in certain circumstances, to restrict the processing of your personal data – this enables you to ask us to suspend the processing of your personal data in the following scenarios:
    • if you want us to establish the personal data's accuracy;
    • where our use of the personal data is unlawful but you don’t want us to erase it;
    • where you need us to hold the personal data even if we no longer require it as you need it to establish, exercise or defend legal claims;
    • you have objected to our use of your personal data (see below) but we need to verify whether we have overriding legitimate grounds to use it;
  • a right of data portability, namely to obtain and reuse your personal data for your own purposes across different services. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to personal data which you initially provided consent for us to use or where we used the personal data to perform a contract with you;
  • to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. We will not provide your personal data to third parties for direct marketing, or for any purposes incompatible with the purpose for which the data was originally collected, without your consent. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
  • not to be subject to automated decision-making (including profiling), where it produces a legal effect or a similarly significant effect on you;
  • the right to withdraw your consent at any time where we are relying on consent to process your personal data (including but not limited to direct marketing purposes). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent and
  • to claim compensation by civil action for damages caused by a breach of the Data Protection Laws.

If you wish to exercise any of these rights, please contact our Data Privacy Manager by email at [email protected], or The Glenrothes representative with whom you normally deal.

WHO DO WE SHARE YOUR PERSONAL DATA WITH? 

To effectively fulfil our obligations to you, and to provide you with marketing and certain experiences, special invitations and benefits, we use a number of trusted and reliable third parties (including within or outside Hong Kong) to carry out functions which involve the processing of your personal data. These include:

  • vendors who will process your personal data on our behalf and under our written instructions to carry out their services during the course of our business, such as IT service providers, financial institutions, customer relationship management vendors, marketing service providers, and other cloud-based solutions providers that are used by The Glenrothes in the conduct of its business. We contract with such vendors to ensure that they only process your personal data under our instructions and ensure the security and confidentiality of your personal data by implementing the appropriate technical and organisational measures for such processing;
  • vendors that process your personal data in order to assist us to better understand our consumers and how we can improve our consumer engagement, such as HubSpot and Salted Stone;
  • when you order products or services from our online shop, we will share your details with our fulfilment partners (currently Kerry Logistics (Hong Kong) Ltd.), who will process your orders as set out in our terms and conditions of the online shop;
  • where you make a purchase above a certain value or we have or are building a relationship with you, we will share your name and date of birth with our due diligence service provider to carry out due diligence checks;
  • marketing service providers that administer services on our behalf, such as sending communications to our consumers, administering any promotions or ballots which we run; and
  • translation service providers that administer services on our behalf, such as translating communications received and sent in different languages;
  • other agencies and fulfilment partners to administer events, competitions. experiences, brand programmes and other special invitations and benefits;
  • our professional advisors (e.g. lawyers, accountants and bankers);
  • other entities in The Glenrothes group of companies; and
  • The Glenrothes’ third party distributors or joint venture partners.

We may provide your personal data or information to others (such as governmental or law enforcement agencies) in the good faith belief that such action is necessary to: (i) enforce or apply our terms and conditions; (ii) comply with any legal claims raised against The Glenrothes; (iii) protect the rights, property or safety of The Glenrothes and/or the group companies thereof; or (iv) protect the rights, property or safety of the public.

If we intend to provide your personal data collected from you to third parties for their use in direct marketing, we will first obtain your consent (or an indication of no objection) before doing so.

In accordance with applicable law, if The Glenrothes becomes involved in a merger, consolidation, acquisition, change in control, bankruptcy, reorganisation, liquidation or other transaction involving the sale of some or all of our business or assets, user information, including personal data collected from you through your use of our website, could be included in the transferred business or assets. Should such an event occur, we will use reasonable means to notify you, either through email and/or a prominent notice on our website. 

WHERE WE STORE YOUR PERSONAL DATA

We may transfer your personal data outside Hong Kong. This is primarily to allow us to:

  • receive consultancy, marketing and IT services (e.g. cloud storage services, database development and management services, email/webmail services and customer relationship management services) from vendors located outside Hong Kong, for example, in the UK, EEA, the US, South Africa and Australia; and
  • provide special invitations, products, services, experiences and other benefits to you, from other The Glenrothes group companies, or selected third party distributors, joint venture partners, or airport boutique operators. A full list of the entities to whom data is transferred, along with the country they are based in, is available here.

Where your personal data is transferred to a place outside Hong Kong or other locations where restrictions may apply under Data Protection Laws, we will ensure your personal data is afforded an adequate level of data protections, as required by Data Protection Laws, including:

  • by obtaining your consent to the cross jurisdictional transfer of your data as set out above (or otherwise in accordance with one of the other transfer conditions in the PDPO which has been satisfied);
  • by transferring the data to a country that the UK authorities or European Commission have deemed as providing an adequate level of data protection (an "adequacy decision");
  • by implementing an appropriate international transfer mechanism under Data Protection Law, such as standard contractual clauses or a data transfer agreement / addendum approved for this purpose by the UK authorities or European Commission;
  • by relying on a "transfer derogation" under Data Protection Law (e.g. where the transfer is based on your explicit consent, or is necessary to perform a contract with you); or
  • where we are otherwise permitted to make the transfer under Data Protection Laws.

Please contact us if you would like to know further information on the specific mechanism used by us when transferring your personal data in accordance with Data Protection Laws.

HOW LONG DO WE KEEP YOUR PERSONAL DATA? 

We will not retain your personal data for longer than necessary for the purposes set out in this Privacy Policy, including for the purposes of maintaining our relationship with you as well as satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you. 

Different retention periods will apply to different types of data. To determine the appropriate retention period for personal data, we consider any ongoing relationship we have with you, the likelihood you may want to make a further purchase from us in the future, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

When we no longer need to use your personal data, we will remove it from our systems and records, and or take steps to anonymise it so that you can no longer be identified from it (unless we need to keep your information to comply with legal or regulatory obligations we are subject to).

In certain circumstances, you can ask us to delete or remove your data (see the section entitled "What rights do you have?" above for further information on your rights).

We may also use your personal data collected by recording phone calls for the following purposes:

  1. Account management;
  2. Prevention, detection, investigation and prosecution of fraud;
  3. Complaint handling and resolution;
  4. Measuring the quality of the call;
  5. Internal training on call handling.

We have a legitimate interest in retaining calls in order to offer our consumers a good service and to protect our business. If you object to the call recording, you may choose to end the call when you are informed that calls may be recorded.  You will have the option to contact us through alternative means. All calls records will be retained for a period of one year.

HOW DO WE PROTECT YOUR PERSONAL DATA?

The Glenrothes is committed to keeping your personal data confidential, safe and secure.  To prevent unauthorised access, maintain data accuracy and ensure the correct usage of personal data, we monitor and adjust our physical, electronic and managerial procedures to safeguard and secure the personal data we collect online.

THIRD PARTY WEBSITES AND APPS

Our website and services may contain links to other websites or apps operated by third parties. Please be advised that the practices described in this Privacy Policy do not apply to information gathered through these third party websites and apps. We have no control over, and are not responsible for, the actions and privacy policies of third parties and other websites and apps.

QUESTIONS

If you have any questions or concerns about the way in which your Personal Data is processed, please contact our Data Privacy Manager by email at [email protected], or by post at Suites 1202-07, 12/F, Exchange Tower, 33 Wan Chiu Road, Kowloon Bay, Kowloon, Hong Kong.

COMPLAINTS

You have the right to complain about data protection matters to the Office of the Privacy Commissioner for Personal Data (PCPD) or to any other data protection regulator or authority having jurisdiction over us.

The PCPD was established under the PDPO as the dedicated data privacy regulator. You can find out more about the PCPD on its website (pcpd.org.hk). The PCPD can be contacted by calling 2827 2827.

We would however appreciate the chance to discuss and work with you to address your concerns before you approach the PCPD or another regulator, so please contact us in the first instance.

CHANGES

The Glenrothes may update this Privacy Policy from time to time as our privacy practices change, or as required by applicable legal or regulatory requirements. Where it is practicable, we will notify you of any significant changes. However, the last updated date is given at the top of this Privacy Policy and The Glenrothes encourages you to review this Privacy Policy periodically so that you remain informed of the updated version of this Privacy Policy and how we collect, use and/or store your personal data thereunder.

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