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Please read the following carefully to understand the policy and practices regarding how your personal information will be treated by Total Loyalty Company (TLC). This policy applies to all registered and unregistered users of Total Loyalty Company and its TLC programme and affiliated services, and may from time to time be updated, revised, reposted and changed where TLC deems necessary.


Statement of Policy

TLC is committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Personal Data (Privacy) Ordinance with respect to the management of personal information. We are equally committed to ensuring that all our employees, partners and contracted parties uphold these obligations.


Collection of Information 

TLC collects personal information from client employees in order to provide TLC programme services. Depending on the purposes of collection of personal information and the nature of the individuals, this information includes:

- Full name,

- Work and/or Personal email depending on the designation made by Client.

This information can be obtained by: provision of our service client (the HR department of our Client), and directly by email.

TLC takes your privacy and confidentiality seriously. We gather information to deliver our TLC programme services such as e-newsletters, and user accounts to client programme sites. We will not disclose any information to a third party for commercial purposes unless we have permission from you. We do also reserve the right to use any information collected for service analytics purposes, provided we shall not disclose any private information in such analytics unless we first have permission from you.


Purpose of Collection

For clarity, the purposes for which your personal information are used include: 

- To register a unique account for member services with your TLC programme.

- To send you e-newsletters to update you on member services and offerings within your TLC programme.

- For programme and service usage analytics of your TLC programme

TLC will indicate in the relevant forms or applications if the required personal information is for obligatory or voluntary purposes. If certain personal information is to be used for an obligatory purpose and you failed to provide such data, we will not be able to provide the service for which you are applying. 


Disclosure and Transfer

TLC will not disclose personal information without your permission unless we are required to do so by law or we believe that such action is necessary to: comply with the law or applicable regulations; protect and defend our rights and property; protect against misuse or unauthorized use of TLC; or protect the personal safety or property of our users or the public.


Access and Alteration of Data

Any concerns, requests, questions, or complaints about how TLC handles your data should be made to our Data Protection Officer at  2106 Westland Centre, 20 Westlands Road,. Quarry Bay,. Hong Kong or info@totalloyalty.hk.  We will look into your inquiry and will respond within the time frame provided by any applicable law after receiving your request.


Personal Information Collection Statement (“PICS”)

This Statement is made by Total Loyalty Company (TLC), in accordance with the Personal Data (Privacy) Ordinance. This Statement intends to notify you the purpose of collecting your personal information, to whom the personal information will be transferred, to whom data access requests are to be addressed.


Purpose of Collection

For clarity, the purposes for which your personal information are used include: 

- To register a unique account for member services with your TLC programme.

- To send you e-newsletters to update you on member services and offerings within your TLC programme

- For programme and service usage analytics of your TLC programme

TLC will indicate in the relevant forms or applications if the required personal information is for obligatory or voluntary purposes. If certain personal information is to be used for an obligatory purpose and you failed to provide such data, we will not be able to provide the service for which you are applying. 


Use of Personal Information in Direct Marketing

We do not intend to use your personal information in direct marketing, and we will not use your personal information for any purpose outside of your TLC programme.


Disclosure and Transfer

TLC will keep your personal information confidential. Only authorised staff members of TLC will have access on a “need-to-know” basis to and handle your personal information. To the extent necessary, TLC may disclose your personal information to the following parties in or outside Hong Kong solely for the purposes set out in this PICS:

- We may also disclose your personal information when authorised or required by law and in response to requests from law enforcement agencies, government departments or regulatory authorities. 

- We may also share your personal information within TLC and with third parties such as IT contractors, as necessary for any of the purposes as stated above. Where personal information is provided to third parties, the personal information will only be transferred to such third parties that are under a duty of confidentiality to TLC.

Other than to the parties and for the purposes set out in this policy, we will not disclose your personal information to any third party without your prior consent.


Access and Alteration of Data

You are entitled to request access to any personal information that we hold about you, and you can do this by contacting our Data Protection Officer at the address specified below. You may request that we correct the personal information that is inaccurate or out of date.

If you have any concerns, requests, questions, or complaints about your personal information, or if you have any questions about this PICS, please contact our Data Protection Officer at  2106 Westland Centre, 20 Westlands Road,. Quarry Bay,. Hong Kong or info@totalloyalty.hk. We will look into your inquiry and will respond within the time frame provided by any applicable law after receiving your request.