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Home > Legal & Privacy

 

 

Welcome to Hong Kong Airlines' Privacy Policy.

 

Hong Kong Airlines Limited ("HKA") respects your privacy and is committed to protecting your personal data. This Privacy Policy will inform you as to how we look after your personal data when you visit our website or mobile app (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

To facilitate your understanding of this Privacy Policy, please use the Glossary to understand the meaning of some of the terms used.

 

1.  Important information and who we are

 Purpose of this Privacy Policy

This Privacy Policy aims to give you information on how HKA collects and processes your personal data through your use of HKA website or mobile app, including any data you may provide through this website or mobile app when you purchase flights, holidays or any other products or services from us, sign up to any HKA newsletter or publication or take part in a competition.

 

HKA is one of the flying partners of Fortune Wings Club and any personal data collected through HKA website or mobile app in respect of the Fortune Wings Club frequent flyer programme shall also be subject to this Privacy Policy.  However, any personal data submitted to Fortune Wings Club frequent flyer program via other registration channels shall subject to Fortune Wings Club’s own privacy policy and other flying partners’ privacy policies.

 

This website or mobile app is not intended for children aged below 16 and we do not knowingly collect data relating to children aged below 16, unless, for example, required for the purposes of managing the travel arrangements of people travelling with children aged below 16 and for Unaccompanied Children and Minors on our flights.  Parental consent is required for any collection and processing of personal data in relation to children aged below 16.

 

It is important that you read this Privacy Policy together with any other privacy notices or fair processing notices we may provide 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 the other notices and is not intended to override them.

 

Controller

HKA is the controller and responsible for your personal data (collectively referred to as "HKA", "we", "us" or "our" in this Privacy Policy).

 

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights in respect of your personal data, please contact the data privacy manager using the details set out below.

 

Full name of legal entity: 

Hong Kong Airlines Limited

Name and title of data privacy manager:

David Lo, Deputy General Manager, Corporate Compliance,  Corporate Governance & Development Department

Email address:

dataprivacy@hkairlines.com

Postal address:

 

Corporate Governance and Development Department

Hong Kong Airlines Limited

11th Floor, One Citygate, 20 Tat Tung Road,

Tung Chung, Lantau,

Hong Kong S.A.R.

Telephone number:

+852 3151 4531

 

 

When submitting your request, please include your contact details so that we can attend to your enquiry.

 

If you are individuals in the European Union, you have the right to make a complaint at any time to the Information Commissioner's Office ("ICO"), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

 

Changes to the Privacy Policy and your duty to inform us of changes

This version was last updated in 24 May 2018 and historic versions can be obtained by contacting us.

 

In addition to our commitment to comply with the requirements set out in the Personal Data (Privacy) Ordinance of Hong Kong, we are also committed to comply with the data protection law in the European Union, in particular, the requirements set out in General Data Protection Regulation 2016 effective from 25 May 2018.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes.

 

This Privacy Policy may be modified from time to time without further notice.

 

In the event of any inconsistency between the English version and the Chinese version, English version shall prevail.

 

Third-party links

 This website or mobile app may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins and applications and are not responsible for their privacy statements. When you leave our website or mobile app, we encourage you to read the Privacy Policy of every website or application you visit.

 
2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·         Identity Data includes first name, maiden name, last name, nationality and passport details, username or similar identifier, marital status, title, date of birth and gender.

·         Contact Data includes billing address, delivery address, email address and telephone numbers (including emergency contact details).

·         Financial Data includes bank account and payment card details.

·         Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

·         Technical Data includes 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 this website or mobile app.

·         Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

·         Usage Data includes information about how you use our website, mobile app, products and services.

·         Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does 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 or mobile app 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.

 

Unless otherwise required to do so in order to comply with specific laws (e.g. advance passenger information, passenger name records etc.) or necessary to provide certain services to you (e.g. special assistance, delivering your chosen meal preferences etc.) at airports or on board our aircraft, we shall not collect or process any Special Categories of Personal Data about you (this includes but not limited to details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership and information about your health and genetic and biometric data). Where Special Categories of Personal Data are collected and processed to provide certain services to you, we will obtain your explicit consent before collecting and processing the Special Categories of Personal Data. 

 

We may receive Criminal Convictions and Offences Data from law enforcement and other governmental authorities, and record data on Passenger’s Behaviour or interactions with staff before, during and after a flight.  The purpose of collection is to protect the safety of our passengers, staff and equipment.  Processing of such data is carried out in accordance with applicable legal and regulatory requirements.

  

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you 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 (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

 

3. How is your personal data collected? 

We use different methods to collect data from and about you including through:

·         Direct interactions. You may give us your Identity, Contact and Financial Data and other personal information by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

o    apply for our products or services;

o    purchase our products or services;

o    create an account on our website or mobile app;

o    subscribe to our service or publications;

o    request marketing to be sent to you;

o    request special services or assistance;

o    enter a competition, promotion or survey; or

o    give us feedback/ filing of complaints.

 

·           Passenger’s Behaviour.  We may record information about a passenger's behaviour or interactions with staff before, during and after a flight.

 

·         Automated technologies or interactions. As you interact with our website or mobile app, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

 

·         Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

o    Technical Data from the following parties:

·         analytics providers, such as Google, based inside or outside the European Economic Area (“EEA”);

·         advertising networks based inside or outside the EEA; and

·         search information providers based inside or outside the EEA.

o    Contact, Financial and Transaction Data from providers of technical, payment and delivery services based inside or outside the EEA.

o    Identity and Contact Data from data brokers or aggregators based inside or outside the EEA.

o    Identity and Contact Data from publicly availably sources.

o    Criminal Convictions and Offences Data from law enforcement and other governmental authorities.

 
4. How we use your personal data

We will only use your personal data when the applicable law allows us to. Most commonly, we will use your personal data in the following circumstances:

·         Where we need to perform the contract we are about to enter into or have entered into with you.

·         Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

·         Where we need to comply with a legal or regulatory obligation.

 

Please see below to find out more about the types of lawful bases that we will rely on to process your personal data.

 

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.

 

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one legal basis has been set out in the table below.

 

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

Performance of a contract with you

To process and perform your flight booking including:

(a) Manage payments, fares, fees and charges

(b) notify you of relevant flight information such as pre-flight check-in and changes to your flight

(c) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e)Marketing and Communications

(a)Performance of a contract with you

(b)Necessary for our legitimate interests (to recover debts due to us)

To register you as a new member of Fortune Wings Club through our website

(a) Identity

(b) Contact

(c) Profile

Performance of a contract with you

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms and conditions or privacy policy

(b) Asking you to provide feedback about your experience with us and our partners or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to participate in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e)Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, and fraud prevention)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests (to develop our products/services and grow our business)

To protect the safety of our passengers, staff, aircrafts and equipment

(a)  Identity

(b)  Criminal Convictions and Offences.

(c)  Passenger’s Behaviour

(a)  Necessary to protect our legitimate interests (protecting the safety of our passengers, staff, aircrafts and equipment).

(b)  Necessary to comply with a legal obligation.

(c)  Necessary to protect vital interests (to protect the lives of our passengers and staff).

 

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

 

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

 

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

 

Third-party marketing

We will get your explicit opt-in consent before we share your personal data with any third party for marketing purposes.

 

Opting out of any marketing materials

You can ask us or third parties to stop sending you marketing messages at any time by logging into your account and adjusting your marketing preferences, by following the opt-out links on any marketing message sent to you or by contacting us.

 

Where you opt out of receiving these marketing messages, this will not apply to communications that we send to you in respect of your purchase of our products and services e.g. live information about your flight with us, disruption and other operational updates as may be necessary from time to time.

 

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 click here. 

 

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 wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

 

If we need to use your personal data for an unrelated purpose, we will 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 where this is required or permitted by law.

 

5. Disclosures of your personal data

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.

·         Internal Third Parties as set out in the Glossary.

·         External Third Parties as set out in the Glossary.

·         Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the applicable law.

 

6. International transfers

If you are based in the EEA at the time you provide personal data through this website or mobile app, a transfer of your personal data outside of the EEA will take place.  We share your personal data within the HKA group of companies, affiliates and business partners for legitimate purposes. This will involve transferring your data between countries outside the EEA. Many of our External Third Parties are based outside the EEA so their processing of your personal data will involve a transfer of data between countries outside the EEA.

 

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

·         We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, seeEuropean Commission: Adequacy of the protection of personal data in non-EU countries.

·         We may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

7.  Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They are subject to a duty of confidentiality.

 

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

8. Data retention

How long will you use my personal data for?

 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

 

To determine the appropriate retention period for personal data, we consider 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 and regulatory requirements.

 

Details of retention periods for different aspects of your personal data are available in our retention policy which you can request from us by contacting us.

 

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

9. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

·         Request access to your personal data

·         Request correction of your personal data

·         Request erasure of your personal data

·         Object to processing of your personal data

·         Request restriction of processing your personal data

·         Request transfer of your personal data

·         Right to withdraw consent

If you wish to exercise any of the rights set out above, please contact us.

 

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

 

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

 

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

 

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

Internal Third Parties

 

Other companies in the HKA group of companies acting as joint controllers or processors, including Hong Kong Aviation Group Services Limited ("HAGSL") and Fortune Wings Club and providing IT and system administrative services and undertaking leadership reporting.

 

External Third Parties

It includes:-

·         service providers acting as processors based in Hong Kong, the People's Republic of China and other countries on our route network who provide airport, ground handling and inflight services (other than HAGSL) e.g. special assistance, call centre operations, sales & marketing support, inflight meal service providers,  IT and system administrative services responsible for maintenance of the website;

·         professional advisers acting as processors including lawyers, bankers, auditors and insurers based inside and outside of the EEA who provide consultancy, banking, legal, insurance and accounting services;

·         tax authorities, regulators and other authorities acting as processors or joint controllers based in Hong Kong, the People's Republic of China and other countries on our route network who may require reporting of processing activities in certain circumstances; and

·         card issuers, in order to detect or prevent fraudulent transactions.

 

YOUR LEGAL RIGHTS

You have the right to:

 

Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

 

Request erasure of your personal data. 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 information unlawfully or where we are required to erase your personal data to comply with local law. 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.

 

Object to 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. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

 

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

 

Request the transfer of your personal data to you or to a third party. 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 automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

Withdraw consent at any time where we are relying on consent to process your personal data. 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.