Annex A to the Addendum – Rules on processing minors’ personal data (hereinafter “Annex A”)
1. Application
This Annex A provides the rules of the activities of Missions Points Network Company Limited’s (“MPNCL”, “we”, “us”, or “our”) activities in processing personal data of persons aged below eighteen (18) who are:-
- located in Mainland China who visit or use the Applications or visits the Website of MPNCL, or otherwise use MPNCL’s products and/or services including but not limited to the loyalty program “K Dollar Program” managed and operated by MPNCL and/or any other loyalty program managed and operated by other entities through which the relevant loyalty points can be converted to points under the “K Dollar Program”, by phone or any other means from Mainland China; and/or
- holding Mainland China passports and/or resident identity cards who visit the premises, including but not limited to malls, shops, and/or buildings where “K Dollar” under MPNCL’s “K Dollar Program” can be earned and/or used in Hong Kong or otherwise uses MPNCL’s products and/or services by phone or any other means in Hong Kong.
2. Personal data
Clause 2 of the Addendum applies, save and except that the “sensitive personal data” involved in this Annex A includes all Minors’ personal data.
3. How we collect and process Minors’ personal data
The following shall apply to how we collect and process Minors’ personal data:-
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- Minors’ personal data shall only be provided to us upon the consent of Minors’ parents or legal guardians. If the Minors’ parents or legal guardians subsequently withdraw the consent, they and the Minors shall immediately cease the provision of their personal data to us.
- If Minors’ parents or legal guardians become aware that without their consent Minors under their care have provided personal data to us, please notify us to delete them by contacting our Personal Data Privacy Officer via the contact details set out in Clause 10 of the Addendum.
- Minor’s personal data will be processed by us for the purposes as further specified below only (“Purposes for Minors”). In particular, in order for us to carry out the Purposes for Minors, the personal data set out below (either collected from you directly and/or via K11 Loyalty Program Limited, Discovery Park Commercial Services Limited, New World Loyalty Programme Limited, Chow Tai Fook Membership Program, Humansa Limited and/or any other entities which manage and operate other loyalty programs under which the relevant loyalty points can be converted to points under the “K Dollar Program” and/or otherwise have other business collaboration relating to the Purposes with us) may be required to be provided. If such information is not available or not accurate, we may not be able to perform the Purposes for Minors. For the avoidance of doubt, if/where applicable, we will indicate which kind of personal data is mandatory or optional for you to provide at the relevant time of data collection, e.g. when you register your membership account(s) with the relevant club(s)/loyalty programme(s) operated by us:-
No. Purposes Personal data we may collect 1. For daily operation and administration of your membership, and to contact you in connection with your membership - Name
- Membership Number
- Phone number
- Email address
- Language Preference
- Transaction information (including your characteristics and transaction behavior)
- Credit card and electronic / digital payment information
2. To deliver bespoke services and membership benefits to you - Name
- Membership Number
- Email address
- Phone number
- Month of birth
- Gender
- Age Range
- Language Preference
3. To process bookings, purchases, orders or requests made by you - Name
- Membership Number
- Phone number
- Email address
4. To send you birthday messages and offers (if you have provided your birthday information) or event reminders - Name
- Membership Number
- Email address
- Phone number
- Month of birth
- Language Preference
5. Identifying and verifying your identity and/or as a member of any of the relevant club(s)/loyalty programme(s) operated from time to time by us, our relevant Affiliates and/or relevant Marketing Partners (if applicable, as the case may be) - Name
- Membership Number
- Phone number
- Password
- Email address
6. Assisting you to register for your selected or designated membership(s) of other clubs/loyalty programmes of our Affiliates and/or our Marketing Partners by transferring your relevant account information to the aforesaid clubs/loyalty programmes (as the case may be) for the purpose of registration; and enabling the consequent account administration, management and related functions of such selected or designated clubs/loyalty programmes for the purposes of unified access control for your various accounts on the relevant club/loyalty programme’s website, application and/or application platform, data migration or synchronisation for or across your various accounts, and/or unified/centralised management of certain member rewards/benefits initiatives (e.g. K Dollars) that may be applicable to your various accounts. For avoidance of doubt, insofar as your personal data are transferred to such other club(s)/loyalty programme(s) for any of the aforesaid purposes (as applicable), the handling of your personal data will be further subject to the terms and conditions and personal information collection statement of the operator(s) of those other applicable club(s)/loyalty programme(s) - Name
- Membership number
- Phone number
- Email address
- Age Range
- Gender
- Language Preference
- Month of birth
- Date of birth
- Place of residence
7. Handling the registration of your membership account(s) with the relevant club(s)/loyalty programme(s) operated by us - Name
- Membership number
- Phone number
- Email address
- Age Range
- Gender
- Language Preference
- Month of birth
- Date of birth
- Place of residence
8. Subject to your consent, handling the relevant account binding or unified access control management features (as the case may be) for your membership account(s) with us together with your other selected or designated membership(s) with other clubs/loyalty programmes operated by our Affiliates and/or our Marketing Partners, if any, as the case may be, by processing your relevant account information (including, but not limited to, your membership account number/identifier, name, email and mobile, as applicable) that you may provide to us and/or that we may from time to time receive or otherwise obtain from those other relevant clubs/loyalty programmes (as the case may be) for the purposes of account binding (subject to your consent) or enabling and maintaining unified access control management functions for your relevant accounts (as the case may be) - Phone number
- Membership number
9. For our handling, administration and management of the relevant account administration, management and related functions of your various selected or designated clubs/loyalty programmes’ membership accounts for the purposes of enabling and maintaining unified access control for your various accounts on the relevant club/loyalty programme’s website, application and/or application platform, conducting the relevant data migration or synchronisation for or across your various accounts, unified/centralised management of certain member rewards/benefits initiatives (e.g. K Dollars) that may be applicable to your various accounts (as the case may be), and the consequent data transfers with the operators of such other relevant clubs/loyalty programmes for or relating to the aforesaid purposes - Name
- Membership number
- Phone number
- Email address
- Age Range
- Gender
- Language Preference
- Month of birth
- Date of birth
- Place of residence
- Transaction information (including your characteristics and transaction behavior)
- Credit card and electronic/digital payment information
10. For our operations, management, administration, processing and/or distribution of the relevant member rewards/benefits (if any) under the relevant promotional campaigns/events, trade promotion competitions, activities, accounts and/or arrangements for our member rewards/benefits initiatives (e.g. K Dollars) that you may be eligible for (if any), subject to our applicable terms and conditions/rules for the foregoing (as the case may be); and in the event that you may be claiming the eligible rewards/benefits (if any) with us through any other clubs/loyalty programmes of our Affiliates and/or our Marketing Partners and/or other participating companies you have registered or transacted with that honour or make available member rewards/benefits (“Other Participating Companies”) running your account(s) with them, for our processing of such cross-club/program claims and handling related data transfers of your relevant account information and transactional records with those other relevant participating clubs/loyalty programmes and/or Other Participating Companies running your account(s) with them (as the case may be) for the administration, processing and/or distribution of the relevant member rewards/benefits (if any) - Name
- Membership number
- Phone number
- Email address
- Age Range
- Gender
- Language Preference
- Month of birth
- Date of birth
- Place of residence
- Transaction information (including your characteristics and transaction behavior)
- Credit card and electronic/digital payment information
11. Registering you as a user of the Applications and/or the Website (as the case may be) - Name
- Membership number
- Phone number
- Email address
- Age Range
- Gender
- Language Preference
- Month of birth
- Date of birth
- Place of residence
12. Activating and linking your KDP rewards/benefits wallet with your relevant account(s) (and corresponding rewards/benefits wallet(s), if any/where applicable) of the other club(s)/loyalty programme(s) of our Affiliates and/or our Marketing Partners and/or Other Participating Companies running your account(s) with them (as the case may be) - Phone number
- Membership number
13. To serve you better and/or maintain your personal data and/or information across multiple pages within or across one or more sessions when using the Applications and/or the Website (as the case may be) - Log Files
- Tracking Data
14. Following registration as a user/member, accessing your account information (including, but not limited to, your name, membership number, etc.) and managing your account (including, but not limited to, changing your password, updating your personal information, subscribing/ unsubscribing from direct marketing, processing eligible member rewards/benefits (if any) for your applicable account(s), etc.) - Log Files
- Membership number
15. Research, development, and analysis in relation to your/customer behaviour including carrying out data sorting and analysis to enable us to better understand your characteristics and transaction behaviour to provide other goods and/or services better tailored to your needs, and to assist us in selecting Marketing Subjects that are likely to be of interest to you, and carrying out aggregated behavioural analysis, including using personal data for statistical analysis, data science studies and data mining. In the event that you have enabled the personalized recommendation feature on the Applications, your personal data will also be used for the AI Use-Cases (as further defined below) - Membership Number
- Email address
- Month of birth
- Gender
- Age Range
- Nationality / Place of residence
- Language Preference
- Marital Status
- Family Status
- Education Level
- Occupation
- Place of residence
- District
- Have kids or not
- Transaction information (including your characteristics and transaction behavior)
- Tracking data
- Credit card and electronic/digital payment information
16. For you to make enquiries, complaints, and/or suggestions to us in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future) - Name
- Phone number
- Email address
- Membership Number
17. Seeking your feedback, including through surveys, in relation to the Purposes and/or the Goods and Services (including, but not limited to, through an in-app text box on your mobile device or through our official social media page and/or our official website, or by text message, email and/or mail, and/or other media whether now known or available in the future) - Name
- Email address
- Membership Number
- Interests and favourite activities
- Transaction information (including your characteristics and transaction behavior)
18. Improving the Applications, the Website, the Purposes, and our and our Affiliates’ and Marketing Partners’ Goods and Services - Tracking Data
- Interests and favourite activities
- Transaction information (including your characteristics and transaction behavior)
19. Direct marketing and cross-marketing for the Marketing Subjects, subject to consent - E-mail address
- Gender
- Month of birth
- Date of birth
- Phone number
- Mailing/ correspondence address
- Tracking Data
- Interests and favourite activities
- Social media account information
- Transaction information (including your characteristics and transaction behavior)
20. Data analytics, profiling, information management and database administration - Interests and favourite activities
- Tracking Data
- Marital status
- Family Status
- Educational level
- Occupation
- Yearly Income
- Language Preference
- Place of residence
- Transaction information (including your characteristics and transaction behavior)
- Credit card and electronic/digital payment information
21. Deterring, detection, investigation and/or prevention of activities that may violate, or may be suspected to violate, our policies or may be abusive, illegal, and/or criminal subject to the applicable laws and regulations in the Mainland China - Name
- Contact details
- Transaction information (including your characteristics and transaction behavior)
- Credit card and electronic/digital payment information
22. Collection or recovery of any debt owed by you to us or our Affiliates - Name
- Contact details
- Transaction information (including your characteristics and transaction behavior)
23. The normal management, operation, and maintenance of the Applications, the Website and the provision of the Goods and Services to you, including without limitation sending messages and/or notifications to you in relation to the management, operation, maintenance and administration of the Applications, the Website and the provision of the Goods and Services - Membership number
- Transaction information (including your characteristics and transaction behavior)
24. Storing your personal data (whether by a single or multiple Affiliates (including us) or our Marketing Partners) for the purpose of sharing such personal data with our Affiliates and/or our Marketing Partners for any and all of the other Purposes listed above - Membership number
- Transaction information (including your characteristics and transaction behavior)
- In general, we process Minors’ personal data with their parents’ or legal guardians’ consent, and where appropriate, with separate consent from their parents or legal guardians for processing Minors’ personal data under specific circumstances required by the applicable data protection laws and regulations in Mainland China. Besides, disclosure of Minors’ personal data as above mentioned will be conducted in accordance with the applicable data protection laws and regulations in Mainland China.
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4. Minors’ rights as the personal data subjects
Clause 4 of the Addendum applies to the extent that you as a Minor, or as the parents or legal guardians of the Minor(s), may exercise the Minor(s)’ rights as provided therein.
5. Retention of personal data
Clause 5 of the Addendum applies only to the extent for the Purposes for Minors.
In addition, we strictly control the access to Minors’ personal data and only allow authorised personnel that are strictly necessary to process Minors’ personal data to access such data.
6. How we entrust others to process, share and transfer Minors’ personal data
Clause 6 of the Addendum applies only to the extent for the Purposes for Minors.
7. How we store and transfer Minors’ personal data
Clause 7 of the Addendum applies only to the extent for the Purposes for Minors.
8. This clause is intentionally left blank
9. Miscellaneous
Clause 9 of the Addendum applies.
10. How to contact us
Clause 10 of the Addendum applies to the extent that you as a Minor or as the parents or legal guardians of the Minor(s) may contact us or exercise the Minor(s)’ rights over their personal data as provided therein.
11. Inconsistency or conflict
Clause 11 of the Addendum applies.