Privacy Policy

This privacy policy sets out how Hong Kong Business Aviation Centre Limited (“HKBAC”, “us” or “we”) collects, stores and handles the personal data of its customers.

HKBAC may change this privacy policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

On 25 May 2018 the EU General Data Protection Regulation (“GDPR”) came into effect. GDPR will apply to our EU based customers and, as part of our commitment to privacy and greater transparency, we have updated our privacy policy accordingly.

1. Your privacy
HKBAC is committed to protecting your personal data and will at all times observe relevant legislation in the collection, use and maintenance of your personally identifiable information.

2. What information do we collect?
We may request information from you which may be used to identify you personally (“Personal Data”), including but not limited to:
a. Your personal information such as your name, gender, date of birth, nationality, passport or other personal identification number;
b. Your contact information such as your telephone number, mailing address or email address;
c. Your credit or debit card information and billing information;
d. The name of the aircraft owner;
e. Your business information such as company name, business title and associated contact information; and
f. Your flight details, such as meal and service preferences and other requirements.

If certain Personal Data is requested in relation to specific services but not supplied by you, we may be unable to provide the services to you in whole or in part. We will notify you if this is the case at the time.

3. Use of cookies
A cookie is a small amount of data created in a computer when a person visits a website on a computer. It often includes an anonymous unique identifier, which can be used to identify a computer. A cookie is not however used to collect any personal information, and nor can it identify an individual user of the website.

We use session cookies on the HKBAC website and mobile operating system. These are temporary cookies that allow us to link the actions of a user during a browser session. A browser session starts when you open the browser window and finishes when you close the browser window. Session cookies are created temporarily. Once you close the browser, all session cookies are deleted.

You have the ability to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the features on the HKBAC website and mobile operating system if cookies have been disabled completely.

4. How we use your Personal Data
We may use the Personal Data you provide for one or more of the following purposes:

a. For the performance of a contract, including  processing and administering your booking of our services;
b. For the supply of any services which we may offer to you or you may require from us from time to time including alerts by text message (SMS) and other forms of messaging;
c. For identification and verification purposes in connection with any of the services that may be supplied to you;
d. Where it is necessary for our legitimate interests (or those of a third party). This means our legitimate interest in conducting and managing our business to enable us to give you the best products and services 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;
e. Where we need to process your Personal Data in order to protect the vital interests of you or another natural person, e.g. where you require urgent assistance;
f. Where we need to comply with a legal or regulatory obligation (please see section 9 below)
g. To contact you.
h. To facilitate the payment for services provided or arranged by us, including verification of credit card details with third parties and to detect or prevent fraudulent transactions;
i. To improve our products and services; and
j. For marketing, promotional and customer relationship management purposes.

We will only use your personal data for the purposes for which we have collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

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 (please see section 5 below) or for special categories of Personal Data i.e. sensitive personal data.

Where special categories of Personal Data (this could include details about your race or ethnicity, religious beliefs and information about your health and genetic and biometric data etc.) are collected and processed to provide certain services to you, we will obtain your explicit consent to do so beforehand.

5. Direct marketing
Occasionally, we may use your Personal Data to send you marketing communications such as emails containing news, offers, promotions and joint marketing offers about our services. However, we will only do this if you provide your consent. When providing us with your Personal Data, you may give your consent by ticking a box indicating your consent.

You may opt out from receiving marketing communications at any time, free of charge, by writing to us at the address below or by emailing us at hkbac@hkbac.com.

6. Accessing your Personal Data
It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us. You may request access to, or correction or deletion of, your Personal Data held by us or object to, or restrict, further processing of your Personal Data (this will not affect the lawfulness of any processing carried out before you withdraw your consent). Any such request must be in writing and sent to the following address:

Customer Service Department
Hong Kong Business Aviation Centre Limited
12 South Perimeter Road, Hong Kong
International Airport, Lantau, Hong Kong

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.

7. Links to other websites
The HKBAC website and mobile operating system may contain links to other websites that are operated by third party companies with different privacy practices. You should remain alert when you leave our system and read the privacy statements of other websites. We have no control over Personal Data that you submit to or receive from these third parties.

8. Security
We are committed to ensuring that your Personal Data is secure. In order to prevent unauthorised access or disclosure, we have implemented appropriate physical, technical and administrative measures to safeguard and secure the Personal Data we collect. We have put in place procedures to deal with any suspected Personal Data breach and we will notify you and any applicable regulator of a breach where we are legally required to do so.

9. Disclosure and transfer of Personal Data
We will not sell, distribute or lease your Personal Data to third parties except as indicated in this privacy policy.

For the purposes of providing the services and products requested by you, we may disclose and transfer Personal Data to certain companies who we consider appropriate.

The entities with whom we may share your Personal Data include but are not limited to:
a. any agent, contractor or third party service providers including hotel, catering or towing companies;
b. credit reference agencies;
c. credit or debit companies and/or banks; and
d. government or non-government authorities, agencies, and/or regulators..
We may disclose your Personal Data to relevant third parties, whether within or outside Hong Kong, where we are required to do so by law, regulatory requirement or government or law enforcement authorities (such as immigration and customs control and/or border control agencies), or where we have otherwise requested and obtained your express consent. Please be advised that some jurisdictions offer less protection of Personal Data than that provided in Hong Kong.

If HKBAC restructures or has a change in corporate control we may transfer your Personal Data to relevant parties.

10. Data controller
Any Personal Data provided to or gathered by HKBAC is controlled primarily by HKBAC.

11. Retention of data
All Personal Data that has been collected from you will only be stored for a limited duration that is relevant to the purpose for which it was processed and for as long as required by applicable law.

Last updated: 7 June 2018

This Terms & Conditions are available within our facility and on our website at www.hkbac.com.


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