Privacy Policy - ELEMENTS CLUB
  1. Your Privacy
  2. MTR Corporation Limited ("MTR Corporation", "we", "our" or "us") respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy explains our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region and all related codes of practice and guidance notes issued by the Privacy Commissioner. In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality. Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This policy may from time to time be revised, or otherwise changed where we deem necessary but we will give you advance notice of any such revision or change. If there is any inconsistency between the English and Chinese version of this Privacy Policy, the English version shall prevail. "Personal data" means any personally identifying information or sensitive data (such as names, occupations, addresses, contact details, ID Card or Passport numbers, Octopus Card numbers, credit card information, your age, your marital status, your employer, your income) from which it is practicable for the identity of an individual to be ascertained.

  3. Purposes for which we will use your Personal Data

    We collect your personal data when you apply for the Programme membership. If you are under the age of 13 you must ask a parent or your guardian before providing any personal data to us. If you want us to process your application to be a Programme member, you must provide the personal data marked as mandatory in the Membership Registration Form. Such personal data provided by you will be used by ELEMENTS for the purposes of: (a) application, administration, continuation and termination of your membership of the Programme; (b) providing you with news, notices and other communications of ELEMENTS CLUB and/or MTR Corporation; (c) verification of your identity; (d) redemption of bonus points and issuance of redemption letters; (e) handling and following up service calls, enquiries and complaints; (f) meeting the requirements to make disclosure to any governmental authority in Hong Kong under the requirements of any law binding on MTR Corporation; and (g) to enable us to better understand the demographics of our Members.

    It is entirely voluntary for you to provide personal data which is not marked as "mandatory" in the Membership Registration Form. Purposes for which it is only voluntary for you to provide your personal data are: (a) to enable us to better understand the demographics of our Members; and (b) to enable us to provide other services better tailored to your needs.

    Use of Data in Direct Marketing
    We intend to use your personal data for direct marketing purposes, the details of which are stated in our Personal Information Collection Statement. If you object to our use of your personal data for the relevant direct marketing purposes, please tick the box at the bottom of our Personal Information Collection Statement before you sign at the end of this form. If you do not tick the box, you agree that we may use your personal data for the relevant direct marketing purposes.

  4. Disclosure

    In cases where we do collect personal data from you, we will: (a) tell you (by way of our Personal Information Collection Statement or by a separate notification) that we are doing so and the use that we will make of such personal data we collect; (b) where relevant, give you the opportunity to object to the use of your personal data in direct marketing; and (c) tell you how we will store your personal data and how you can review, change and delete the personal data we have stored.

    We will take all practicable steps to keep your personal data confidential but we may transfer/assign such data to the following parties: (a) if MTR Corporation decides to sell any relevant part of its business, to any actual or proposed assignee, transferee or successor of or to MTR Corporation's rights in respect of your personal data; (b) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, redemption services and other services to MTR Corporation and/or the Programme; (c) any person to whom MTR Corporation is under an obligation to make disclosure under the requirements of any law binding on MTR Corporation or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which MTR Corporation is expected to comply.

  5. Security

    Except as mentioned in paragraph 3 above, your personal data, however stored, will be accessed only by our employees or contractors who are authorised to do so. Where personal data is stored electronically, it will be kept on a secured server and will be password-protected (or under some equivalent form of protection) and accessible only by authorised personnel of MTR Corporation or its contractors. Employees and contractors designated to handle personal data will be instructed to do so only in accordance with this Privacy Policy.

  6. Use of Personal Data in Legal Proceedings

    If it becomes necessary that we have to take action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and taking legal action against you.

  7. Your Right to Access and Correction

    You may at any time request access to and to correct personal data relating to you in any of our records. You may also ask us to delete you or your personal data from any active mailing or distribution list. To exercise any of your rights, contact us at the address, facsimile number or email below, marking your communication "Confidential". In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days, but we may charge you a reasonable fee for doing so.

  8. Personal Data Privacy Officer

    The person to whom (1) requests (i) for access to data or correction of data, (ii) for general information regarding our policies and practices with respect to personal data and (iii) about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:

    Personal Data Privacy Officer, Secretarial & Legal Department (Marked Confidential)
    Address: MTR Headquarters Building, Telford Plaza, Kowloon Bay, Kowloon, Hong Kong

  9. Retention of Data

    We will keep your personal data for as long as necessary to fulfil the purpose for which the data was collected. We may also retain archived personal data for statistical purposes. Personal Data which is no longer required will be destroyed.