THE ABERDEEN MARINA CLUB PRIVACY POLICY

Introduction
The Aberdeen Marina Club (referred to as "Club", "we", "us", or "our") respects your privacy, and is committed to protecting the privacy, confidentiality and security of the personal data you provide to us or that we collect about you when you use our mobile application (“APP”) and our website at (“Site”), which are owned and managed by the Club, when you contact our membership team, or when you otherwise interact with us. For the purposes of this Privacy Policy, “personal data” shall have the meaning as given to it by the Personal Data (Privacy) Ordinance (Cap. 486) (“Ordinance”) of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong SAR”).
This Privacy Policy explains our personal data practices and the choices you can make about the way your personal data is used. This Privacy Policy gives effect to our commitment to protect your personal data and serves as the guidelines to be observed by us.
You will be asked to consent to the terms of this Privacy Policy when you first download and open the App or login to your membership account via the Site, including when making reservations for Club activities, events or restaurants, purchasing goods or services, or otherwise corresponding with us through the Site.  Your continued use of the App and the Site will constitute your deemed consent to, or acknowledgement of, the terms of this Privacy Policy.
The Club at 8 Shum Wan Road, Aberdeen, Hong Kong SAR is responsible for using your personal data. For any questions concerning your personal data or other general inquiries, you can contact our membership team at .

Types of Personal Data We Collect
Information you provide to us: we collect personal data (including where applicable sensitive personal data) you provide directly to us. This includes:

    • your personal information, such as your full name, gender, date of birth, contact information (e.g. country of residence, physical address, email address and phone number), photographs, facial recognition data, marriage certificate, birth certificate, nationality, and identification information (e.g. HKID, passport, and visa information);
    • your Club membership information, such as membership number, account details, and profile details;
    • your payment information, such as bank account details, credit card or other payment card information (where required), and billing address;
    • any information necessary to fulfill your special requests;
    • your reviews, preferences, feedback, and opinions about our membership, Club facilities, activity classes, or goods and services provided by the Club; and
    • any other personal data you choose to provide to us.

Information We Collect Automatically When You Use our APP and Site: when you access or use the APP or the Site, we automatically collect personal data about you, including:

    • Log Information: we may collect system log information about your use of the APP and the Site, including the access times, pages viewed, your IP address and the page you visited before navigating to the APP and the Site.
    • Device Information: we may collect information about mobile device you use to access the APP and the Site, including the hardware model, operating system and version, and unique device identifiers.
    • Push related (Android and iOS): In order to ensure that the App can normally receive broadcast information pushed by the Club when the App is closed or running in the background, the App must use the (self-start) capability. There will be a certain frequency of sending broadcast through the system to wake up the self-start or associated startup behavior of the App, which is necessary for the realization of functions and services.  When you open push messages, relevant content will be opened after obtaining your explicit consent. There is no associated startup without your consent.
    • Information Collected by Cookies: we and our service providers use various technologies to collect information, including cookies. Cookies are small data files stored on your device memory that help us improve the Site and your experience, see which areas and features of the Site are popular and count visits. For more information about cookies, and how to disable them, please see our .

Information Collected for Device Permissions: To enhance your experience with the APP and the Site, we require certain device permissions during use. We will request your consent before enabling any permission, allowing you to “allow” or “deny” each request. Once authorized, we will enable the relevant permissions. You can withdraw authorization through your system settings at any time. Please note that withdrawing authorization may limit access to certain functions, but it will not prevent the use of other functions of the APP or the Site. There are specific permissions that we may require from you. For example: 

    • (App only) Notifications/ push notifications: to enable receipt of notification messages, which may include reminders, sounds, and icon badges.
    • (App only) Camera permission: to allow access to the camera to take photos for use in various membership application forms.
    • (App only) Photo permission: to access photo albums and upload photos for use in various membership application forms. 
    • (App only) Biometric sign-in: to enable fast and secure access to the APP.
    • Calendar permission: to add bookings or reservations to your calendar as reminders or notes.
    • Storage permission: to access files stored on your device for use in various membership application forms. 

You can review the details of your privacy permissions and disable specific permissions through system settings. The methods of displaying and disabling permissions may vary depending on your device. Please refer to the instructions or guides provided by your device manufacturer or operating system provider for more details. 
Information We Collect From Other Sources: we may also obtain personal data via third party SDK platforms and from public sources and combine that with information we collect through the App and the Site where we believe that it is necessary to help manage our relationship with you.
Where you provide personal data of third parties (for example, names, gender, date of birth, relationship and contact details of your family members in connection with bookings or family memberships), you confirm that you have their consent or rely on applicable legal basis to provide their personal data to us. We recommend you show them this Privacy Policy.

How We Collect, Use and Disclose Your Personal Data
We may collect, use, and disclose your personal data for the purposes set out below.
For the performance of our agreement with you, in order to:

    • register, process, administer, and manage Club membership and other relevant membership applications, including (i) assessing eligibility for membership accounts for members and their spouses, children, other family members, visitors and guests; (ii) verifying identity; (iii) issuing membership cards; (iv) enabling the use of membership facilities, activity programmes, benefits, and privileges; and (iv) providing car park services, including the issuance and re-issuance of car parking labels;
    • process, confirm, provide, deliver and charge for the use of Club facilities, and/or the purchase of goods and services as well as event bookings, reservations and activity registrations made through the APP or the Site;
    • monitor, control, and manage your use and access to Club facilities, activity programmes, benefits, and privileges and process payments for such use and access; and
    • provide you with access to the content on the APP and the Site, and respond to your enquiries and requests for information and services.

For our legitimate commercial interests, in order to:

    • better understand how our Club facilities, activity programmes, membership benefits and privileges, and goods and services impact you, so as to providea more personalised level of service and to further develop our Club facilities, activity programmes, membership benefits and privileges, and goods and services;
    • monitor your use of the APP and the Site and conduct analysis of the use of the APP and the Site in order to operate, evaluate, and improve the APP, the Site and our services, understand your preferences, and troubleshoot any problems; and
    • conduct market analysis, market research, member satisfaction and quality assurance surveys to improve our Club facilities, activities, membership benefits and privileges, and goods and services offered on the APP and the Site.

For compliance with legal obligations to which we are subject, in order to:

    • meet legal and regulatory requirements and administer general record keeping;
    • prevent, detect and investigate crime and analyse and manage commercial risks (such as fraud, debt recovery and management); and
    • conduct investigations.

Use of information based on your consent:

    • to facilitate direct marketing, promotional and membership management purposes, including sending you promotional communications (including without limitation, emails and push notifications) or special offers if you have consented to receive the same; and
    • for any other purposes for which we have obtained your consent.

In order to complete a purchase order, or make an enquiry, you must provide us with the personal data marked with an asterisk or otherwise indicated as mandatory, otherwise we may not be able to process your request or comply with our legal obligations.

Disclosures of Your Personal Data
We may share your personal data to the following entities and parties, for the purposes listed above (where applicable):

      • between and among the Club and its affiliates and their respective employees as are relevant for the above purposes and to facilitate the operation of our business, but we shall only do so on a need-to-know basis;
      • with third-party payment processors, payment service providers, banks and financial institutions, IT and marketing support service providers and other consultants, vendors and service providers who need access to such information to carry out work, provide goods or services on our behalf, charge for goods or services provided to you, or who help us to provide the APP and the Site to you;
      • with third-party vendors or service providers who need access to such information for development and maintenance of the APP and the Site, providing technical support, and delivery of ordered goods and services;
      • with any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;
      • any business partner, investor, assignee, or transferee (actual or prospective) in connection with, or during negotiations of, or to facilitate any business asset transactions (which may extend to any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or any change of management of the Club);
      • with our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
      • with any other party at your consent or at your direction or whom you authorise us to disclose your personal data to; and
      • otherwise as permitted or required by Hong Kong law.

Your personal data will be stored in Hong Kong SAR.

Direct Marketing
From time to time, we would like to use your name, physical address, email address, mobile phone number, and other relevant contact information to send you either via emails, SMS messages, push notifications, post, or information that we think may be of interest to you, including about the Club facilities, activity programmes, and  goods and services available on the APP and the Site.
You may choose not to receive marketing communications or opt-out from receiving marketing communications at any time, free of charge, by following the unsubscribe instructions contained in the marketing communications or contacting us in accordance with the section “Your Rights and Contact Us” below. If you opt out of these communications, we may still send you non-promotional communications, such as those about your purchase details or members communications, unless we are prohibited from doing so by Hong Kong law.

Retention of Personal Data
To the extent required or permitted by Hong Kong law, we take reasonable steps to delete, destroy, de-identify or redact personal data in a secure manner when retention is no longer necessary for legal or business purposes for which it was collected (as set out in this Privacy Policy) or when requested by you.

Our Commitment to Data Security
We have in place reasonable technical and organisational measures to prevent unauthorised or accidental access, processing, erasure, loss or use of your personal data and to keep your personal data confidential. These measures are subject to ongoing review and monitoring. To protect your personal data, we also require our third-party service providers to take reasonable precautions to keep your personal data confidential and to prevent unauthorised or accidental access, processing, erasure, loss or use of personal data, and to act at all times in compliance with Hong Kong law.
We cannot guarantee that the APP and the Site will function faultless and without any interruptions. We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programs used for electronic communications and transmission of viruses.
We recommend that where applicable, you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

Third Party Sites
The APP and the Site may contain links to other websites, apps, content, services or resources on the internet which are operated by third parties. If you access other websites, apps, content, services or resources using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these sites. Please check these policies before you submit any personal information to these sites.

Minors
We do not knowingly collect personal data from minors. If you are a minor, you may only use the APP and the Site with the permission of your parent or guardian.

Your Rights and Contact Us
You have the right to request access to, and a copy of, your personal data held by us, and to request correction of any personal data that is inaccurate. Whenever reasonably possible and required, we will strive to respond to your request within forty (40) days after receiving your request.  Where we are unable to comply within that period, we will notify you in writing and comply with the request as soon as practicable in accordance with the Ordinance.  
You may also withdraw your consent to receiving direct marketing communications at any time. You may in certain circumstances ask us to delete your personal data, in which case, to the extent permissible by Hong Kong law, we will take reasonable steps to delete or de-identify your personal data. Please note that we may not be able to continue providing services to you if you entirely withdraw your consent or ask us to delete your personal data entirely, and this may also result in the termination of any agreements with the Club.
For all matters relating to your personal data, including questions, requests, or complaints, please contact us by email at or by post at 8 Shum Wan Road, Aberdeen, Hong Kong SAR.

Changes to the Privacy Policy
We may modify this Privacy Policy from time to time. Any changes to this Privacy Policy will be posted to the APP and the Site so that you are always informed of the way we collect and use your personal data, and we encourage you to review this Privacy Policy whenever you access the APP and the Site or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. Updated versions of this Privacy Policy will include the date of the revision at the end of this Privacy Policy so that you are able to check when the Privacy Policy was last amended. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the APP and the Site. Use of the APP and the Site following such changes constitutes your acceptance of the revised Privacy Policy then in effect but, to the extent such changes have a material effect on your rights or obligations as regards our handling of your personal data, such changes will only apply to personal data after the changes are applied.

Governing Law
This Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong SAR.

Last Updated: 28 April 2026