GR8 Leisure Concept Ltd. respects the privacy of all its customers and business partners, and treats personal data provided by you as confidential. We pledge to fully comply with the requirements of the Personal Data (Privacy) Ordinance Cap. 486 (“Ordinance”) of Hong Kong.
This Policy gives effect to our commitment to protect your personal data and has been adopted by all of the hospitality properties owned, managed and/or operated by GR8 Leisure Concept Limited or its affiliated or associated companies. References to “GR8 Leisure Concept Ltd”, “we”, “our” and “us” hereinafter, depending on the context, collectively refer to those separate and distinct properties or entities.
Collection of Personal Data
The term “personal data” in this Policy refers to personal information that can be used to identify you as an individual. It can include, among other things, your name, contact number, address, age, gender, passport or other identification document details, personal financial information, or travel partner information.
You can visit our website without providing any personal data. When we need to collect personal data from you to provide you with a particular service, we will ask you to voluntarily supply us with the information we need.
Personal data may be collected as part of: (i) fulfilling requests for information or services, (ii) accommodating your personal preferences, (iii) purchasing our products or services, (iv) submitting job applications and (v) facilitating communications.
You may always choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a reservation without a name).
How we use Personal Data
We will only use your personal data fairly and where we have a lawful reason to do so.
We are allowed to use your personal data if we have your consent or another legally permitted reason applies. These include to fulfil a contract with you, where we have a legal obligation to do so, or when it is in our legitimate business interest to use your personal data. We can only rely on our legitimate business interest if it is fair and reasonable to do so.
We may use relevant portions of your personal data in order to:
- process and/or confirm hotel arrangements and restaurant reservations;
- provide and charge for goods and services you purchase;
- provide privileges, benefits and services to you;
- provide you with a better, more personalised level of service;
- conduct market analysis, market research, customer satisfaction, and quality assurance surveys;
- respond to requests for information and services;
- provide for the safety and security of guests;
- administer general record keeping;
- facilitate direct marketing, promotional and customer management purposes, including sending you sales promotional communications or special offers if you have consented to receive the same;
- facilitate matching for whatever purpose with other personal data;
- disclose the winner of contests and lucky draw competitions conducted by us or on our behalf; and
- meet legal and regulatory requirements.
We will only process special category data where the processing is necessary to facilitate your requests or to provide you with goods and services you require and for the purposes stated above or with your explicit consent.
Disclosures and Transfers of Your Personal Data
From time to time, we may disclose and transfer your personal data (whether within or outside of Hong Kong) to GR8 Leisure Concept Ltd’s business units to facilitate your requests or provide you with goods and services you require and for the purposes described under the section “How we use Personal Data”.
We do not permit the sale or transfer of personally identifiable information to third parties.
When personal data is transferred from the European Union (“EU”) and European Economic Area (“EEA”) to outside the EU and EEA, we use the model clauses approved by the European Commission to ensure that such data transfers are compliant with applicable privacy legislation.
Visitors to our website www.gr8lc.com do so on an anonymous basis. We have not configured our website to collect any information from your computer without your consent. This means that unless you voluntarily and knowingly provide us with information, we will not know your identity, your email address, or any other information identifiable to you.
It is our intention to only send you mail and email communications that will be useful to you and that you may want to receive. When you indicate that you would like to receive promotional material either on a guest comment card, through the newsletter sign-up form on the website, or patronise our restaurants and provide your email address to us specifically and expressly in order to receive marketing communications, we will periodically contact you via email and provide information about special offers and promotions that may be of interest to you.
These communications will relate to offers relating to GR8 Leisure Concept Ltd and the brands operated by our group companies. We typically use third party email service providers to send emails. These service providers are contractually prohibited from using your email address for any purpose other than to send emails related to our group operations. Data will not be shared with third parties for their own marketing purposes.
We provide you with the ability to unsubscribe from all marketing communications. Every time you receive an email, you will be provided with the choice to opt-out of future emails by following the instructions provided in the email. You may also opt-out of receiving promotional materials by sending a letter or fax to our Data Protection Officer (see details set out in the section “Your Rights regarding Your Personal Data” below).
Our Commitment to Data Security
To maintain the accuracy of your personal data, as well as preventing unauthorised access to and ensuring the correct use of your personal data, we have carried out appropriate physical, electronic, and managerial measures to safeguard and secure the personal data we collect. These measures are subject to ongoing review and monitoring. Whilst we make every effort to protect your personal data, no security measures can guarantee that your personal data will not be subject to interference, misuse, or hacking and we shall not be responsible for any loss, misuse, or alteration arising as a result of such incidents.
Children and Minors
This website is not intended for children and minors and we do not knowingly solicit or collect personal data from children and minors. As a parent or legal guardian, please do not allow your children to submit personal data without your permission.
To enhance your experience on our web site, some of our web pages may use “cookies.” Cookies are text files that we place in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your email address or other personally-identifiable information unless you choose to provide this information to us by, for example, registering for one of our services. However, once you choose to furnish the site with your personally-identifiable information, this information may be linked to the data stored in the cookie.
Keeping Your Personal Data
We do not keep your personal data for any longer than is necessary to fulfil the purpose for which we collected it, or to comply with any legal, regulatory or reporting obligations or to assert or defend against any legal claims.
Your Rights regarding Your Personal Data
You are entitled to access and make changes to or update any personal data relating to your profile held in our database. You should update the personal data held by us whenever there is a change or if it is incorrect, so that we can keep your data accurate and up to date. Further, you have the right to:
- object to our use of your personal data more generally;
- require us to erase your personal data without undue delay;
- restrict our processing of your personal data so that the processing can only continue subject to restrictions; and
- require personal data which you have provided to us and which are processed by using automated means, based on your consent or a contract with you, to be provided to you in machine readable format so that they can be portable to a replacement service provider.
If you have any questions about this Policy, or if you would like to submit a request for access to or change of the personal data that we maintain about you, or to object our use of your personal data or exercise your rights stated above, or make a complaint, please contact our Data Protection Officer by email at firstname.lastname@example.org; or by fax at (852) 2526 4833; or by post to
Data Protection Officer
GR8 Leisure Concept Ltd – Marketing Communications Department
16/F MW Plaza
40 Kimberley Road
Tsim Sha Tsui, Kowloon
We reserve the right to charge a reasonable fee for the processing of any such access request. As indicated above, all requests for access to your personal data must be submitted in writing. When communicating your request, please be sure to include your full name, address, and telephone number so we can ascertain your identity, and specify clearly the type of enquiry and the original source of data collection.
It is important to note that all email communication is not secure. There is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email, for example, from the “Get in Touch” section of our website. We recommend that you do not include any sensitive information including credit card details when using email or using any public computers/public Wi-Fi. Our email responses to you may not include any sensitive or confidential information. Please bear in mind that no security system or system for transmitting information over the Internet is guaranteed to be secure.
To be prudent, it is advisable to always close your browsers when you have finished completing a form or a reservation. Although the session will automatically terminate after a short period of inactivity, it is easier for a third party to gain access to your profile whilst you are logged onto our website and making a reservation.
Changes to the Policy
This Policy was updated in June 2018. In the future, we may need to modify this Policy and make additional changes. Any changes to this Policy will be included in the latest version published on this website, so that you will always understand our current practices with respect to the way we collect and use your personal data. Updated versions of our Policy will include the date of the revision so that you are able to check when the Policy was last amended.
Any changes to our Policy will become effective upon posting the revised Policy on the website. Use of the website following such changes constitutes your acceptance of the revised Policy then in effect.
This Policy complies with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region as well as applicable local laws.
This Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.