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Customer privacy policy

Cathay Pacific Customer Privacy Policy – Mainland China

When you use Cathay Pacific’s services, you entrust us with your Personal Information. This Cathay Pacific Customer Privacy Policy – Mainland China (“Privacy Policy”) sets out what information we collect, and how we use it for individuals based in the People’s Republic of China (“PRC”).

This Privacy Policy also applies when you buy travel packages from us or from Cathay Holidays Limited (or its subsidiaries).

Cathay Pacific also offers the Cathay Membership Programme, our loyalty programme. If you are a Cathay Membership Programme member, this Privacy Policy also explains how Cathay Pacific uses and shares any Personal Information in connection with your membership.

1. Our Commitment to Protect Your Privacy

At Cathay Pacific, we are committed to protecting your Personal Information and your privacy. To ensure that you can make informed decisions and feel confident about sharing certain Personal Information with us, please read this Privacy Policy to understand who we share your Personal Information with and for what purposes, and the choices you have concerning how your Personal Information is collected and used by us. We may also provide further privacy collection notices highlighting certain uses of your Personal Information, together with the ability to opt in or out of certain uses, when we collect Personal Information from you.

We will notify you of any changes to our Privacy Policy, including by posting the revised policy on https://www.cathaypacific.com. The changes will be effective from the date of posting.

By visiting our website, using its services, or otherwise interacting with us, you acknowledge that you have read and understood this Privacy Policy and agree that we may collect, use, store, transmit and disclose your Personal Information in accordance with this Privacy Policy.

2. The Personal Information We Collect

Personal Information means any type of information (recorded via electronic means or otherwise) associated with an identified or identifiable natural person, excluding information after anonymisation handling. Personal Information may include Sensitive Personal Information.

Sensitive Personal Information refers to Personal Information that, once leaked or illegally used, is likely to lead to the violation of the personal dignity of natural persons or harm to personal and property safety, including biometric identification, religious belief, specific identity, medical and health care, financial accounts, whereabouts and track, as well as the Personal Information of minors under 14 years of age. In this Privacy Policy, Sensitive Personal Information is in bold and underlined to draw your attention.

2.1 We will collect and process the following Personal Information about you:

Your Personal Information such as your full name, salutation, gender, date of birth and nationality, travel document details including passport number, passport expiry date, country that issued your passport and your country of residence (this information is also known as Advanced Passenger Information (API)), your contact details, your parents’/guardian’s names and contact details, address, and photographs and other images;

Payment details used to purchase our products and services such as credit or debit card number and expiry date, account information relating to other payment services (such as online or mobile payment services or virtual currency) and billing information;

Information about your travel arrangements such as your travel itinerary, hotel selection, your choice of tours, car rentals or other add-ons to your travel package, details of your travel companions or persons assisting you, your activity at airport departure and arrival halls, your redemption group members, seat and meal preferences, your emergency contacts and any information relating to any special assistance that you require such as dietary requirements or health issues;

Information provided in your application to join the Cathay Membership Programme, your membership number, your username and your earning and claiming of Status Points or Asia Miles, and details about your nominated companions;

Information such as previous travel arrangements, feedback about your experiences, details of lost luggage and other claims, your use of our inflight entertainment system and inflight connectivity, and your purchase of our duty-free products and branded items;

Information that we collect about your interests, preferences, and opinions such as your hobbies, your language preference, destinations you are interested in and products and services you have bought;

A record of any interactions and correspondence between us such as calls made through our call centre, any interactions you have with our staff or representatives (including whilst on board our flights) and any interactions with us or posts that refer to us on social media;

Your responses to surveys and contests conducted by us or on our behalf;

Details of your visits to our website, your use of social media platforms and our mobile applications and other information collected through cookies and other tracking technology including information that you look at, such as your cookies, device ID, geolocation, login ID and web/behavioural tracking. We may also collect information about you that is publicly available online, including your social media profiles; and

If you are an employee or other person travelling or obtaining products or services in relation to our corporate/business travel services or one of our corporate or government clients, we will collect certain information about your employment, company information or relationship with our corporate or government clients such as your company’s or employer’s name, your professional title, and your work contact information.

We will collect and handle Sensitive Personal Information, for example, your passport identity information, your credit or debit card information, information of your minor children or dependents or when we handle requests for special medical or access assistance or your specific dietary requirements that may indicate your religious beliefs and health issues. We will ask you for your separate consent when collecting and handling your Sensitive Personal Information.

2.2 Certain Personal Information (particularly details of your travel documentation, payment details, and contact information) are required for many of our products and services and if you fail to supply such Personal Information as requested for specific services, we may be unable to deliver you the products and services in full.

 

3. How we collect Personal Information

3.1 We will collect some Personal Information from you directly. We will collect other Personal Information from third parties including: (a) travel agents (including corporate travel managers) and other persons that make bookings or otherwise interact with us on your behalf; (b) our service providers and agents such as our ground handling agents who assist you with check-in and boarding or our call centre agents who provide customer service; (c) third parties such as other airlines, providers of other travel-related services; (d) our third party marketing partners; (e) the third parties that we partner with in connection with the Cathay Membership Programme, including credit card issuers, hotel operators, retailers, and restaurants; (f) the operator of our loyalty programme (i.e. Asia Miles Limited); (g) organisations which conduct credit, fraud, and other passenger checks; (h) immigration, customs, border security and law enforcement bodies, airport authorities and other government or regulatory bodies; and (i) providers of third party websites, apps, and social media platforms.

3.2 If you provide us with information about other individuals, you must tell those individuals and let them know where they can find a copy of this Privacy Policy, and obtain their lawful consent if required under applicable laws.

3.3 If you were a member of Asia Miles or Marco Polo Club loyalty programmes, we have obtained your Personal Information through those programmes to continue offering you our services, now under the name of Cathay Membership Programme, and to maintain your tier status and miles balance.

3.4 Your Personal Information may be accessed, transferred and/or stored outside of China by staff or suppliers.

 

4. Why we collect and use your Personal Information

4.1 We may collect, store, and use your Personal Information to provide our service and products to you, or to improve our services. Below we have listed the purposes for which we process your Personal Information and the types of Personal Information corresponding to each purpose:

When you purchase a ticket through our online platforms, we will collect the passenger’s name, title, mobile number, passenger type, email address, membership number, departure location, travel destination, travel category (round trip/single trip), flight number, flight time, cabin class, seat number, and payment information (credit or debit card information, payment record). The above information is necessary to complete the purchase of tickets, and will be used to identify and verify your identity, to handle travel and service arrangements for you, to contact you and send you communication information about the services, and to provide you with travel packages or requested services, if you do not provide such information, you will not be able to purchase tickets and enjoy subsequent services.

You may choose to provide us with your Frequent Flyer Membership Number so that you can earn mileage and status points under the Cathay Membership Programme or our other partner airlines.

In addition, we will continue to use the above information when you, through our online platforms, change your ticket, refund your ticket, pre-check in, and manage your trip. In order to provide you with a better travel service, we may also collect information about your lost baggage and other claims, your use of in-flight entertainment systems and in-flight connectivity services, as well as your purchase of duty-free products and brand product information.

When you book the hotel through our online platforms, we will collect your name, contact information, country, residence address, check-in and check-out date, hotel information, payment information, and travel destination.

If you book the flight ticket on our online platforms on behalf of other passengers, you are required to submit these passengers’ name and contact information. You should ensure that you have obtained such passengers’ consent on providing their Personal Information to us before booking the flight ticket.

When you register as a member through our online platforms, we will collect your name, title, mobile number, date of birth, email address, and the password you set. The above information is necessary for the completion of membership registration and is also necessary for us to provide membership services for you. If you do not provide such information, you will not be able to register as a member.

In addition, you may choose to provide us with your mailing address, country or territory of residence, travel documents (including passport number, passport validity date, country/territory of issue and country/territory of residence) associated accounts, emergency contacts, frequent flyer programmes of partner airlines, seat and meal preferences, so that we can provide you with better service and experience. However, even if you do not provide this information, it will not affect your membership and access to the corresponding basic services.

When you log in to our online services, we require you to enter your mobile number (or email/membership number/username) and password, or complete the login through an associated account. This information is necessary to complete the login. If you do not provide this information, you will not be able to successfully log in.

When you choose to join the Cathay Pacific Membership Programme, we will collect your membership number, user name, accumulated and claimed membership points or “Asia Miles” mileage, as well as nominated travel companion information to ensure that we can confirm your membership identity, customise your products and services, and ensure that you enjoy the benefits of our Cathay Membership Programme (for example, you will be greeted graciously by our staff and crew after you providing your details to us). We can also personalise communication for you and tailor the information we provide to your preferences and interests.

If you were a member of Asia Miles or Marco Polo Club loyalty programmes, we will obtain your Personal Information through these programmes to continue our service to you (currently under the name Cathay Pacific Membership Programme) and retain your tier status and miles balance.

You may voluntarily provide us with your Personal Information when you send an email, make a call to our call centre, interact with our online platforms’ features, interact with our employees or representatives (including on our flights), and interact with us on social media or with posts that mention us, to ensure that we are able to confirm your identity and respond to your needs (including baggage claims, flight delays, etc.). Such Personal Information includes name, title, email address, mobile phone number and service-related information (such as itinerary information and information about other products and/or services). If necessary, we may also request you to provide other Personal Information with your consent.

You may participate in our online or offline activities, some of which may require you to submit your Personal Information, such as your name, title, email address, mobile phone number, membership number, etc. The specific Personal Information collection is subject to the relevant instructions on our activity page.

With your consent, we may use your Personal Information for marketing and promotional purposes, including (i) sending you the latest news about our products and services (and the products and services of our Group companies, such as Asia Miles), offers and promotions; (ii) sending you joint marketing activities regarding our travel services and packages, membership programmes, contests and raffles, tax-free sales, and ancillary services such as travel insurance, hotel transfers, and car rentals; or (iii) customising and tracking your interactions with Internet banner ads and links from third-party sites to our sites.

We may send you marketing, promotional and research activities by mail, telephone or online (including via email, SMS, and social media platform) and, where appropriate and necessary, we will ask for your consent to collect your information or give you the option to opt out of receiving marketing materials. We will provide the option to unsubscribe or stop receiving newsletters within any direct communications we send to you (you can contact us using the contact information provided in Chapter 9 below). If you choose to unsubscribe or stop receiving marketing newsletters, we will still send you information about your Cathay Pacific flight and any other services information we provide. If you are a Cathay Pacific Membership Programme member, you will continue to receive account summaries and updates on our services.

In order to improve our products and/or services, we may conduct market research to collect, through cookies and tracking technology, details of your visit to our online platforms, use of social media platforms and our mobile applications, including information you see.

With your consent, we may also use your Personal Information to analyse market trends. This may integrate the Personal Information we have about your use of our services with the information we collect about your network usage. We may also combine the information we collect about you with information we collect about other customers to gain these insights and identify market trends.

In order to fulfil the obligations stipulated by laws and regulations and ensure the security and compliance of the online and offline services we provide, we may collect your name, bank card information, passport information, and web log information for following purposes: (1) identifying verification and payment processing; (2) detecting fraud; (3) detecting misuse of reservations, money laundering and other criminal or illegal activities; (4) accounting, billing and audit purposes; (5) developing, maintaining and testing our systems; (6) processing of claims; (7) emergency response to ensure the safety and security of all our staff and passengers; and (8) understanding, exercising, enforcing or protecting our legal rights and those of others.

4.2 In accordance with the applicable laws and regulations, we may process your Personal Information based on one of the following legal bases:

  • Based on your consent;
  • Necessary for entering into or performing a contract with you;
  • Necessary for the performance of our statutory duties or obligations;
  • Necessary to respond to public health emergencies or to protect the life, health and property safety of natural persons in emergency situations;
  • Conduct news reporting, public opinion supervision and other activities for the public interest, and process Personal Information within a reasonable scope;
  • In accordance with the law, to a reasonable extent, process your own or other Personal Information that has been disclosed legally;
  • Other scenarios stipulated by laws and regulations.

We will, on the basis of the above legal bases, process the Personal Information we collect in accordance with the terms and conditions of this Privacy Policy and for purposes necessary to provide our products and/or our services.

 

5. How do we protect Children's Personal Information

Cathay Pacific is committed to ensuring the protection of children’s Personal Information. According to local laws and regulations, we consider an individual to be a child if they are under the age of 14. Children are not allowed to create accounts under the Cathay Membership Programme and / or purchase tickets without parental or guardian consent. If we find that we have collected Personal Information of children without parental or guardian consent, we will delete that data as soon as possible. For more information about our processing of children’s Personal Information, please read the Children Privacy Notice. If you have concerns about your child’s privacy, or if you believe that your child may have entered Personal Information without parental or guardian consent, please contact us using our contact details as stated in Chapter 9 of this Privacy Policy.

 

6. Who we share your Personal Information with

In certain circumstances, we will disclose your Personal Information to third parties as described below. You can find a list of the third parties to whom we may transfer the Personal Information in mainland China: List of third parties in Mainland China.

We will permit our third-party service providers, including agents, contractors, and other Cathay Pacific group companies, to use your Personal Information on our behalf for the purposes set out in Chapter 4. Examples of such third parties include our ground handling agents who assist you with check-in and boarding, our airport lounge operators, operators of our IT systems and call centre agents. We may also disclose your Personal Information to third parties in order to facilitate any special arrangements that you may have requested, such as liaising with airport authorities to arrange wheelchair assistance or our catering providers to accommodate any special meal requests.

If you are a member of the Cathay Membership Programme, we will share your Personal Information with our wholly owned subsidiary, Asia Miles Limited, for the provision and management of the Membership Programme, including sending you marketing materials if you have consented to receive such communications.

In order to facilitate and administer your travel arrangements, we may transfer your Personal Information to third parties such as other airlines (including oneworld partner airlines, other partner and codeshare airlines in the context of codeshare and interline arrangements [where we are the marketing carrier]), hotel partners, land or sea transport operators, as well as to travel agents or other persons who interact with us on your behalf. Your Personal Information will be used by such third parties in accordance with their privacy policies. The privacy policies of our interline and codeshare partner airlines can be found in the International Air Transport Association (“IATA”) privacy policy repository at http://www.iatatravelcenter.com/privacy. For others, please visit the third parties’ website for more details.

We may disclose your Personal Information to third parties so they can provide marketing services or conduct marketing or social interaction activities on our behalf such as campaigns, contests, sweepstakes, market research, customer surveys and data analytics to help us improve and tailor our marketing activities, products, and services. Subject to us having obtained appropriate consent from you, we may also disclose your Personal Information to our third-party marketing partners in order that they may market their products and services to you.

For employees or other persons travelling or obtaining products or services in relation to one of our corporate or government clients, we will disclose your travel details and information concerning your use of our service to our corporate or government clients.

We may disclose your Personal Information to governments and regulatory authorities and bodies and to other individuals, bodies and organisations such as immigration, customs, border security, airport authorities, dispute resolution, prosecution and law enforcement bodies, legal advisers, organisations which conduct credit, fraud and other passenger checks, and other individuals, bodies and organisations for the purposes of complying with our legal obligations, for example, where we are required by laws in the United States, France and other countries to disclose your Personal Information in relation to your travel document, booking details, and flight itinerary (also known as Passenger Name Record (PNR) and/or Advanced Passenger Information (API)) to relevant customs and immigration authorities as required by laws. We may also disclose your Personal Information to such individuals, bodies, and organisations for reasons of safety and security, to enable us to provide our products and services to you and otherwise for legal and administrative purposes.

7. Marketing

7.1 Subject to your consent, we may use Personal Information for marketing and promotional purposes, including: (i) for sending or showing you updates on latest news, offers and promotions in connection with our products and services (and the products and services of our group companies such as Asia Miles and third parties) (ii) for sending or showing you joint marketing offers about our travel services and packages, loyalty programmes, contests and sweepstakes, duty-free sales and ancillary services such as travel insurance, hotel transfers and car rentals; or (iii) for tailoring and tracking your interactions with internet banner advertisement and links from third party websites to our website.

7.2 Subject to your consent, we may also use Personal Information to analyse our customers’ preferences and market trends and derive insights, which we may use to tailor the types of products and offers that we present to you. This may involve us combining Personal Information that we hold about your use of our services with information that we have collected about your web usage. We may also combine information that we have collected about you with information that we have collected about our other customers in order to derive these insights and establish market trends. We may provide these insights to our third-party partners and Asia Miles for their marketing and promotional purposes. We also use advertising services and products provided by third party service providers (such as marketing agencies and social media platforms) for marketing and promotional purposes, which may involve us sharing Personal Information that we hold about you with them.

7.3 We may communicate marketing, promotions, and research invitations to you by post, telephone, or online (including by email or through your mobile device or via online banner advertisement) and, as appropriate and where required, we will ask you for your consent, or otherwise provide you with the opportunity to choose not to receive marketing, at the time we collect your data.

7.4 We will provide an option to unsubscribe or opt out of further communication on any direct marketing communication sent to you. You may also opt out by contacting us as set out in Chapter 9 below.

7.5 Please note that if you choose to unsubscribe or opt out of marketing communication, we will still send you communications about your travel with us and any other services that we provide to you. Where you are a Cathay Membership Programme member, you will also continue to receive administrative emails, account summaries, and updates to our services.

 

8. Transmission, storage, and security of your Personal Information

No data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion. However, we maintain commercially reasonable physical, electronic, and procedural safeguards to protect your Personal Information in accordance with the requirements of data protection legislation.

All Personal Information we collect about you is stored on our or our subcontractors’ secure servers. We comply with our security policies and standards when accessing or using this information and restrict access to your Personal Information to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our website or mobile applications, we ask you not to share a password with anyone.

We may be required to export your Personal Information to jurisdictions located outside of Mainland China. Where we transfer your Personal Information abroad, we ensure that appropriate safeguards are in place and that the transfer is conducted in compliance with applicable laws and regulations.

As an entity headquartered in Hong Kong, we are an overseas recipient which receives and processes your Personal Information. We process your Personal Information within the purposes and methods provided in this Privacy Policy and the categories of processed Personal Information have also been disclosed in this Privacy Policy.

Your Personal Information may also be provided by us to the following overseas entities or organisations (this list also disclose the purpose for which your Personal Information is processed): List of third parties outside Mainland China

We will retain your Personal Information for the period necessary for the purpose of providing your products and services, except where otherwise required by law or regulation or where we have other legal basis, such as potential or pending litigation, contractual requirements, or legal retention requirements. After the above retention period expires, we will delete or anonymise your Personal Information.

9. Your rights and contacting us

You have the right to ask us to:

  • provide you with access to your Personal Information and copies of certain Personal Information we held about you;
  • update or correct inaccurate and/or incomplete Personal Information about you;
  • provide you with further details on how we use and process your Personal Information;
  • delete Personal Information we no longer have grounds to process in certain circumstances permitted by law;
  • terminate your account when you no longer use our services or products;

Please note that we will not charge a fee when we deal with your requests in the exercise of the above rights.

  • where processing is based on consent, withdraw the consent; and
  • object to direct marketing (including any profiling for such purposes) at any time.

You have the right to ask us not to process your Personal Information for direct marketing purposes. You can exercise your right to prevent such processing by indicating that you do not consent to direct marketing at the point at which we collect your Personal Information. You can also exercise the right at any time after we have collected and used your Personal Information for direct marketing purposes by:

  1. following the opt-out instructions contained in the relevant communications; or
  2. updating your email subscriptions at https://www.cathaypacific.com/cx/en_CN/membership/my-account/profile.html?tab=communication-preference

In the event of the death of a natural person, close relatives of the deceased person may, for their own lawful and legitimate interests, exercise the rights to request access, copy, correct, and delete the relevant Personal Information of the deceased, unless the deceased had otherwise arranged before his/her death.

You have the right to request transfer of your Personal Information to designated Personal Information processors if the following conditions are met: (1) the transfer is technically feasible; (2) your request is reasonable and (3) the legal conditions specified by regulatory authority is satisfied. The Personal Information will be provided in a structured, commonly used, and machine-readable form.

You have the right to refuse our commercial marketing by means of automated decision-making.

Customers requesting to exercise their rights or needing more information or clarification on our Personal Information usage are welcome to contact us at dpo@cathaypacific.com or write to us at the below mailing addresses. We will respond to you as soon as practicable and in compliance with applicable laws and regulations.

The Data Protection Officerr
Cathay Pacific Airways Limited
7th Floor Cathay Pacific City
8 Scenic Road
Hong Kong International Airport
Lantau
Hong Kong

10. Use of Cookies and Software Development Kits on Cathay Pacific Group Sites and Apps

The websites and apps of the Cathay Pacific group companies, including cathaypacific.com use cookies which, among other things, help us to improve your experience of our websites and to ensure that they perform as you expect them to. For detailed information on how we use cookies and the purposes for which we use then, please see our Cookies Policy. In addition, our websites and apps may use third-party software development kits (SDK) to provide you with corresponding functions or services, specifically as follows:

SDK Detailed information
Glassbox SDK Vendor: Glassbox
Function: Data/information tracking to support product investigation and repair
Collected information Type: Device ID and in-app experience
Data Use: Collection, storage, and analysis
Contact information: +1855 445 2772(support contact)
Privacy Policy Link: https://www.glassbox.com/privacy-policy/
Branch SDK Vendor: Branch
Function: Provide connectivity between channels to improve cross-channel performance
Collected information Type: Personal information and device ID
Data Use: Collection, storage, and use
Contact information: https://branch.io/contact/
Privacy Policy Link: https://branch.io/policies/privacy-policy/
Marketing Cloud SDK Vendor: Salesforce
Function: Marketing push notifications
Collected information Type: Personal information, cell phone number and device ID
Data Use: Collection, storage, and use
Contact information: 1-800-664-9073
Privacy Policy Link: https://www.salesforce.com/company/privacy/
Tealium SDK Vendor: Tealium
Function: Customer experience analysis
Collected information Type: In-app experience
Data Use: Collection, storage, and use
Contact information: +1 (858) 779-1344
Privacy Policy Link: https://tealium.com/privacy/
Pressreader SDK Vendor: PressReader
Function: Provide users with digital magazines and newspapers
Collected information Type: Personal information and flight information
Data Use: Collection, storage, and use
Contact information:
https://care.pressreader.com/hc/en-us/requests/new
Privacy Policy Link: https://care.pressreader.com/hc/en-us/articles/205818089-Privacy-Policy
Adyen Checkout SDK Vendor: Adyen
Function: Allow users to make payments within the application
Collected information Type: Personal information and payment information
Data Use: Collection and use
Contact information: https://www.adyen.help/hc/en-us/requests/new
Privacy Policy Link: https://www.adyen.com/policies-and-disclaimer/privacy-policy
Alipay WAP Payment SDK Vendor: Ant Group
Function: Allow users to make payments using Alipay within the application
Collected information Type: Personal information and payment information
Data Use: Collection and use
Contact information: global.service@alipay.com
Privacy Policy Link: https://global.alipay.com/docs/ac/Platform/privacy
Huawei Core SDK Vendor: Huawei
Function: Allow users to make payments and receive notifications using Huawei devices (for Huawei users only)
Collected information Type: Device ID, Personal Information and payment information
Data Use: Collection, storage, and use
Contact information: +8675528780808 (global office headquarters)
Privacy Policy Link: https://www.huawvei.com/en/privacy-policy
Native App Traffic Protection SDK Vendor: Akamai
Function: Perform system security
Collected information Type: Behavioral data when interacting with the application
Data Use: Collection and use
Contact information: https://www.akamai.com/why-akamai/contact-us
Privacy Policy Link: https://www.akamai.com/legal/privacy-and-policies/privacy-statement
InMobile SDK Vendor: Accertify
Function: Perform system security verification and fraud prevention
Collected information Type: Mobile device information
Data Use: Collection, storage, and use
Contact information: https://accertify.com/contact-us/north-america/
Privacy Policy Link: https://accertify.com/client-privacy/

 

11. Links to Other Sites

This website contains links to other sites that are operated by third party companies with different privacy practices. You should remain alert when you leave our site and read the privacy statements of other websites. We have no control over Personal Information that you submit to or receive from these third parties.

Children Privacy Notice

Cathay Pacific Airways Limited (“Cathay Pacific”, “CX” or “we”) is committed to protecting children’s personal information and privacy. This Children Privacy Notice (this “Notice”) sets out what children’s personal information we collect and how we use it, the rights of children and their parents/guardians (“Guardians”) as well as instructions for their Guardians. Unless otherwise indicated, for the purposes of this Notice, a “Child” means a minor who is under the age of 14.

This Notice applies to all products and/or services that we provide to our customers located in Mainland China and process children’s personal information. We may revise and update this Notice from time to time in accordance with updates to laws and regulations, as well as requirements for maintaining orderly transactions, protecting consumer rights and interests, and business operations. We will disclose changes to you in an appropriate manner.

This Notice specifies the rules for processing children’s personal information based on the Cathay Pacific Customer Privacy Policy -Mainland China. To the extent that this Notice is different from the Cathay Pacific Customer Privacy Policy -Mainland China, this Notice applies; to the extent that this Notice does not specify, the Cathay Pacific Customer Privacy Policy -Mainland China applies.

This Notice does not apply to any website not owned or managed by CX or any other third-party website that children may visit through third party links and/or activities. With respect to such websites, please see those respective sites for the privacy policies that may apply.

We hereby remind you that:

If you are a Child, you are required to read this Notice carefully with your Guardian and obtain your Guardian’s consent to use our products and/or services or to provide us your personal information.

If you are the Guardian of a Child, please read and fully understand the terms of this Notice, especially those in bold, before your Child access or use the products and/or services we offer or providing your Child’s personal information to us.

 

1. Notice to Guardians

If you are a Guardian of a Child, please read and choose carefully before agreeing to this Notice, especially the words in bold. Only use or give permission for your Child to use the service or product after confirming that you have fully understood and agreed to all of the Notice. If you do not agree with the contents of this Notice, you and the Child should immediately cease accessing/using the products and/or services offered by CX.

If you are not the Child’s Guardian, please ensure that you are authorized by the Child’s Guardian to provide the Child’s personal information and purchase tickets for the Child.

If you have become aware of a breach of your account and password used to buy tickets for the Child, or any other incident that may result in the disclosure or misuse of the Child’s personal information, please contact us through our contact details located in Chapter 7 of this Notice.

 

2. How We Collect and Use Children’s Personal Information

Personal information refers to all kinds of information recorded electronically or otherwise, that can by itself, or in combination with other information, including but not limited to a natural person’s name, date of birth, ID card number, personal biometric information, address, telephone number, etc., be used to identify a natural person.

Personal information of children under the age of 14 is sensitive personal information. We collect and process children’s personal information with strict protection measures when there is a specific purpose and sufficient necessity for doing so.

We may collect personal information of children from various sources. We may collect personal information of children that you provide when you use our Digital Channels (including our official CX website (cathaypacific.com), “Cathay Pacific” App (CX App), “Cathay Pacific” WeChat mini programme (CX WeChat mini programme), “Cathay Pacific” WeChat official account, etc.), receive offline services, or participate in other activities hosted by CX. We may also use cookies and other technologies to automatically collect device information or usage information from children when you visit our Digital Channels. We collect and use children’s personal information only for the purposes described in this Notice; if you refuse to provide this information (especially children’s travel documents, payment and contact information), you may not be able to use some of the services we provide.

2.1 Booking and purchasing tickets for your child

If you are the Guardian of a Child, when you purchase a ticket for your Child through the Digital Channels, we will collect your Child’s name, departure location, travel document details including passport number, passport expiry date, country that issued your passport and your country of residence (this information is also known as Advanced Passenger Information (API)), travel destination, travel category (round trip/one way), flight number, flight time, cabin class, and seat number.

Where a minor flies alone without an adult, we offer an unaccompanied minor service. In order to obtain flight information, carry out service preparation and complete the pick-up and accompanying service, you need to provide the child’s personal information as described above, as well as the full name and contact information (mobile phone number) of the adult responsible for the pick-up and drop-off at the place of departure and arrival.

2.2 Account registration and login

When a minor under the age of 18 (including a Child) registers as a member through the Digital Channels, we need to obtain the consent of his or her Guardian. Therefore, we will collect the Child’s age, his or her Guardian’s name, and the Guardian’s cell phone number to complete the verification process. We will collect the Child’s title, name, email address, and the password for the registered account.

2.3 Collection of children’s personal information from third parties

We may collect personal information about children from third parties, including but not limited to travel agents, other airlines and providers of other travel-related services. Please refer to the “How we collect Personal Information” section of the Cathay Pacific Customer Privacy Policy - Mainland China for the scope of the collection.

2.4 Other scenarios

We may also collect and use other personal information about children during your Child’s use of our products and services in order to provide you or your Child with our products and services (e.g., to provide personalized displays or recommendations). Please refer to the “The Personal Information We Collect”, “How we collect Personal Information” and “Why we collect and use your Personal Information” sections of the Cathay Pacific Customer Privacy Policy - Mainland China for specific purposes of use, the scope of personal information collected and the consequences of refusing to provide the information.

In addition, we may also automatically collect your Child’s personal information through cookies, SDKs and other similar technologies. Please refer to the “Use of Cookies on Cathay Pacific Group Sites” sections of the Cathay Pacific Customer Privacy Policy - Mainland China for details.

Please note that in some cases we are unable to identify whether the specific person using our product or service is a Child or not. In cases where the user does not voluntarily provide personal information, such as page views, we are unable to determine whether personal information that is not clearly age-identifiable is children’s personal information, and we will process such personal information in accordance with the provisions of the Cathay Pacific Customer Privacy Policy - Mainland China. If you find that the personal information we are processing is personal information of a Child, please contact us promptly.

2.5 Legal basis for processing children’s personal information

Please understand that, in accordance with national laws and regulations, we may process children’s personal information only under any of the following circumstances:

  • Where the Guardian’s separate consent is obtained.
  • Where it is necessary for the conclusion or performance of a contract to which the individual is a contracting party.
  • Where it is necessary for performing a statutory responsibility or statutory obligation.
  • Where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency .
  • Where the personal information is processed within a reasonable scope to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes
  • Where the personal information, which has already been disclosed by the individual or otherwise legally disclosed, is processed within a reasonable scope and in accordance with the applicable law.
  • Any other circumstance as provided by law or administrative regulations.

If we use children’s personal information for purposes other than those set forth in this Notice, or use information collected for specific purposes for other purposes, we will seek the consent of the Guardian as required by applicable law.

 

3. How We Share Children’s Personal Information with Third Parties

3.1 Sharing

For the personal information you provide, we will keep it confidential and protect it in accordance with the relevant laws and regulations of the People’s Republic of China, and will not provide or display such information to any third party in any way, except for the following cases:

  • We will share children’s personal information with their Guardians who can access and manage the relevant personal information;
  • Other scenarios as disclosed in the “Who we share your Personal Information with” section of the Cathay Pacific Customer Privacy Policy -Mainland China

Only after you have provided authorization and standalone consent, and on the basis of lawfulness, legitimacy, necessity and specific and explicit purposes will we provide children’s personal information to the extent necessary for providing products and/or services to children. We will also assess the legality, legitimacy, necessity, and impact on the rights of children of providing personal information of children to such third parties.

3.2 Entrusted processing to third parties

We may entrust third party service providers (including agents, contractors, suppliers and other companies in the CX group) to process children’s personal information. If we do so, we will evaluate the entrusted party capabilities and the entrusting process and require the processing to not exceed the scope of our authorization by singing an agreement. Please refer to the “Who we share your Personal Information with” section of the Cathay Pacific Customer Privacy Policy - Mainland China for details.

3.3 Transfers

In the event of a merger, acquisition or liquidation of the CX group, or other situation involving a merger, acquisition or liquidation that involves the transfer of personal information, we will require the new company, organization or individual in possession of the Child’s personal information to continue to be bound by this Notice and the Cathay Pacific Customer Privacy Policy - Mainland China, or we will require the company, organization or individual to seek authorization from the Child’s Guardian again.

3.4 Disclosure

We will only publicly disclose a Child’s personal information under the following circumstances.

  • We are allowed to publicly disclose a Child’s personal information with the express consent or choice of the Child’s Guardian.
  • To comply with the request of judicial or administrative authorities to disclose a Child’s personal information in accordance with legal procedures and legal authority.

 

4. How We Store and Protect Children’s Personal Information

We will retain children’s personal information for the minimum period necessary for achieving the specific purposes, except where otherwise required by law or regulation or where we have other legal bases. After the above storage period, we will delete or anonymize your children’s personal information.

We have put in place commercially reasonable physical, electronic, and procedural safeguards to protect children’s personal information from unauthorized access, public disclosure, use, modification, damage, or loss in order to meet the requirements of applicable laws and regulations.

All personal information that we collect about children is stored on our secure servers or those of our subcontractors. When accessing or using this information, we adhere to our security policies and standards and strictly control access to children’s personal information. You are responsible for maintaining the confidentiality of any personal information we send to you about children and for complying with any other security procedures we instruct you to follow. if we provide you with (or you have chosen) a password that allows you to access parts of our website or mobile application, please do not share your password with anyone.

If you are aware that your Child’s personal information has been compromised, please contact us via the contact information in Chapter 7 of this Notice so that we can take appropriate action.

 

5. Children’s Rights to Personal Information

5.1 Your and your Child’s rights to personal information

In accordance with the relevant laws, regulations and standards of China, we ensure that you and your children can exercise the following rights with respect to children’s personal information. Please refer to the “Your rights and contacting us” section of the Cathay Pacific Customer Privacy Policy - Mainland China for details.

5.2 How we respond to relevant requests

You may exercise your Child’s personal information rights at any time through our Digital Channels, or through the contact information disclosed in Chapter 7 of this Notice. We will respond to relevant requests in accordance with applicable laws and regulations, provided that you give necessary information to verify the identity of the Child and the identity of the Child’s Guardian. In general, we do not charge fees for reasonable requests, but we may charge fees for repeated requests or requests that exceed reasonable limits, depending on the circumstances.

If you would like to exercise your Child rights or require additional information or clarification on the use of specific personal information, please contact us using the details in Chapter 7 of this Notice.

Please note that, in accordance with relevant national standards, we will not be able to respond to requests from children under the following circumstances:

  • When the requests are related to the fulfilment of our obligations under laws and regulations.
  • When the requests are related to national security and defence security.
  • When the request is related to public safety, public health, or significant public interest.
  • When the request is related to criminal investigation, prosecution, trial and execution of judgment.
  • When there is sufficient evidence of subjective malice or abuse of rights by the data subject.
  • When it is necessary to protect the life, property, and other significant legitimate interests of the subject of the personal information or other individuals, but it is difficult to obtain the authorization and consent of the individual.
  • Responding to your request would cause serious harm to your or other individuals’ and organizations’ legitimate rights and interests.
  • When these requests are related to trade secrets.

 

6. How Children’s Personal Information is Transferred Globally

We may be required to export your personal information to jurisdictions located outside of Mainland China. Where we transfer your personal information abroad, we ensure that appropriate safeguards are in place and that the transfer is conducted in compliance with applicable laws and regulations.

As an entity headquartered in Hong Kong, we are an overseas recipient which receives and processes children’s personal information. We process children’s personal information within the purposes and methods provided in this Notice and the categories of processed personal information have also been disclosed in this Notice.

Children’s personal information may also be provided to the following overseas entities or organizations: List of third parties outside Mainland China

 

7. How to Contact Us

If you or your Child wish to exercise the rights as an individual under this Notice, or if you have any questions about how we process personal information about children, please contact us by email at dpo@cathaypacific.com or write to us at the below mailing addresses. We will respond to you as soon as practicable and in compliance with applicable laws and regulations.

The Data Protection Officer
Cathay Pacific Airways Limited
7th Floor Cathay Pacific City
8 Scenic Road
Hong Kong International Airport
Lantau

Hong Kong