1. Our Commitment to Protect Your Privacy
The laws of certain countries require us to provide you with additional information about our processing activities and we have included separate appendices to deal with these. As well as this document, please refer to the appendices which apply to you.
2. The Personal Data We Collect
2.1 We will collect and process some or all of the following Personal Data about you:
Your personal information such as your full name, gender, date of birth, 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 Marco Polo Club, your membership number, your user name and your earning and claiming of club points , 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, your images captured via CCTV in our airport lounges and aircraft, your use of our cargo services including details of the cargo shipments, 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, 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;
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. 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
2.2 Certain Personal Data (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 Data as requested for specific services, we may be unable to deliver you the products and services in full.
3. How we collect Personal Data
3.1 We will collect some Personal Data from you directly. We will collect other Personal Data 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 Marco Polo Club, including credit card issuers, hotel operators, retailers and restaurants; (f) operators of our partner loyalty programmes such as Asia Miles; (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.
4. Why we collect and use your Personal Data
4.1 When you share information with us, you help us make our services to you better. Here are some of the ways we will use your Personal Data:
To provide our products and services to you and to process and administer your travel and service arrangements, to contact you about your travel and service arrangements and to send you service-related communications, to deliver of benefits and services associated with your travel package or requested services, to identify and verify your identity in connection with the services we provide, to provide or facilitate any special assistance you may have asked for;
To tailor and personalise the products and services that we provide to you, including providing your details to our staff and cabin crew so they can greet you personally and acknowledging your loyalty if for example you are a Diamond Marco Polo Club member. We may also tailor our communications to you and tailor what we present to you to better match your preferences and interests;
For customer support purposes such as responding to your enquiries and requests, providing assistance to you in relation to issues such as baggage claims and flight delays;
Where you are a member of Marco Polo Club, we will use Personal Data that we collect about you for the operations of the Marco Polo Club such as processing your membership application and to ensure that you get the benefit of our loyalty programmes and partner loyalty programmes including Asia Miles, including to track your earning and claiming of club points, your accrual and redemption activities and record your mileage credits. If you a member of Asia Miles and where we have your consent to do so, we will also disclose your Personal Data to Asia Miles so they can send you details of any offers or promotions in connection with your travels with us, which may be of interest to you;
For the purposes of improving our products and services for the benefit of our customers generally, including to ensure that our websites and web pages (including social media pages) function correctly and in accordance with your preferences and circumstances;
To ensure the safety and security of all our staff and passengers and to undertake any necessary activities during emergency events;
To comply with our legal and regulatory obligations and for legal and administrative purposes such as, verifying and processing payment, screening against fraud, screening against abusive booking, money laundering and other criminal or unlawful activities, accounting, billing and audit purposes, developing, maintaining and testing our systems, for claims handling and for understanding, exercising, enforcing or protecting our legal rights and those of others.
5. Who we share your Personal Data with
In certain circumstances, we will disclose your Personal Data to third parties as described below:
We will permit our third party service providers, including agents, contractors and other Cathay Pacific group companies, to use your Personal Data on our behalf for the purposes set out in section 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 Data 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.
We may disclose your Personal Data 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 Data to our third party marketing partners in order that they may market their products and services to you. If you are a member of Asia Miles, we will also share your Personal Data with Asia Miles for the above purposes, as well as to enable Asia Miles to combine your Personal Data with the personal data they hold about you.
We may transfer your Personal Data to the Asia Miles Loyalty Programme, or to operators of our partner loyalty programmes, to facilitate your participation in the relevant programme.
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 Data 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 Data 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 Data 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.
6.1 We may use Personal Data 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.
6.2 We may also use Personal Data 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 Data 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 Data that we hold about you with them.
6.3 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.
6.4 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 paragraph 8 below.
6.5 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 Marco Polo Club member or a Registered Account holder, you will also continue to receive administrative emails, account summaries and updates to our services.
7. Transmission, storage and security of your Personal Data
7.1 IT Security
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 Data in accordance with the requirements of data protection legislation.
All Personal Data 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 Data 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.
7.2 Exporting your Personal Data
Your Personal Data may be transferred outside the country in which you are located, including to countries with a lower level of data protection than in the country in which you are located.
7.3 Retention period
We will retain your Personal Data for as long as is necessary for the processing purpose(s) for which it was collected and any other permitted linked purpose (for example where we are required to retain personal data for longer than the purpose for which we originally collected it in order to comply with certain regulatory requirements). Our retention periods are based on business needs and your information that is no longer needed is either irreversibly anonymised (and the anonymised information will be retained) or securely destroyed.
8. Your rights and contacting us
8.1 General rights
You have the right (subject to various exceptions and in accordance with data protection legislation in your country) to access certain Personal Data held about you and correct any inaccuracies. We may charge a reasonable fee for the processing of any data access request in accordance with data protection legislation in your country. You also have the right to raise a complaint about our processing with the data protection regulator in your jurisdiction.
8.2 Right to opt out of direct marketing
You have the right to ask us not to process your Personal Data 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 Data. You can also exercise the right at any time after we have collected and used your Personal data for direct marketing purposes by:
(a) following the opt-out instructions contained in the relevant communications; or
(b) updating your email subscriptions at http://www.cathaypacific.com/cx/en_HK/offers/newsletter/login-to-subscribe.html for CX/KA newsletter OR http://www.cathaypacific.com/cx/en_HK/frequent-flyers/my-account/manage-account/update-profile/subscription-to-email-updates.html for MPO newsletter.
8.3 Updating information
We will take reasonable steps to try and ensure that your Personal Data is accurate. To help us do this, please notify us of any changes to your Personal Data.
8.4 Contacting us
Customers requesting more information or clarification on specific Personal Data usage are welcome to contact us at email@example.com or write to us at the below mailing addresses:
The Data Protection Officer
Cathay Pacific Airways Limited
6th Floor Cathay Pacific City
8 Scenic Road
Hong Kong International Airport
Hong Kong Dragon Airlines Limited
5th Floor Cathay Dragon House
11 Tung Fai Road
Hong Kong International Airport
10. 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 Data that you submit to or receive from these third parties.
This notice is written in 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 notice, the English version shall prevail.
These Terms and Conditions were last updated on 23 Jul 2019.
NOTE 1 Cathay Pacific means Cathay Pacific Airways Limited, Hong Kong Dragon Airlines Limited, Cathay Holidays Limited (and its subsidiaries)
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