LITHE Enterprise Limited (“Company”)

Personal Data Statement to Customers (“this Statement”)

This Statement is to inform the customers of the policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal data adopted by the Company and the owners of the properties managed and/or operated by the Company in accordance with the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of the Hong Kong Special Administrative Region (“Ordinance”) and the relevant law regulations. References to “we”, “us”, “our” or “ours” in this Statement are to be construed, depending on the context, as referring to those properties or entities collectively or severally.

1. We will collect the personal data from the customers to enable us to provide you with the goods and/or services. Failure to supply your personal data may result in us not being able to provide you with the goods and/or services.
2. Customers will be asked to confirm their acceptance of and/or consent to the terms of this Statement when making reservations or otherwise communicating with us via this website or as required under applicable laws. Customers’ use or access of our website will also constitute deemed to consent/accept the use of that date as set out in this Statement.

Where a customer provides personal data of third parties (e.g. names and contact details of the customer’s family members or friends for reservation purposes), the customer acknowledges and confirms that the customer has obtained the relevant third parties’ consent to provide their personal data to us. We shall not liable to you in this regard.

3. We collect the following types of the personal data (including but not limited to) for the purposes mentioned in paragraph 5 below: 

• Personal information and contact information of the customer such as your name, gender, date of birth, identity card number, telephone number, email address, correspondence address, mailing address and/or billing address;
• Business information of the customer;
• User account details of the customer such as credit card and other payment transaction details;
• IP address, real-time geographic location data, browsing records, and/or other Internet log information of the customer;
• Login/logout information of customer; and
• any other information which the customer chooses to provide to us.

4. The customer agrees that any personal data with respect to the customer or any other party which has been provided by the customer to us (“Personal Data”) may be disclosed and transferred to the following locations or persons who shall hold, use, process, retain or transfer such Personal Data for the purposes mentioned in paragraph 5 and on a need-to-know basis (whether within or outside Hong Kong): 

• our corporate office in Hong Kong and our vehicles where the customer has booked or visited or traveled with;
• competent court of law, law enforcement agencies, or other governmental or statutory authorities, institutions or organisations;

• our associated company, business partner, agent, contractor, bank, insurance company, credit provider, financial institution, service provider or professional adviser of ours or any other person under a duty of confidentiality to us;
• any of our holding companies, their subsidiaries and any company in which the same has a direct interest; 
• any actual or proposed assignee or transferee of ours; and
• any other party at the customer’s consent or instruction.

5. The customer acknowledges and agrees that his/her Personal Data is provided for the following purposes (including but not limited to): 

• identifying the customer and any accounts of the customer hold with us;
• the provision of any goods and/or services to the customer (including vehicles reservations and arrangements, membership-related services and responding to inquiries and requests for information or services);
• determining and verifying the customer’s eligibility for discounts and promotions on products and services;
• the analysis, verification and/or checking of the customer’s credit, credit history and payment;
• the ensuring of the customer’s on-going credit worthiness;
• the processing of any payment instructions, direct debit facilities and/or credit facilities requested by the customer;
• the determination of the amount of debt owed to or by the customer and/or the processing and/or collection of amounts outstanding from the customer and those providing security for the customer’s obligations; 
• processing applications or renewal applications for our business partners’ products and services, including but not limited to insurance and financial products on the customer’s behalf;
• processing insurance claims for our business partners’ products and services on the customer’s behalf;
• enabling us to store the personal data of the customer so you do not have to re-enter it each time you purchase a product or renew;
• the performance, preparation and enforcement of the order or any agreement between the customer and us;
• direct marketing of our services/the products and services of the Company’s business partners;
• in connection with any merger, sale, financing or acquisition of our business by/with another company;
• conducting research, statistical analysis and behavioral analysis;
• handling the customer’s complaints and account enquiries, handling any claim and/or proceedings against the Company or any party;
• fraud prevention and detection;
• auditing purposes;
• disclosures under the requirements of any law; and
• any other purposes relating to the above.
• A cookie is a small text file which is placed onto customer’s computer (or other electronic device) when customer access the Company’s website. We use cookies on our website to:
• recognise customer whenever you visit our website;
• obtain information about customer’s preferences, viewing and browsing behavior, online movements and use of the Internet;
• keep track of the items stored in customer’s shopping basket and take customer through the checkout process;
• carry out research and statistical analysis to help improve our services and to help us better understand our visitor and customer requirements and interests;
• target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to customer’s interests;
• make customer’s online experience more efficient and enjoyable; and
• enable tighter security.

If customer wants to disallow the use of cookies, customer can do so on customer’s own web browser. If customer disable cookies, customer acknowledges that customer may not be able to use some of the functionality of our website.

7. This Statement only applies to the Company’s website. Our website may contain links to other sites and pages. By activating a link, such as for example by clicking on the banner of an advertiser, customer leaves our website and the Company does not exercise control over any personal data or any other information customer gives to any other entity after customer has left our website. Access to and use of such other websites is at customer’s own risk.
8. We intend to use the customers’ personal information (including their names and contact details) for use in direct marketing of the news, offers, services, promotions, events and other information in relation to our hospitality businesses. We may not so use the customers’ personal information without the customers’ consent or indication of no objection. We will always ask for the customers’ consent or indication of no objection before using the customers’ personal information for direct marketing. Customers may always opt-out from receiving our direct marketing communications by following the instructions in the relevant communications or contact us directly at info@lithe88.com.
9. Under and in accordance with the relevant laws, the customer has the right to: 

• check whether we hold any Personal Data with respect to the customer;
• access such of the Personal Data which we hold with respect to the customer;
• require us to correct any Personal Data which is inaccurate;
• ascertain our policies and practices (from time to time) in relation to the Personal Data and to be informed of the kinds of the Personal Data held by us;
• withdraw consent to the processing of his/her Personal Data;
• erasure of his/her Personal Data;
• restrict data processing;
• object against profiling;
• data portability; and
• lodge a complaint with a supervisory authority (where applicable).

10. In accordance with the Ordinance, we have the right to charge the customer a reasonable fee for the processing of any data access request. Any request for access to the Personal Data, correction of the Personal Data or information regarding policies and practices and kinds of Personal Data held by us or any request in relation to the customers’ rights under paragraph 7 above should be in writing and addressed us as follows: 

LITHE Enterprise Limited

Unit 9, 9/F, Asia Trade Centre, 79 Lei Muk Road, Kwai Chung, New Territories, Hong Kong

Attn: Personal Data Administrator

11. We will only retain the Personal Data for so long as necessary to fulfill the purposes for which it was collected and for the purposes of satisfying our legal, accounting or compliance-related requirements.

    To determine the appropriate retention period, we consider the amount, nature, sensitivity, the potential risk of harm from unauthorised use or disclosure of the Personal Data, the purposes for which we collect/process the Personal Data and the applicable legal requirements.

12. This Statement has been translated into different languages. If there is any inconsistency or ambiguity between the English version and the other versions, the English version shall prevail.

We keep this Statement under regular review and place updates on our website from time to time.

Last Updated: