UA Cinema Circuit Limited (“the Company”) respects personal data and is committed to fully implementing and complying with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance ("the Ordinance"). This Policy is applicable to the members of UA Loyalty Club and Free Member as well as any other persons that their personal data is collected, by whatever means, used and held by the Company.

Kinds of Personal Data Collected, Used and / or Held
Only name, gender, birthday (except year of birth), email address or telephone number, member’s bonus points record, survey and activity comments as well as transaction records will be collected, used and / or held by the Company. In case of using mobile application (“App”), your International Mobile Station Equipment (“IMEI”) number and Media Access Control Address (“MAC Address”) will also be collected, used and / or held by the Company.

Main Purposes of collecting and / or RETAINING Personal Data
You may provide us with your personal data at your own will. Should you are under the age of 18, please consult your parents or guardians before providing your personal data. If the Company is unable to obtain such data that specifies as “Compulsory Items”, the requested services, products, gifts, privileges or information cannot be provided. Without your authorization for collecting and retaining your IMEI and MAC Address, the Company’s APP cannot be downloaded to your mobile and hence you cannot use the APP accordingly.

The main purposes of collecting and retaining personal data are as follows:
(1)    Payments: Credit card information will only be used for necessary payment of the purchase of movie tickets and other products through the Company’s website or App;
(2)    Handling of Membership Account and Activity: Registration, verification of identity, clearing fees, bonus points accumulation, gifts redemptions, patronage and communication; date of birth for providing birthday benefit to UA Loyalty Cub member;
(3)    Group Ticketing, House Booking, Ordering Vouchers or other services: Patronage, communication, service confirmation, clearing fees, venue arrangement, service schedule, etc.;
(4)    Handling of Personal Data Requests: Verification of identity for handling requests of access, correction and erasure of personal data;
(5)    Statistics: Carry out statistics and data analysis, such relevant reports will contain only anonymous data for the purpose of improving our service and product quality and as marketing statistics for clients’ reference;
(6)    App Services: Once you have registered as a Free Member with IMEI, the system can identify the mobile by memorizing the IMEI. By using the same mobile, the user is not required to enter his/her password again for the next purchase. The Company will also monitor and analyze the download status of UA App to ensure system performance and stability. MAC addresses are collected for the purpose of analyzing the hit rate of the Company’s App in order to source and make available promotional or marketing information that you may be interested;
(7)    Direct Promotions and Marketing: Only after obtaining your consent, the Company may send or contact you from time to time to share promotional or marketing information, promotional and marketing subjects shall include our film introduction, cinema activities, members’ privilege and gifts; also business partners’ services and products: travel, banking and finance, beauty and cosmetics, property and shopping mall, entertainment, sports, music, gaming, transportation, automobile, household, fashion & clothing, retail, dining, food, beverage, insurance, gambling, education, health and well-being, drugs, culture & arts, environmental protection, charity, book and magazines, social networking, technology & e-commerce, mobile application, mobile payment, cloud services, media and consumer products and services.

Retention of Members’ Personal Data
The application forms, completed for the online registration, with personal identifiable data thereof will be retained for six months after membership expired and will be permanently erased from our record upon expiry of the said retention period.

Accuracy and Change of Members’ Personal Data
In order to ensure the correctness of the Members’ personal data retained by the Company, particularly contact details, you may receive our request of confirmation or verification. Please feel free to contact us for correction or change of personal data or your desire to opt-out from receiving future direct promotional and marketing information. Your request will be processed and will come to effect within 14 working days after our receipt of your request. This service is free of charge.

Access to Members’ Personal Data
You are welcome to contact us for requesting access to a copy of your personal data maintained by the Company. We will only handle such requests made by you in person. This service is free of charge.

Personal Data Handling and Security Measures
Your personal data collected and maintained by the Company may be transferred to certain professional services companies in Hong Kong for processing on our behalf, or accessed by these companies for facilitating our services. These professional services may include ticketing system operation, membership card services, website management, system development and maintenance etc.

The Company has established and implemented security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data, and will monitor and ensure services companies to take the same security measures. All personnel that may access to the data will be ensured complying with the requirements of data protection.

The Company’s security measures are listed below
(1)    The services companies shall not keep any personal data transferred to them longer than as necessary for processing of the data;
(2)    Controls on password complexity, re-tries or resets are implemented to prevent passwords from being compromised;
(3)    Advanced encryption technology is used to protect the safety of personal data (including names, email addresses, telephone numbers, credit card information and purchase records) during transmission. Our SecureSocketLayer (SSL) system will prevent your data being transmitted from unauthorized interception or access by THIRD PARTIES;
(4)    Individual and separate server(s) with properly configured firewall are used to store personal data;
(5)    Only the personnel that have been trained with the strict privacy guidelines and procedures are authorized to access or handle your personal data. Such personnel are accountable for any non-compliance with the related obligations;
(6)    The SECURITY SYSTEM will be reviewed regularly;
(7)    Personal data of members expired at least half a year or above will be purged every half year.

Apart from the requirements from professional services companies and statutory requirements, the Company will not transfer or disclose any of your personally identifiable data to any other parties.

Limitation of Liability
The Company has implemented all reasonably practicable procedures, measures and steps to safeguard the security of your personal data.  However, no method of transmission over the Internet, or method of electronic storage, is totally secure. The Company cannot guarantee its absolute security.

Unless there is proved negligence, the Company shall not bear any liabilities therefor. Our liabilities, if any, shall only limit and subject to the scopes set out in the terms and conditions of this Policy, UA Loyalty Club, Free Member and UA website/mobile App services respectively.

After clicking on an advertisement or a hyperlink button on our website, you may have left our website and entered the website of a Company’s advertising client, content provider, supplier, associated company or business partner. Your visit to these third parties’ websites is not protected by this Policy.

These third parties’ websites are not owned or controlled by the Company. The Company has not authorized them to collect any personal data from you. Therefore, the Company is not responsible for any exposure of your data at these websites or losses arising from a third party website’s practice or policy. Please contact the manager or owner of such websites directly for any enquiries or questions about their own privacy practices or policies.

Changes in this Privacy Policy
The Company may update or amend this Privacy Policy in the future, if necessary. The revised Policy will be posted on our website with an effective date.  Please visit our website from time to time for the latest information.

When you browse our website, the internet provider will store your data. Such data may include IP address, operating system, web browser model, internet supplier and number of storage.
The internet provider will disclose to us your visit only as a “hit” and the web browser model. The Company collects this data solely for statistic purpose. No personal data will be analyzed.

Should there be any differences or inconsistencies between the Chinese version and English version of this Policy, the Chinese version shall prevail.

Contact Us
Should you have any requests, enquiries or comments to our Privacy Policy or Practice, please email at or write to us at Customer Services, UA Cinema Circuit Limited,
7 Shing Yip Street, 23rd Floor Legend Tower, Kwun Tong, Kowloon, Hong Kong.
In general circumstances, your requests or enquiries will be handled within 14 working days after receipt of the same and verification of your identity.

Effective Date
This Privacy Policy becomes effective from 
4 October 2018.

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