Privacy Policy

1. Introduction

GLIA HONG KONG HOLDINGS CO., LIMITED ("we", "our", "us"), the operator of SamuiBeachClub.com, respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website at samuibeachclub.com (the "Website").

This Privacy Policy applies to all users of our Website and complies with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and the General Data Protection Regulation (GDPR) for users in the European Economic Area.

2. Information We Collect

We may collect and process the following types of information:

2.1 Information You Provide Directly

• Contact Information: Name, email address, telephone number when you contact us or subscribe to our newsletter
• Correspondence: Any information you provide when communicating with us via email or contact forms
• Feedback and Reviews: Information you provide when submitting feedback or reviews about venues
• Account Information: If you create an account, username, password, and profile information

2.2 Information Collected Automatically

• Usage Data: IP address, browser type, operating system, referring URLs, pages viewed, time spent on pages, links clicked
• Device Information: Device type, unique device identifiers, mobile network information
• Location Data: General geographic location based on IP address
• Cookies and Tracking Technologies: Information collected through cookies, web beacons, and similar technologies (see Cookie Policy below)

2.3 Information from Third Parties

• Social Media: If you interact with us on social media platforms, we may receive information from those platforms
• Analytics Providers: Aggregated data from analytics services such as Google Analytics
• Venue Partners: Information about events, offers, and venue details provided by our partner venues

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 To Provide and Improve Our Services

• Display venue information, beach guides, and travel content
• Respond to your enquiries and provide customer support
• Send you newsletters, updates, and promotional materials (with your consent)
• Personalise your experience on the Website
• Analyse usage patterns to improve our Website and services

3.2 For Business Operations

• Maintain and improve Website security and functionality
• Prevent fraud and enforce our Terms of Service
• Comply with legal obligations and respond to legal requests
• Protect our rights, privacy, safety, or property

3.3 For Marketing and Communications

• Send you information about venues, events, and special offers
• Conduct surveys and gather feedback
• Provide targeted advertising (subject to your preferences)

4. Legal Basis for Processing (PDPO Compliance)

Under Hong Kong law, we process your personal data based on:

• Consent: You have given clear consent for us to process your personal data for specific purposes
• Contractual Necessity: Processing is necessary to fulfil our obligations under our Terms of Service
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided these do not override your rights
• Legal Obligations: Processing is required to comply with applicable laws and regulations

5. How We Share Your Information

We do not sell your personal data. We may share your information with:

5.1 Service Providers

Third-party service providers who perform services on our behalf:

• Web hosting providers
• Email service providers
• Analytics providers (e.g., Google Analytics)
• Payment processors (if applicable)
• Customer support tools

These service providers are contractually obligated to protect your data and use it only for the purposes we specify.

5.2 Venue Partners

With your consent, we may share relevant information with venue partners to facilitate bookings, reservations, or enquiries you initiate through our Website.

5.3 Legal Requirements

We may disclose your information if required by law or in response to:

• Court orders or legal processes
• Governmental or regulatory requests
• Protection of our rights, property, or safety
• Prevention of fraud or illegal activities

5.4 Business Transfers

If we are involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change.

6. International Data Transfers

Our Website is operated from Hong Kong. If you access our Website from outside Hong Kong, your information may be transferred to, stored, and processed in Hong Kong or other jurisdictions where our service providers operate.

By using our Website, you consent to the transfer of your information to Hong Kong and other countries which may have different data protection laws than your country of residence.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention Periods:

• Contact enquiries: 2 years from last contact
• Newsletter subscriptions: Until you unsubscribe
• Usage data and analytics: 26 months
• Account information: Duration of account plus 1 year after closure

8. Your Rights Under Hong Kong Law

Under the PDPO, you have the following rights:

8.1 Right to Access

You have the right to request access to the personal data we hold about you.

8.2 Right to Correction

You have the right to request correction of inaccurate or incomplete personal data.

8.3 Right to Erasure

You have the right to request deletion of your personal data in certain circumstances.

8.4 Right to Data Portability

You have the right to request a copy of your personal data in a structured, commonly used format.

8.5 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes.

8.6 Right to Withdraw Consent

Where we rely on your consent, you have the right to withdraw it at any time.

9. Cookie Policy

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit our Website. They help us provide you with a better experience.

9.2 Types of Cookies We Use

Essential Cookies

Necessary for the Website to function properly. These cannot be disabled.

• Session management
• Security features
• Basic functionality

Analytics Cookies

Help us understand how visitors interact with our Website.

• Google Analytics
• Usage statistics
• Performance monitoring

Functional Cookies

Enable enhanced functionality and personalisation.

• User preferences
• Language settings
• Display preferences

Marketing Cookies

Used to deliver relevant advertisements.

• Ad targeting
• Campaign effectiveness
• Social media integration

9.3 Managing Cookies

You can control cookies through your browser settings. Please note that disabling certain cookies may affect Website functionality.

Browser Controls:

• Chrome: Settings > Privacy and Security > Cookies
• Firefox: Settings > Privacy & Security > Cookies
• Safari: Preferences > Privacy > Cookies
• Edge: Settings > Privacy > Cookies

Third-Party Cookies:

• Google Analytics: Google Analytics Opt-out

10. Third-Party Links

Our Website may contain links to third-party websites, including venue websites, booking platforms, and social media. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

11. Children's Privacy

Our Website is not intended for children under 16 years of age. We do not knowingly collect personal data from children. If you believe we have collected information from a child, please contact us immediately.

12. Security Measures

We implement appropriate technical and organisational measures to protect your personal data, including:

• SSL/TLS encryption for data transmission
• Secure server infrastructure
• Access controls and authentication
• Regular security audits
• Employee training on data protection

However, no method of transmission over the internet is 100% secure. We cannot guarantee absolute security.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

• Posting the updated policy on this page
• Updating the "Last Updated" date
• Sending an email notification (for significant changes)

Your continued use of the Website after changes indicates acceptance of the updated policy.

14. Contact Us

For questions about this Privacy Policy or to exercise your data rights:

Complaints:

If you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data:

• Website: www.pcpd.org.hk
• Email: enquiry@pcpd.org.hk
• Tel: +852 2827 2827