Scope of This Policy
 

SJM Resorts, Limited (“SJM”), GLP Hospitality Services Limited and SJM’s other subsidiaries (referred to as “SJM RESORTS” or “COMPANY” or “SJM Group”) value and respect your privacy. This Privacy Policy describes the collection, use, protection, and sharing practices of personal data by COMPANY. This Policy applies to:

• the websites, applications, systems, social media pages and other platforms owned or operated by COMPANY (referred to as “Platform”); and
• activities that are offline or unrelated to our Platform, as applicable to the operations of COMPANY in Macao

(collectively referred to as “Channels”)

By visiting or using the Channels, you agree to the terms and conditions of this Privacy Policy. Please read this Privacy Policy carefully before visiting or using our Channels, or otherwise providing us with any of your personal data. If you do not agree to any of this Policy, please do not use the Channels.

This Policy is made in compliance with the Macao SAR Law No. 8/2005 - the Personal Data Protection Act (“PDPA”) and under the Macao jurisdiction, and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Bureau (“DSPDP”) of Macao.

 

Personal Data We Collect
 

Information You Provide to Us
 

When you visit the Channels, you may provide us with personal information such as your name, postal address, e-mail address, telephone number and mobile number (“contact information”). It also includes, where applicable, your travel details, such as booking confirmation numbers, number of rooms, arrival and departure dates, payment information and other relevant information in connection with the purpose for which the personal information we collected via Channels. When you make a purchase or engage in other transactions, you may provide us with your contact information and, in addition, other information such as your date of birth, passport or ID number (or copy thereof) and your credit or debit card number. For particular types of purchases or transactions, you may provide us with other additional information, such as your profession, name of your employer and your professional address. When you use integrated social media features on Channels or other social media websites, your personal information may be collected by COMPANY for such purpose.

There are also other instances where you’ll provide us with information. For example, when you register a user account on our Channels, you may provide us your personal information as mentioned above.

 

Information We Collect Automatically
 

When you visit our Channels or use Wi-Fi services we make available at our properties, we automatically collect the following information:

• Patronage Behaviour, including your purchases, reservations and other activities performed within SJM Resorts;
• Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, session time, operating system and platform;
• IP address, this is identified and logged automatically in our server log files when you access our Channels. We use IP addresses to calculate usage levels, diagnose server problems and administer our Channels. We also may derive your approximate location from your IP address; and
• Channels visit information, including the full Uniform Resource Locators (“URL”) clickstream to, through and from the Channels (including date and time); products you viewed or searched for in the Channels; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the Channels.

 

Information Received from Third Parties
 

We also collect information about you (as relevant and appropriate to the COMPANY Service you have requested) from third parties, including online travel agencies and other third party hotel booking partners; consumer reporting agencies, in connection with a credit application or financial account with COMPANY, as further disclosed and described to you at the time of your application; COMPANY event ticket sales management partners, ticket brokers, and club promoters; social media channels, such as Facebook, WeChat or Instagram, consistent with your settings on such services; marketing and analytics providers; and third party analytics services and content from third party businesses, including as described in our Cookie Notice below.

 

Necessity to Provide Information
 

The information we request from you is necessary to fulfil the purposes detailed below. If you do not provide the required information, we may not be able to perform the underlying purpose, including, but not limited to, providing the requested or expected products, services or information.

 

Personal Data We Use
 

Purposes
 

We collect personal data to deliver superior quality of service. We will use the information you provide to us for the purpose you provided it to us (e.g., to make a reservation and book a suite at one of our properties), which is stated when information is collected. We may also use your information in other ways for our business purposes and to provide you with the products, services, and experiences you request and expect from us, including but not limited to the following purposes:

• To perform, manage and deliver an agreement we have with you;
• To fully respond to your questions, requests, or communications;
• To verify your identity;
• To process guest reservations and/or requests for information or services;
• To provide you with products and services, including but not limited to loyalty membership and benefits and display of content;
• To check if you qualify for certain offers or services (e.g. special events, promotional offers, etc.) and for payment and billing for products and services;
• To develop new COMPANY products and services;
• To improve and personalize the guest experience for you and others;
• To audit, research and conduct analysis in order to maintain and improve our services and protect our guests and patrons;
• To perform credit concession, debt collection, payments and bank transfers;
• To conduct statistical or demographic analysis, marketing and promotions planning and execution, market research and analysis, customer satisfaction and quality assurance surveys;
• To ensure the technical functioning and security of our network;
• To comply with applicable laws and regulations as well as the Court orders or other legal processes or other legal requirements of any governmental authorities;
• To protect the rights or property of SJM Group, its employees, and its guests and patrons;
• To administer your account, to save your personal settings, review previous bookings or plan and manage future reservations or benefit from other features only available to account holders (such as incentives or other benefits we may offer);
• To send you marketing communications or other promotional materials referring to contests, offers and/or promotions related with our services.

 

Cookie Notice
 

A “cookie” is a small text file that Channels can place on your computer to store your preferences. Cookies are not personally identifiable by themselves, but they can be linked to personal data you provide to us.

We may use cookies so that we can improve your online experience, including to detect your browser’s capabilities, to track ads we display to you, to store login and purchase information of your choice, and to generate statistics on Channels usage.

You have many choices to manage cookies on your computer. Most browsers allow you to block or delete cookies from your system, and you can set most browsers to prevent cookies from being placed on your devices. If you do this, however, you may have to manually adjust preferences every time you visit Channels and it may not be possible to use the full functionality of the Channels.

 

Personal Data We Share with Third Parties
 

Provided that we are allowed (or required) to, we may share the information we collect with other companies within SJM Group, our agents, our service providers, our contractors, our business partners; with governmental authorities, statutory boards, government officials, law enforcement authorities, industry associations, legal process participants such as our legal advisers, courts, or other alternative dispute forums; and/or with other third parties in connection with any proposed or actual changes in our business structure or ownership. We will always require any third party with which information is shared to exercise reasonable care to protect such information and restrict the use of such information to the purposes for which the information is shared. In some cases, we will seek or may be required to collect your specific consent.

Although you may opt out of the use and sharing of personal information for marketing purposes, there may be situations in which we are still allowed (or required) to use and share information we collect to the authorities for the purpose of legal compliance.

We use the services of third-party service providers, such as e-mail service providers, website, App and system development service providers, platform owners or providers of logistic support to systems websites and Apps, data management service providers, and/or marketing companies assisting with the development and support to marketing campaigns or events of us. These service providers act as contractors under the authority of COMPANY and COMPANY may share your personal information with these service providers. These service providers are contractually prohibited from using personally identifiable information for any purpose other than for the purposes COMPANY consented to by you.

We prohibit the sale of personal information by said service providers. We also prohibit the transfer of personal information by said service providers to other entities outside the SJM Group without your approval. We contractually require these service providers to implement technical and organizational security measures designed and appropriate to protect personal data due to be processed against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against other unlawful forms of processing. The measures adopted should ensure a level of security appropriate to the risks represented by the processing and the nature of the data to be protected. These measures may vary depending on the applicable legal requirements.

Note on third party websites. Our Channels may contain links to third party websites, which are not controlled by us and which are not covered by this Privacy Policy. We are not responsible for the privacy policies of websites to which our Channels links. If you provide any information to such third parties, we strongly suggest you to review such third party’s privacy policies before using and/or accessing certain sections of such websites.

 

Data Transfer – Macau and Cross-Border
 

We may transfer, process and store your personal information within and outside of Macau or outside of regions or countries in which you are located, including but not limited to Mainland China, Hong Kong SAR, Singapore and other countries and jurisdictions outside of Macau.

If you are located in the European Economic Area (“EEA”) and you provide personal information to us, in order to fulfil your request or for the purposes set out above , please note that such personal information may be transferred to and stored in Macau or other regions or countries where we do business and where other companies within the SJM Group, our agents, our service providers, our contractors, our business partners, relevant governmental authorities, statutory boards, government officials, law enforcement authorities are located. Although the data protection laws of various countries may differ from those in your own country, we take appropriate steps to ensure that your personal information is handled in accordance with the Privacy Policy and relevant applicable laws. We may transfer your information to third parties located outside the EEA where we have taken adequate measures to ensure that appropriate safeguards are in place.

If you are a resident of the People's Republic of China (“PRC”) and are located within the PRC, we shall inform you and seek your separate consent in circumstances where we will transfer or process your sensitive personal information.

 

Protection and storage
 

The information we collect may be processed through manual or automated means, and may be digitally stored on premise. Our staff is required to take reasonable measures to ensure that unauthorized persons cannot view or access your personal information.

While stored, the information we collect is kept strictly confidential and not made accessible to any third parties. Security and confidentiality of the data is protected by systems and procedures no less protective than those followed by the industry standards. However, no security system is impenetrable, and these systems could become accessible in the event of a security breach. While we cannot guarantee that loss, misuse, or alteration of information will never occur, we use reasonable efforts to prevent it. Please keep in mind that no method of storage or transmission over the Internet is completely secure, so your use of our products and services and provision of information to us that was not specifically requested is at your own risk.

We will retain your personal data for no longer than is necessary for the purposes for which it was collected or for which it is further processed, unless the data is also retained to satisfy any applicable legal, regulatory or contractual obligations.

 

Changes to This Privacy Policy
 

We reserve the right to revise this Policy at any time without prior notice. When this Policy is revised in a material way, the revised Policy will be posted in our Channels(s).

Your continued use of our Channels and acceptance of our services at COMPANY after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided or your explicit consent is not required by law.

 

Severability
 

In case any provision of this Policy is deemed invalid, illegal or unenforceable, the validity, legality and enforceability of the remaining provisions of this Policy shall not in any way be affected or impaired thereby.

 

Language
 

To the extent that there are any inconsistencies among English and Chinese versions of this Privacy Policy, the English version shall prevail.

 

Governing Law and Jurisdiction
 

This Policy shall be governed by and construed in accordance with the laws of Macau. You hereby submit to the exclusive jurisdiction of the Macau courts in connection with any disputes arising out of this Privacy Policy.

 

Contact Us
 

For questions regarding this Privacy Policy or if you have a privacy concern or questions about how your personal data is used, please contact us by the following means:
E-mail: dataprotection@sjmresorts.com
Official Address: Avenida de Lisboa, nº23, Hotel Grand Lisboa, 8º andar, em Macau

You, as data subject, may access, rectify or update any of your personal information at any time in accordance with the PDPA. Further, if you wish to opt-out of receiving marketing communications or other promotional materials from us, or do not want us to use or share your personal information for marketing purposes with SJM Group or with our business partners, please contact us by the abovementioned means.