The Hongkong and Shanghai Hotels, Limited and its group companies ("HSH Group") have a strong commitment to provide quality service to our shareholders, guests, patrons and potential customers and are further committed to protecting your privacy.

To ensure you can make informed decisions and feel confident about supplying personal data relating to you, we provide this policy statement outlining our data collection practices and the choices you have concerning how the data is being collected and used.

The term "Data" refers to any personal information that can be used to identify you as an individual. It can include, among other things, your name, identity card number, mailing address, telephone number, email address, login name and/or your opinion.

We limit the collection, use and retention of the Data to the specific information we need for legitimate purposes to administer our business. We take appropriate steps to protect Data collected against unauthorised access, disclosure or alteration, and to keep such Data up to date.

This privacy statement contains numerous general and technical details about the steps we take to respect your privacy concerns. We have organised the privacy statement by major processes and areas so that you can quickly link to the information of most interest to you.

Please read this policy statement carefully before submitting any Data to us. If, after reviewing this privacy statement you have any privacy questions or concerns or would like to request access to or correction of Data, please send an email to privacy@peninsula.com or send a letter or fax to:

Data Privacy Team

The Hongkong and Shanghai Hotels, Limited
8/F, St George's Building
2 Ice House Street
Central, Hong Kong

Fax: +852 2147 3720

Please allow 10 business days for us to process any correction of Data.

In order to protect your Data, we will require that you prove your identity to us in relation to your request to access your Data, which may consist of a copy of a government-issued identification, your signature, correspondence address or phone number so we can check them against our records and satisfy ourselves as to your identity. The above information is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Data.

This data privacy statement was written on 11 April 2011. In the future, we may need to make additional changes. All additional changes will be included in the latest data privacy statement published on this website, so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclosures of that information to third parties. Any changes to our statement will become effective upon posting of the revised statement on this site. Use of this site or our services following such changes constitutes your acceptance of the revised statement then in effect.

At this website, you can obtain information about some of our operations, projects, services and activities of the HSH Group. In order to do so, you may be asked to provide Data voluntarily. The HSH Group uses the Data that you provide primarily for supplying you with routine services and information that you require, to respond to your inquiries, process your appointment of proxy and instructions, and to perform shareholder profiling and statistical analysis. We may also send you notices, corporate communications, and any other communications with respect to the HSH Group which may be of interest to you.

Browsing

When you browse this website, we do not collect Data unless you voluntarily and knowingly provide it to us, for example by accessing our website from a link in an email that we send to you or when you log-in to your account.

Fraudulent emails

Please note that the HSH Group companies will never send you an email requesting your personal identity card, password, credit card number or passport. If you receive any suspicious emails that looks like it is from our group, but asks you for your credit card number or passport, personal identity card or social security number, it is a fraudulent email, or "phishing". We recommend that you do not reply to the email or click onto any links or pop-up messages and report to the local authorities which handle fraudulent emails.

Unsecure communication

It is important to note that all email communication is not secure. There is a risk inherent in the use of email. Please be aware of this when requesting information or sending forms to us by email, for example, from the "Contact Us" section of our website. Our email responses to you may include sensitive or confidential information. Please bear in mind that no security system or system of transmitting information over the Internet is guaranteed to be secure.

To be prudent, it is advisable to always close your browsers when you have finished providing us with your Data. Although the session will automatically terminate after a short period of inactivity, it is easier for a third party to gain access to your profile whilst you are logged onto our website and making a reservation.

The HSH Group companies train their employees and staff on the importance of Data privacy and protection. Our privacy policy is updated as required to reflect any changes in applicable laws and developments in best practice procedures. Further, we limit the number of individuals within the companies with access to Data to those directly involved in the process of providing quality service to you.

Secure transmission and storage of data

We treat all Data that you provide to us as confidential information. To prevent Data from unauthorised access or leakage, we have adopted and regularly monitor our group’s security and data privacy policies and procedures.

Data transmission across international borders

As a global company, we have established a global network comprised of properties, offices, global customer service centers, data centers, trusted service providers, and trained associates around the globe. The nature of our business and our operations require us to transfer your Data to other group companies, properties, centers of operations, data centers, or service providers that may be located in countries outside of your own. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, the HSH Group will take appropriate steps to ensure that your Data is protected and handled as described in this privacy statement.

Disclosure of information to third parties

In addition to the required information sharing described above, we use the services of third party agents for the purpose of mailing materials to our shareholders. These parties are contractually prohibited from using Data for any purpose other than for the purpose specified in their respective contracts. We do provide non-personally identifiable information to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the sale of Data to entities outside of the HSH Group for any use unrelated to our group operations or use of Data by third party for their own purposes.

Cookies

Our website only uses "Cookie" technology as a tracking tool with Google Analytics. Cookies identify your browser, rather than you and cannot be used by themselves to disclose your individual identity. Cookies enable us to track the number of page visits from the same computer or browser to be aggregated for statistical purposes.

The types of Cookies that we use are referred to as "session" Cookies and "persistent" Cookies. Session Cookies are temporary and are automatically deleted once you close your Internet browser. Persistent Cookies remain on your computer hard drive until you delete them or are otherwise removed upon expiration. We do not use Cookies to ascertain any Data about you apart from what you voluntarily provide us in your dealings with our group operations. Cookies do not corrupt or damage your computer, programs, or computer files.

You may set your browser to block Cookies (consult the instructions for your particular browser on how to do this), although doing so will affect your ability to perform certain transactions, use certain functionality, and access certain content on our website.

Pixel Tags

Our group and our third-party service providers use pixel tags (also known as "clear gifs", "beacon gifs" etc.).

Pixel tags are not visible to the user of the website and consist of a few lines of computer coding delivered with the web page. Pixel tags are not used to collect any Data about you apart from what you voluntarily provide us in your dealings with our group operations and will allow us to obtain non-personal or aggregate information to be used to enhance your online experience. The HSH Group and our email service providers use pixel tags to:

• Track customer response to our website content;
• Determine your ability to receive HTML-based email messages. Our email service provider includes a pixel tag, which they refer to as a "coded sensor" in all of the HTML-based messages sent on our behalf. The sensor activates when the email message is opened and flags the email address of the user as one that is capable of receiving HTML-based email messages. This capability helps our service provider to send the email in a format you can read. The sensor does not collect or use any other information. If you cannot receive HTML, you will not receive a functioning sensor;
• Know how many users open an email and allow our service provider to compile aggregated statistics about an email campaign for us; and
• Allow us to better enhance customer support and site usability.

The Data that you provide will be retained for such period as may be necessary for our record and verification purposes.

In the unlikely event of a Data breach, we are prepared to follow any laws and regulations which would require us to notify you of the disclosure of private information.

Our careers website allows individuals that wish to be considered for potential employment to attach their curriculum vitae for consideration. We will not use the information you provide for any purpose other than to determine your qualifications for potential employment at the HSH Group.

The HSH Group is only responsible for the privacy statement and content of this website. Our website may contain links to other sites of third parties. We are not responsible for the data collection and use practices, privacy policy or the use of Cookies on other websites that you have accessed this website from and to the non-HSH Group websites that you may access from this website. We advise you to review the privacy policies of such third parties before submitting personal Data.

This website is not intended for children and minors and we do not knowingly solicit or collect Data from children and minors. As a parent or legal guardian, please do not allow your children to submit Data without your permission.

This privacy statement complies with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region as well as applicable local laws.

As an international business with operations in different parts of the world, we may need to disclose Data when required by relevant law or court order, or as requested by other government or law enforcement authorities, or otherwise in good faith where disclosure is otherwise necessary to protect the rights or properties of the HSH Group. This also applies when we have reason to believe that disclosing the Data is necessary to identify, investigate, protect, contact or bring legal action against someone who may be causing interference with our guests, visitors, associates, rights or properties (including this site), or to others, whether intentionally or otherwise, or when anyone else could be harmed by such activities.