Privacy Policy

1. Our Privacy Policy

1.1 Our company recognizes the importance of your privacy and maintaining the confidentiality of your Personal Data (which has the meaning ascribed to it under the Personal Data (Privacy) Ordinance (Cap. 486) under the laws of the Hong Kong S.A.R. (“the Ordinance”)). This Privacy Policy (“this Policy”) applies to all products and services provided by us, including but not limited to the KABU PASS APP (the “APP”), the “KABU PASS Membership Rewards Program” (the “Rewards Program”), and sets out how we may collect, use, process, disclose and retain your Personal Data. This Policy is governed by and observes the requirements under the Ordinance.

1.2 Your privacy is important to us and we have taken steps to minimize the amount of information to be collected from you.

1.3 By registering as a member of the Rewards Programs, using the APP, or using other products and services provided by our company to you, you hereby consent to the collection, use, processing, disclosure and retention of your Personal Data in the manner and for the purposes in accordance with this Policy.

2. Collection of Personal Data

2.1 Please note that it is necessary for you to provide us with certain Personal Data in order for you to become a member of the Rewards Programs and to enjoy the member privileges of the Rewards Programs. You understand that if you are unable or unwilling to provide personal information as marked "mandatory" during the member registration, our company may not be able to accept your membership application. For all other personal data, it is optional for you to provide or not. Personal Data that is necessary for you to provide during the member registration includes:

a. name;

b. gender;

c. mobile phone number;

d. email address; and

e. month of birth.

2.2 When our company provides products and services to you, we may also collect the following information related to you:

a. Personal Data in relation to your membership as listed in Clause 2.1 above;

b. in-app activities when using the APP;

c. transaction history and/or payment details (excluding credit card info);

d. balances and records of member benefits, including but not limited to membership points and e-coupons;

e. remote ticketing, reservation and ordering records;

f. brand and dining preferences;

g. ID (identification code) of your mobile phone and your location;

h. demographic information and feedback you provide in any of our surveys and questionnaires; and

i. any of your information that is necessary in administering your membership under the Rewards Programs, providing you with our services, and complying with our obligations under the law.

3. Purpose of using the Personal Data

3.1 If you provide any Personal Data to us, you are deemed to have authorized us to collect, use, process, disclose and retain such Personal Data for the following purposes:

a. processing your application for membership to the Rewards Programs and administering and managing your membership under the Rewards Programs;

b. verifying your identity;

c. verifying your eligibility to participate in the Rewards Programs;

d. providing you with regular communications with details of the Rewards Programs and related benefits;

e. providing you with customer service and responding to your queries;

f. marketing promotions and services of our company and/or any of our group companies and/or associates, including notifying you of any special offers or new products and sending any promotional material to you relating to promotions and services of our company and/or any of our group companies and/or associates, the Rewards Programs, and the APP;

g. performing research or statistical analysis in order to understand and improve products and services of our company and/or any of our group companies and/or associates and for marketing and promotional purposes; and

h. making such disclosures as may be required for any of the above purposes or as required by law.

4. Disclosure of Personal Data

4.1 We may disclose and/or transfer (whether in Hong Kong or abroad) your Personal Data to any of our group companies and/or associates for any of the purposes set out in Clause 3 above.

4.2 We may disclose and/or transfer (whether in Hong Kong or abroad) your Personal Data to any third party services providers engaged by us in providing administrative, data processing, payment services, research and marketing, distribution, telecommunications, professional or other similar services to us in relation to our services (“Third Party Service Providers”). These Third Party Service Providers are under a duty of confidentiality to us and are only permitted to use your Personal Data in connection with the purposes specified in Clause 3 above, not for their own purposes and not for their direct marketing.

4.3 We may share data that cannot be used to identify you with any third parties for the purposes set out in Clause 3 above, and may use such data in order to better understand your needs and to improve and adapt our products and services.

4.4 We may disclose and/or transfer your Personal Data to courts, law enforcement, regulatory or other governmental agencies if we are required to do so by law, or by a warrant, subpoena or court order.

5. Data Security

5.1 Any Personal Data supplied by you will be retained by us and will be accessible by our authorized employees and any authorized Third Party Service Providers engaged by us, for or in relation to any of the purposes stated in Clause 3 above.

5.2 All reasonable and practicable steps are taken to ensure that any Personal Data held by us is protected against unauthorized or accidental access, processing, erasure, loss or use, and is stored in a secure and safe place and only accessible by our authorized employees or authorized Third Party Service Providers.

5.3 You should be aware that no system is impenetrable, and no information provided over the Internet can be guaranteed to be completely secure. Accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the Internet.

6. Your Rights 

6.1 We will use your Personal Data in direct marketing (whether by email, phone, SMS or media whether now known or available in the future) for the purposes stated in Clause 3 above provided that we have obtained your prior consent or indication of no objection. You have the right to choose whether to receive our direct marketing materials and change your preference from time to time. If you wish to opt out from receiving direct marketing materials from us, you can change your communication preference setting in the APP or send us your request with your name, registered mobile phone number and email address to member.kabu@kabu.com.hk. If you opt out from receiving direct marketing materials from us, we may still send you non-promotional communications in relation to the operation and administration of your membership account.

6.2 Under the Ordinance, you have the right to check whether we hold any of your Personal Data, request access to your Personal Data held by us and correction of such data. Any request for in relation to the above or any questions regarding this Policy should be in writing and addressed to: Customer Service Department, Kabushikigaisha Limited, Unit 03, L22, Tower 1, Enterprise Square Five, MegaBox, 38 Wang Chiu Road, Kowloon Bay, Hong Kong.

6.3 In accordance with the Ordinance, we reserve the right to charge you a reasonable fee for the processing of any Personal Data access or correction request.

7. Policy Updates

7.1 We reserve the right to update this Policy from time to time without prior notice. The updated version of this Policy will be posted on the APP and website with the last update date stated. You are encouraged to check this Policy regularly.

8. Others

8.1 In case of any discrepancy between the Chinese and English version of this Policy, English version shall prevail.

8.2 Should you have any questions or comments concerning this Privacy Policy, you may contact our Customer Service Department at member.kabu@kabu.com.hk.

Last update: March 2024