Emperor Cinemas - Privacy Policy

Emperor Cinemas (“the Company”) respects personal data privacy 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 Emperor Cinemas Member (“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, date of birth, email address, telephone number, member’s reward record, survey and activity comments as well as transaction related information will be collected, used and held by the Company. In case of using mobile app, International Mobile Station Equipment (“IMEI”) number and Media Access Control Address (“MAC Address”) will also be collected, used and 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 be under the age of 18, please consult your parents or guardians before providing your personal data. If we are unable to obtain the data which is specified as “Compulsory Items”, the requested services, products, gifts, privileges or information may not be provided. Our mobile app cannot be downloaded to your handset without your permission to provide IMEI number and MAC Address.


The main purposes of collecting and retaining personal data are as follows:

Payments: Payment processing and/or verification of transaction details and/or credit card privilege entitlements;

Member Account and Activity Handling: Registration for membership; identity verification; statement; members’ rewards input; gift redemption; purchase and activity contact etc.; date of birth maybe used for giving out birthday privileges or gifts;

Handling of Personal Data Requests: Verification of identity for handling requests of access, correction and erasure of personal data;

Statistics: Carry out statistics and data analysis, such reports will contain only anonymous data for customers' reference as well as improving our service and product quality;

Mobile App Services: The system may identify the handset by memorizing the IMEI through registration by the user as a FREE Regular Member. By using the same handset, the user is not required to enter his/her password again for the next purchase. We will also monitor and analyze the download status of Emperor Cinemas mobile app to ensure system performance. MAC addresses are collected for the purpose of analyzing the hit rate of our mobile app in order to source and make available promotional or marketing information that you may be interested;

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, which include our film introduction, cinema activities, members’ privileges 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 Personal Data

The membership information you provided for registration, with personal identifiable data and/or any copies thereof will be erased and/or destroyed within 2 years after received from Members. Credit card information will be destroyed within 6 months after payment process. If you desire to erase your personal data from our members’ and/or contact databases after the expiration of membership, please let us know.

Accuracy and Change of Personal Data

In order to ensure the correctness of the Members’ personal data, particularly contact details, retained by the Company, you may receive our request of confirmation or verification. Please feel free to contact us for correction or change of personal data or opt-out from receiving future direct promotional and marketing information. This service is free of charge.

Access to Personal Data

You are welcome to contact us for requesting access, verify, update or correct your personal data held by us. This service is free of charge. You are also welcome to request a copy of your personal data. We will verify your identity before handling your request and a reasonable fee may be charged for complying with such request. We will respond to your request within the time frame prescribed by the Personal Data (Privacy) Ordinance.

Transfer/Disclosure of Personal Data and Security Measures

Your personal data collected and maintained by the Company may be transferred/disclosed to the parties as listed below, where applicable, for performing certain professional services in relation to our business, which include payment processing and/or verification, ticketing system operation, membership card services, discount/privilege offers, website management, system development and maintenance etc. Those parties include:

1.      Our joint promotion business partners;

2.      Banks or financial institutions;

3.      Any professional services companies who are under a duty of confidentiality to the Company and are acting for or on behalf of the Company; and/or

4.      Government or regulatory authorities or law enforcement agencies as required or authorized by law.

We have established in place 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. However, we may not be able to provide services to you refuse your personal data to be transferred/disclosed to parties 2-4 above.

Our security measures are listed below:

1.      The services companies shall not keep any personal data transferred to them longer than is necessary for processing of the data.

2.      Controls on password complexity, retries 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 through our website or mobile app. Our Secure Socket Layer (SSL) system will prevent your data being transmitted from unauthorized interception or access by third parties.

4.      Standalone 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 non-compliance with the related obligations.

6.      The security system will be reviewed regularly.

Exclusion 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. We cannot guarantee its absolute security. Unless there is proved negligence, we shall not accept 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, Emperor Cinemas Member, and Emperor Cinemas website/mobile app services respectively.

Third Party Websites

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. We have not authorized them to collect any personal data from you. Therefore, we are not responsible for any exposure of your personal 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. We collect 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 English version shall prevail.

Contact Us

Should you have any requests (including Opt-out), enquiries or comments to our Privacy Policy, please email at enquiry@emperorcinemas.com.hk or write to 20/F, Emperor Group Centre, 288 Hennessy Road, Wanchai, Hong Kong. Normally, your requests or enquiries will be handled within 14 working days after receipt of the same and verification of your identity (if necessary).

Effective Date

This Privacy Policy shall be effective from 14 October, 2017.

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