1. Introduction

The Fine Dining Club ("we," "us," or "the Club") is committed to protecting the privacy and personal data of our members, prospective members, and other individuals interacting with our services. This Privacy Policy outlines how we collect, use, disclose, store, and protect your personal data in compliance with the Personal Data (Privacy) Ordinance (PDPO) (Cap. 486) of Hong Kong. By joining the Club, participating in our events, or engaging with our services (e.g., website, newsletter, or membership application), you consent to the practices described in this policy.

2. Personal Data We Collect

We collect personal data to provide and enhance our services, including membership management, event organization, and communication. The types of personal data we may collect include:

• Identity and Contact Information: Name, email address, phone number, mailing address, and date of birth (e.g., for birthday gift eligibility).
• Membership Information: Membership tier, payment details, event attendance records, and preferences (e.g., dietary restrictions for events).
• Event-Related Data: Information provided during event registrations, such as RSVP details or guest names.
• Communication Preferences: Preferences for receiving our monthly digital newsletter or other communications.
• Website Usage Data: Information collected via our website (e.g., IP address, browser type, or pages visited), including data from cookies or similar technologies (if applicable).
• Other Information: Any additional data you voluntarily provide, such as feedback, survey responses, or inquiries.

3. How We Collect Personal Data

We collect personal data through the following methods:

• Membership Application: When you apply for membership (Savor Tier or Connoisseur Tier) via our application form (online or offline).
• Event Participation: When you register for or attend events, including kitchen cross-over events or new restaurant experiences.
• Website Interaction: Through our website (e.g., fine dining map integration) or online forms.
• Communications: When you subscribe to our newsletter, contact our team, or respond to surveys.
• Third Parties: From partnered restaurants, chefs, or event organizers (e.g., for event logistics or new restaurant openings), with your consent or as permitted by law.

4. Purposes of Collecting and Using Personal Data

We use your personal data for the following purposes, in line with the PDPO's requirements:

• Membership Management: To process applications, manage membership tiers, handle renewals, suspensions, and transfers.
• Event Organization: To facilitate event registrations, track attendance, and accommodate preferences (e.g., dietary needs for kitchen cross-over events).
• Birthday Gift Program: To deliver gifts during your birthday month.
• Newsletter Delivery: To send the monthly digital newsletter with fine dining trends, chef spotlights, new restaurant openings, and event announcements.
• Service Improvement: To analyze feedback, survey responses, or website usage to enhance our events and member experience.
• Legal Compliance: To comply with legal obligations under the PDPO or other applicable Hong Kong laws.
• Communication: To respond to inquiries, provide updates, and manage event invitations or RSVPs.

5. Disclosure of Personal Data

We may disclose your personal data in the following circumstances, ensuring compliance with the PDPO:

• Service Providers: To third-party service providers (e.g., Supabase for membership database management, payment processors like Stripe, or event organizers) who assist in delivering our services, bound by confidentiality agreements.
• Partnered Restaurants and Chefs: To facilitate event logistics (e.g., kitchen cross-over events, new restaurant openings), with your consent or as necessary.
• Legal Requirements: When required by law, court order, or regulatory authority in Hong Kong to disclose personal data.
• Membership Transfers: If you request a membership transfer (subject to Club approval), limited data may be shared with the transferee to verify eligibility.

We will not sell, rent, or share your personal data for marketing purposes without your explicit consent.

6. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, or misuse, in accordance with PDPO requirements:

• Secure Storage: Personal data is stored in a secure membership database (e.g., Supabase) with encryption and access controls.
• Limited Access: Only authorized staff can access personal data, subject to strict confidentiality obligations.
• Secure Transmission: Data collected via our website or payment systems is transmitted using secure protocols (e.g., HTTPS, secure payment gateways).
• Regular Reviews: We conduct periodic reviews of our security measures to ensure ongoing protection.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy or as required by Hong Kong law:

• Active Members: Data is retained for the duration of your membership, including during approved suspensions.
• Terminated Members: If membership is terminated, data is retained for 6 months to address any disputes or inquiries, then securely deleted unless legally required.
• Event Data: Event-related data (e.g., RSVPs, dietary preferences) is retained for 12 months after the event, unless needed for ongoing services.
• Newsletter Subscriptions: Data for newsletter delivery is retained until you unsubscribe or membership ends.

8. Your Rights Under the PDPO

As a data subject under the PDPO, you have the following rights regarding your personal data:

• Access: Request access to the personal data we hold about you, including details on how it is used.
• Correction: Request correction of inaccurate or incomplete personal data.
• Erasure: Request deletion of your personal data, subject to legal retention requirements (e.g., for financial records).
• Objection: Object to the use of your data for specific purposes (e.g., newsletter communications).
• Withdrawal of Consent: Withdraw consent for data processing where applicable, which may affect your ability to receive certain services (e.g., newsletter, event invitations).

To exercise these rights, contact our Data Protection Officer at finediningmap@gmail.com. We will respond within 40 days, as required by the PDPO, and may charge a reasonable fee for data access requests.

9. Cookies and Website Tracking

If you interact with our website (e.g., for membership applications or fine dining map integration), we may use cookies or similar technologies to enhance your experience:

• Essential Cookies: Enable core website functions (e.g., form submissions, event RSVPs).
• Analytics Cookies: Collect anonymized data on website usage (e.g., pages visited, session duration) to improve our services.

You can manage cookie preferences through your browser settings. Disabling cookies may limit certain website functionalities.

10. Third-Party Links

Our website or newsletter may include links to third-party sites (e.g., partnered restaurants, event venues). We are not responsible for the privacy practices of these sites. Please review their privacy policies before providing personal data.

11. International Data Transfers

Some events may involve sharing limited personal data (e.g., name, dietary preferences) with overseas partners (e.g., restaurants, travel agencies). We ensure such transfers comply with PDPO requirements, using contractual safeguards or your explicit consent.

12. Updates to This Privacy Policy

We may update this Privacy Policy to reflect changes in our services or legal requirements. Updates will be posted on our website and communicated to members via email or newsletter. The effective date will be updated accordingly.

13. Contact Us

For questions, concerns, or to exercise your data rights, please contact our Data Protection Officer:

14. Complaints

If you believe your personal data has been mishandled, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong: