| 2. | Security
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| The Company uses industry standard technologies such as firewalls, security electronic transactions (SET) and secure socket layers
(SSL) to protect the confidentiality of a User’s personal identifiable information inputted and transmitted across the Company’s websites namely,
miramar-group.com, miramarhk.com, newtonhk.com,
newtoninn.com, nanhai-hotel.com, miramar-express.com, resort.com.hk and newtonkln.com (“the Websites?. However, while “complete security?currently does not exist on the Internet, the Websites are designed to give the User control over the privacy of their credit card information, name, address, email and any other information a User provides the Company with.
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| If a User is using a security-enabled browser (such as Microsoft Internet Explorer version 2.1 or greater, or Netscape Navigator version 2.0 or greater), the information sent to the Company regarding their purchase is encrypted, making it extremely difficult to read even if it is wrongly intercepted. The industry-standard SET and SSL technology the Company uses ensures the encryption of critically sensitive information like your credit card information.
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| The Websites are registered with site identification authorities to enable a User’s browser to confirm the identity of the Company before any transmission is sent. With this technology, the identity of the Websites are automatically confirmed behind the scenes prior to the transmission of any information requested to complete an online booking and a User’s data reaches only their intended target or the Users browser notifies them (prior to a User sending any personal information) that the potential receiving website looks suspicious and should be avoided.
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| If at any time a User would like to make a booking, but would rather give their credit card information to a representative over the telephone or by telefax, then they will be given the opportunity to choose from those alternatives as specified on the booking pages.
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| 3. | Types of personally identifiable information the Company collects
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| To enable us to provide a User with our services, we require each User to provide to us information, such as full name, full address, phone number, fax number, e-mail address, credit card number and credit card expiration date. The Company will only use this credit card information to verify a User’s name, address, and other information, properly provided by a User. If the Company has trouble processing any bookings, the contact information provided will be used to make contact with a User.
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| In the course of using the Websites, we automatically track certain information about a User. This information includes the URL that a User just came from (whether this URL is on the Websites or not), what browser they are using, and their IP address. Many websites automatically collect this information.
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| In addition, the Company uses cookies on certain pages of the Websites. Cookies can help us provide information, which is targeted, to a User’s interests. Cookies are stored on a User’s hard drive, not on the Websites. Most cookies are "session cookies," meaning that they are automatically deleted at the end of a session.
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| If a User chooses to engage in our services provided by the Websites, the Company will collect information about such behaviour. The Company will share aggregated demographic information with its subsidiaries, associated parties and affiliates. This is not linked to any personal information that can identify any individual person.
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| If a User uses a third party service co-branded by the Company, the third party service provider may provide information about a User to the Company and likewise a User’s information will need to be provided to specific hotels, airlines or the like, as appropriate, depending on the services the User is purchasing.
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| If a User sends to the Company personal correspondence, such as emails or letters, or if other Users or third parties send correspondence about a User’s activities or postings on the Websites, the Company may collect and retain such information in a file specific to the User.
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| 4. | What we do with User’s information
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| The Company internally uses personally identifiable information about a User to improve marketing and promotional efforts, to statistically analyse the usage of the Websites, to improve content and product offerings and to customize the Websites?content and layout. The Company believes that these uses allow improvement to the Websites and better tailors it to meet all User’s needs.
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| The Company may also use personally identifiable information about a User to deliver information to them that, in some cases, are targeted to the User’s interests, such as targeted banners and promotions.
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| The Company may use a User’s email address and, in rare situations their mailing address or phone number, to contact them regarding administrative notices from time to time.
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| The Company may use information in the file that the Company maintains about a User, and other information that the Company obtains from their current and past activities on the Websites, to resolve disputes, troubleshoot problems and enforce the Terms and Conditions of Use.
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| If a User elects to use the referral service to inform a friend about the Websites, the Company will ask them for the friend’s name and email address. The Company will automatically send the friend a one-time email inviting them to visit the Websites. The friend may contact the Company to request the removal of this information from the Company’s database.
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| From time to time the Websites request information from a User via surveys or contests. Participation in these is voluntary and the User has the choice whether or not to disclose information. Survey information will be used for purposes of monitoring or improving the use and satisfaction of the Websites.
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| 5. | Our Disclosure of User’s information
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| The Company does not and will not sell or rent any personally identifiable information about a User to any third party. The Company does aggregate personally identifiable information and disclose such information in aggregate to advertisers and for other marketing and promotional purposes. In these situations, the Company does not and will not disclose to these entities any information that could be used to personally identify a User. Certain information, such as a Users credit card number and bank account number are not disclosed in aggregate at all.
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| Throughout the Websites, the User is identified by their email address. As a result, a User may disclose their email address to other third parties that might send them unsolicited email and be able to personally identify all of their activities on the Websites.
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| The Company will, as required by the due process of law and the rules and regulations applicable to it in Hong Kong, at any one time, cooperate with all statutory regulators, law enforcement agencies and appropriate inquiries and with all third parties seeking to properly enforce their intellectual property or other rights.
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| The Company offers features on the Websites where the Company will by necessity, need to provide some of the User’s information to the third party offering such services. To the extent that the third party requires a User’s information to enable the User to use or provide their service, the Company will notify the User of the specific information that will be provided to such third parties. Before a User uses the service they should evaluate whether they will accept the terms and conditions of the third party service, and therefore irrevocably and unconditionally grant the Company the right to pass their information on to that third party.
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| Due to the existing regulatory environment in Hong Kong, where there is little or no relevant legislation except for the Data Privacy Ordinance, the Company cannot ensure that all of the User’s private communications and other personally identifiable information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), the Company may be forced to disclose information to the government, regulatory bodies or third parties under certain circumstances, or third parties may unlawfully intercept or gain access transmissions or private communications. Further, the Company can (and you irrevocably authorize us to) disclose any information about you to law enforcement, regulatory bodies or other government officials, as the Company, in its sole discretion, believes necessary or appropriate. Therefore, although the Company uses industry standard practices to protect a User’s privacy, the Company does not in any way expressly or implicitly, promise, and a User should not expect, that their personally identifiable information or private communications will remain private.
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| 6. | Reviewing and Changing Personally Identifiable Information
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| A User will be able to change and request removal of their personally identifiable information held by the Company, including their email address, their name, address, phone number, fax number and gender by simply sending an email to webmast@miramar-group.com.
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| The Company will retain in file information on Users. Such information is never completely removed from our databases due to technical constraints and the fact that the Company backs up its systems. Therefore, each and every User must be aware that they cannot expect that all of their personally identifiable information will be completely removed from the Company’s databases in response to such a request.
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| A User must promptly update their information if it changes.
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