Hong Kong Express Airways Limited (“HK Express” or “we”) is committed to protecting children’s personal information and privacy. This Children Privacy Notice (this “Notice”) sets out what children’s personal information we collect and how we use it, the rights of children and their parents/guardians (“Guardians”) as well as instructions for their Guardians. Unless otherwise indicated, for the purposes of this Notice, a “Child” means a minor who is under the age of 14.
This Notice applies to all products and/or services that we provide to our customers located in Mainland China and process children’s personal information. We may revise and update this Notice from time to time in accordance with updates to laws and regulations, as well as requirements for maintaining orderly transactions, protecting consumer rights and interests, and business operations. We will disclose changes to you in an appropriate manner.
This Notice specifies the rules for processing children’s personal information based on the HK Express Customer Privacy Policy - Mainland China. To the extent that this Notice is different from the HK Express Customer Privacy Policy - Mainland China, this Notice applies; to the extent that this Notice does not specify, the HK Express Customer Privacy Policy - Mainland China applies.
This Notice does not apply to any website not owned or managed by HK Express or any other third-party website that children may visit through third party links and/or activities. With respect to such websites, please see those respective sites for the privacy policies that may apply.
We hereby remind you that:
If you are a Child, you are required to read this Notice carefully with your Guardian and obtain your Guardian’s consent to use our products and/or services or to provide us your personal information.
If you are the Guardian of a Child, please read and fully understand the terms of this Notice, especially those in bold, before your Child access or use the products and/or services we offer or providing your Child’s personal information to us.
If you are a Guardian of a Child, please read and choose carefully before agreeing to this Notice, especially the words in bold. Only use or give permission for your Child to use the service or product after confirming that you have fully understood and agreed to all of the Notice. If you do not agree with the contents of this Notice, you and the Child should immediately cease accessing/using the products and/or services offered byHK Express.
If you are not the Child’s Guardian, please ensure that you are authorised by the Child’s Guardian to provide the Child’s personal information and purchase tickets for the Child.
If you have become aware of a breach of your account and password used to buy tickets for the Child, or any other incident that may result in the disclosure or misuse of the Child’s personal information, please contact us through our contact details located in Section 7 of this Notice.
Personal information refers to all kinds of information recorded electronically or otherwise, that can by itself, or in combination with other information, including but not limited to a natural person’s name, date of birth, ID card number, personal biometric information, address, telephone number, etc., be used to identify a natural person.
Personal information of children under the age of 14 is sensitive personal information. We collect and process children’s personal information with strict protection measures when there is a specific purpose and sufficient necessity for doing so.
We may collect personal information of children from various sources. We may collect personal information of children that you provide when you use our digital channels (“Digital Channels”) (including our official HK Express website (hkexpress.com), mobile application, WeChat mini programme, WeChat official account, etc.), receive offline services, or participate in other activities hosted by HK Express. We may also use cookies and other technologies to automatically collect device information or usage information from children when you visit our Digital Channels. We collect and use children’s personal information only for the purposes described in this Notice; if you refuse to provide this information (especially children’s travel documents, payment and contact information), you may not be able to use some of the services we provide.
2.1 Booking and purchasing tickets for your child
If you are the Guardian of a Child, when you purchase a ticket for your Child through the Digital Channels, we will collect your Child’s name, departure location, travel document details including passport number, passport expiry date, country that issued your passport and your country of residence (this information is also known as Advanced Passenger Information (API)), travel destination, travel category (round trip/one way), flight number, flight time, fare type, and seat number (if applicable).
2.2 Collection of children’s personal information from third parties
We may collect personal information about children from third parties, including but not limited to travel agents, other airlines and providers of other travel-related services. Please refer to the “How we collect Personal Information” section of the HK Express Customer Privacy Policy - Mainland China for the scope of the collection.
2.3 Other scenarios
We may also collect and use other personal information about children during your Child’s use of our products and services in order to provide you or your Child with our products and services (e.g., to provide personalised displays or recommendations). Please refer to the “The Personal Information We Collect”, “How we collect Personal Information” and “Why we collect and use your Personal Information” sections of the HK Express Customer Privacy Policy - Mainland China for specific purposes of use, the scope of personal information collected and the consequences of refusing to provide the information.
In addition, we may also automatically collect your Child’s personal information through cookies, SDKs and other similar technologies. Please refer to the “Use of Cookies and Software Development Kits on Cathay Pacific Group Sites” sections of the HK Express Customer Privacy Policy - Mainland China for details.
Please note that in some cases we are unable to identify whether the specific person using our product or service is a Child or not. In cases where the user does not voluntarily provide personal information, such as page views, we are unable to determine whether personal information that is not clearly age-identifiable is children’s personal information, and we will process such personal information in accordance with the provisions of the HK Express Customer Privacy Policy - Mainland China. If you find that the personal information we are processing is personal information of a Child, please contact us promptly.
2.4 Legal basis for processing children’s personal information
Please understand that, in accordance with national laws and regulations, we may process children’s personal information only under any of the following circumstances:
- Where the Guardian’s separate consent is obtained.
- Where it is necessary for the conclusion or performance of a contract to which the individual is a contracting party.
- Where it is necessary for performing a statutory responsibility or statutory obligation.
- Where it is necessary for responding to a public health emergency, or for protecting the life, health or property safety of the natural person in the case of an emergency.
- Where the personal information is processed within a reasonable scope to carry out any news reporting, supervision by public opinions or any other activity for public interest purposes.
- Where the personal information, which has already been disclosed by the individual or otherwise legally disclosed, is processed within a reasonable scope and in accordance with the applicable law.
- Any other circumstance as provided by national laws and regulations.
If we use children’s personal information for purposes other than those set forth in this Notice, or use information collected for specific purposes for other purposes, we will seek the consent of the Guardian as required by applicable law.
3.1 Sharing
For the personal information you provide, we will keep it confidential and protect it in accordance with the relevant laws and regulations of the People’s Republic of China, and will not provide or display such information to any third party in any way, except for the following cases:
- We will share children’s personal information with their Guardians who can access and manage the relevant personal information;
- Other scenarios as disclosed in the “Who we share your Personal Information with” section of the HK Express Customer Privacy Policy - Mainland China.
Only after you have provided authorisation and standalone consent, and on the basis of lawfulness, legitimacy, necessity and specific and explicit purposes will we provide children’s personal information to the extent necessary for providing products and/or services to children. We will also assess the legality, legitimacy, necessity, and impact on the rights of children of providing personal information of children to such third parties.
3.2 Entrusted processing to third parties
- We may entrust third party service providers (including agents, contractors, suppliers and other companies in the Cathay Pacific group which HK Express belongs to) to process children’s personal information. If we do so, we will evaluate the entrusted party capabilities and the entrusting process and require the processing to not exceed the scope of our authorisation by singing an agreement. Please refer to the “Who we share your Personal Information with” section of the HK Express Customer Privacy Policy - Mainland China for details.
3.3 Transfers
In the event of a merger, acquisition or liquidation of the Cathay Pacific group, or other situation involving a merger, acquisition or liquidation that involves the transfer of personal information, we will require the new company, organisation or individual in possession of the Child’s personal information to continue to be bound by this Notice and the HK Express Customer Privacy Policy - Mainland China, or we will require the company, organisation or individual to seek authorization from the Child’s Guardian again.
3.4 Disclosure
We will only publicly disclose a Child’s personal information under the following circumstances.
- We are allowed to publicly disclose a Child’s personal information with the express consent or choice of the Child’s Guardian.
- To comply with the request of judicial or administrative authorities to disclose a Child’s personal information in accordance with legal procedures and legal authority.
We will retain children’s personal information for the minimum period necessary for achieving the specific purposes, except where otherwise required by law or regulation or where we have other legal bases. After the above storage period, we will delete or anonymise your children’s personal information.
We have put in place commercially reasonable physical, electronic, and procedural safeguards to protect children’s personal information from unauthorised access, public disclosure, use, modification, damage, or loss in order to meet the requirements of applicable laws and regulations.
All personal information that we collect about children is stored on our secure servers or those of our subcontractors. When accessing or using this information, we adhere to our security policies and standards and strictly control access to children’s personal information. You are responsible for maintaining the confidentiality of any personal information we send to you about children and for complying with any other security procedures we instruct you to follow. if we provide you with (or you have chosen) a password that allows you to access parts of our website or mobile application, please do not share your password with anyone.
If you are aware that your Child’s personal information has been compromised, please contact us via the contact information in Chapter 7 of this Notice so that we can take appropriate action.
5.1 Your and your Child’s rights to personal information
In accordance with the relevant laws, regulations and standards of China, we ensure that you and your children can exercise the following rights with respect to children’s personal information. Please refer to the “Your rights and contacting us” section of the HK Express Customer Privacy Policy - Mainland China for details.
5.2 How we respond to relevant requests
You may exercise your Child’s personal information rights at any time through our Digital Channels, or through the contact information disclosed in Chapter 7 of this Notice. We will respond to relevant requests in accordance with applicable laws and regulations, provided that you give necessary information to verify the identity of the Child and the identity of the Child’s Guardian. In general, we do not charge fees for reasonable requests, but we may charge fees for repeated requests or requests that exceed reasonable limits, depending on the circumstances.
If you would like to exercise your Child rights or require additional information or clarification on the use of specific personal information, please contact us using the details in Chapter 7 of this Notice.
Please note that, in accordance with relevant national standards, we will not be able to respond to requests from children under the following circumstances:
- When the requests are related to the fulfilment of our obligations under laws and regulations.
- When the requests are related to national security and defence security.
- When the request is related to public safety, public health, or significant public interest.
- When the request is related to criminal investigation, prosecution, trial and execution of judgment.
- When there is sufficient evidence of subjective malice or abuse of rights by the data subject.
- When it is necessary to protect the life, property, and other significant legitimate interests of the subject of the personal information or other individuals, but it is difficult to obtain the authorisation and consent of the individual.
- Responding to your request would cause serious harm to your or other individuals’ and organisations’ legitimate rights and interests.
- When these requests are related to trade secrets.
We may be required to export your personal information to jurisdictions located outside of Mainland China. Where we transfer your personal information abroad, we ensure that appropriate safeguards are in place and that the transfer is conducted in compliance with applicable laws and regulations.
As an entity headquartered in Hong Kong, we are an overseas recipient which receives and processes children’s personal information. We process children’s personal information within the purposes and methods provided in this Notice and the categories of processed personal information have also been disclosed in this Notice.
Children’s personal information may also be provided to the following overseas entities or organisations: List of Third Parties outside Mainland China.
If you or your Child wish to exercise the rights as an individual under this Notice, or if you have any questions about how we process personal information about children, please contact us by email at dpo@hkexpress.com or write to us at the below mailing addresses. We will respond to you as soon as practicable and in compliance with applicable laws and regulations.
The Data Protection Officer
Hong Kong Express Airways Limited
1st Floor, 11 Tung Fai Road,
Hong Kong International Airport, Lantau, Hong Kong