As a responsible cargo terminal operator awarded by the Airport Authority Hong Kong, Asia Airfreight Terminal Company Limited (AAT), Asia Airfreight Services Ltd (AAS) the holding companies of AAT (including the head offices and other subsidiaries of them) (hereinafter referred to as “the holding companies”) and/or other subsidiaries of AAT (collectively referred to as “the Company”, “we”, “our” or “us”) are firmly committed to a set of business principles and ethics that help drive us forward. One of these principles is respect to people and privacy and that begins with how we respect and protect the personal data we receive. To preserve the confidentiality of your personal data provided to us, we maintain the following data privacy principles:
- we only collect personal data that we believe to be relevant and required for the purposes as stated in our Personal Information Collection Statement (“PICS”);
- all data collected are used exclusively for the purpose for which the data are to be used at the time of its collection;
- we will not disclose your personal data to third parties for direct marketing or other unrelated purposes unless we have expressly informed you and have your explicit consent or are required by law;
- we aim to keep your personal data accurate;
- we maintain appropriate security systems designed to ensure that the collected data are safely and appropriately maintained and are safeguarded against unauthorized accesses, tempering, amendments and/or deletions;
- on the reasonable requests of the relevant data subject, we aim to provide within a reasonable time the details of the data in our possession on the said data subject and provide reasonable access to the same and shall on his/her/its request, make the necessary corrections to such data;
- in the event that any data are no longer necessary to be maintained, we will within a reasonable period delete the said data from the database of the Company; and
- in all circumstances, we will comply with the Personal Data (Privacy) Ordinance (“the Ordinance”) and all other relevant regulations.
Personal Data We Hold
There are several broad categories personal data held by the Company:
- Customer and App user records are kept for the purposes of providing services, facilities and goods; responding to and following up on customer inquiries, cargo owner identification and/or verification; ensuring security and safety issues; conducting customer surveys, researching and developing products and direct marketing activities;
- Personal records are kept for human resources management and administration purposes such as managing the recruitment, assessment interview, background check, hiring, payroll, appraisal and termination of personnel of the Company;
- Contractor records are kept for the purposes of engaging, managing, monitoring and appraising our professional relationships with contractors and their staff who provide services to the Company;
- Other records that contain personal data held by the Company include records of our business partners, officers, shareholders, visitors and operational and administrative records that contain personal data.
We have legitimate interests in properly administering the services, facilities and goods we provide. In addition, our use of your personal data may be necessary for supplying you the said services, facilities and goods. Our use of your personal data may also be necessary to comply with our legal obligations and to establish or exercise our legal rights.
Transfer of Personal Data
We may disclose personal data when required to do so by law, for example, in response to a court order or requests from law enforcement agencies or regulatory authorities within or outside Hong Kong.
We may transfer your personal data to parties such as employees, related companies, including holding companies, subsidiaries, joint venture partners, agents, independent contractors, business partners and service providers, as necessary for any of the purposes stated in our PICS. Where personal data is provided to third party organizations, the personal data will only be transferred to such parties that respects privacy and are under a duty of confidentiality to the Company.
Accuracy of Personal Data
We have set up procedures in place to maintain personal data at a reasonable level of accuracy, completeness and relevancy for the purpose for which the personal data is to be used. We aim to keep your data accurate. However, we rely on you to disclose all material and accurate information to us and to inform us of any errors or changes in such information.
Individuals may amend their personal data, as appropriate, set out in "Access and Correction of Your Data" section below.
Retention of Personal Data
Our policy is to retain personal data for no longer than is required to fulfil the purpose (or any directly related purpose) for which the data was to be used, subject to the relevant legal, statutory and regulatory requirements.
Security of Personal Data
We have put in place appropriate physical, electronic, and managerial procedures to safeguard and help protect personal data against unauthorized or accidental access, erasure or other uses. HTTPS are authentication of the accessed website, and protection of the privacy and integrity of the exchanged data while in transit. It protects against man-in-the-middle attacks, and the bidirectional encryption of communications.
Direct Marketing Activities
We intend to use your personal data for direct marketing purpose. We may not use your personal data for such purpose unless we have received your consent to such intended use. Our direct marketing may be conducted via various communication channels such as your email address, correspondence address, phone number and SMS.
Your name, email address, correspondence address, home phone number, mobile phone number, fax number, gender, date of birth, and age may be used by us in direct marketing of the following classes of goods and services: cargo related services, logistic services and training programmes.
We also intend to provide your personal data to our holding companies, subsidiaries and business partners for their use in direct marketing.
We will use and provide your personal data for direct marketing purpose only in accordance with the Ordinance. We may not do so unless we have received your explicit consent to the same when providing us with your personal data through our websites, forms or through other channels.
If you prefer for your personal data not to be used for the purposes of direct marketing activities, please contact the Chairman of our Personal Data Protection Committee along with your name notifying us that you do not wish your personal data to be used for such purposes. Please refer to “How to Contact Us” section below.
Personal Data Collected Through This Website
We may collect personal data through your use of this website such as name, gender, age, telephone number and email address. Certain information about your computer may also be collected when you visit this website, such as the type of the Internet browser and operating system you are using and the domain name of your Internet service provider. You are not required by law to provide your personal data. However, the Company may not be able to provide you with the services, facilities and goods you may require unless you provide the personal data sought from you.
Use of Personal Data Collected Through This Website
The Company uses the personal data collected through this website primarily for supplying to you the services, facilities and goods you require; to respond to your inquiries; to perform statistical analysis, analysis of website usage or customer requirements; direct marketing activities; and to notify you of any changes to this website or our services which may affect you.
Where cookies are used on websites to collect information about visitors: Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or inform you when they are set. However, if you do so, certain functionalities of this website do not work properly.
Access and Correction of Your Data
Under the Ordinance, you have the right of access to, correction and erasure of your personal data kept and used by the Company. The Company has the right to charge a reasonable fee for processing data access request. Requests may be made in writing to the Chairman of our Personal Data Protection Committee. Please refer to “How to Contact Us” section below.
How to Contact Us
Revised: Aug 2022
Personal Information Collection Statement (PICS)
Asia Airfreight Terminal Company Limited (AAT), Asia Airfreight Services Ltd (AAS), the holding companies of AAT (including the head offices and other subsidiaries of them) (hereinafter referred to as “the holding companies”) and/or other subsidiaries of AAT (collectively referred to as “the Company”, “we”, “our” or “us”) will collect, use and process your personal data (which, in this PICS, will include personal data of any other person as provided by you) in accordance with the Personal Data (Privacy) Ordinance (“the Ordinance”). We respect personal data privacy and are committed to implementing and complying strictly with the data protection principles and the relevant provisions of the Ordinance.
Personal data may include your name, gender, date of birth, identification numbers, company (if applicable), contact information (e.g. address, phone number, email address), payment information (e.g. credit or debit card information), personal reference and salary history, photographs and video footages and any other information which you may provide in any forms submitted to us or though other forms of interaction with us.
You have a choice whether to provide us with your personal data. However, if you fail or refuse to provide us with your personal data when requested, it may result in the Company being unable to provide goods or services to you, unable to process your job application or unable to comply with your other requests (as the case may be). Your personal data may also be collected or received by the Company from the third parties in the ordinary course of the Company’s operations, for example, from the relevant agencies, consignees or airlines (if applicable), in accordance with the relevant provisions of the Ordinance.
1. Purposes of collecting your personal data
Your personal data shall only be collected for a lawful purpose directly related to a function or activity of the Company. The data collected should be necessary and adequate but not excessive for such purpose. The means of collection should be lawful and fair.
The purposes for collecting your personal data by the Company include the following:
I. Provision of goods and services, operations and customer services
- for operational purposes by the Company including the processing and handling of cargoes and/or documents;
- cargo/cargo owner identification and/or verification;
- business analysis relating to the Company;
- forwarding of the data to other parties for the purpose of provision of services (including customs clearance);
- confirming the accuracy of the information collected;
- performing any functions and activities related to our products and/or services including but not limited to marketing, audit, reporting, general servicing and maintenance of online or other services;
- security and safety purposes;
- complying with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognised bodies (whether within or outside Hong Kong) that is assumed by or imposed on the Company;
- exercising any rights the Company may have in connection with the provision of products and/or services.
II. Provision of training services
- Providing training services to applicants;
- For identification of applicants;
- For contacting the applicants;
- For issuing certificates (*your personal data may be sent to third-party institutions for issuing the requisite certificates).
III. Human Resources Management and Employment
- Internal administrative practice;
- To process job application, evaluation of academic qualification and working experience;
- To provide / process employees’ and their dependents’ salaries and benefits;
- To provide certification of documents for employee such as reference letter, salary/appointment/leave certify letter, etc;
- To administer and propose staff promotion and internal transfer;
- To evaluate employee’s job performance;
- To provide and cater for staff training and development;
- To disclose personal data on lawful request in accordance with the law;
- To facilitate organization restructuring or human resources planning;
- To facilitate communication;
- Staff satisfaction survey; and
- any other purposes relating to the above-mentioned items.
IV. Corporate Governance
- Monitoring and governance by holding companies;
- Corporate news and information sharing with holding companies; and
- Business and management decision-making.
2. Disclosure and Transfer of Personal Data
The Company will keep your personal data confidential. Only authorized staff members of the Company will have access to and handle your personal data. Where appropriate, the Company may disclose or transfer your personal data to the following classes of persons within or outside Hong Kong solely for the purposes set out in paragraph 1 above:
- local and overseas subsidiaries as well as joint venture companies internally;
- holding companies (i.e. including the head office and other subsidiaries of the holding companies);
- agents, service providers, and contractors engaged in activities on behalf of the Company;
- any person in connection with any claims made by or against or otherwise involving you in respect of any goods and/or services;
- agents, contractors and service providers including all kinds of professionals such as accountants, auditors, legal advisors, medical practitioners, insurance agents and any other consultants or agents employed by the Company;
- departments of the Government of the Hong Kong Special Administrative Region if so required by the law;
- any person which has undertaken to the Company to keep such data confidential; or
- any person to whom the Company is under an obligation or otherwise required to make disclosure under the requirements of any law, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to the Company including but not limited to any local or foreign regulators, governmental bodies, or industry recognised bodies.
3. Rights of Access and Correction to Data Collected
Under the Ordinance, you have the right of access to, and correction of, personal data kept and used by the Company. The Company has the right to charge a reasonable fee for processing data access request. Requests may be made in writing to the Chairman of our Personal Data Protection Committee at the following address:Asia Airfreight Terminal Company Limited 10 Chun Ping Road Hong Kong International Airport Lantau, Hong Kong
Revised: Aug 2022