Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how Private Sanctuary Limited and its affiliates (collectively referred to as "us", "we" or "our") collect, use and process your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) ("PDPO"), the associated regulations and guidelines as may from time to time be issued by the Privacy Commissioner for Personal Data, Hong Kong.
For the purpose of the GDPR, Private Sanctuary Limited, whose address is at 1F, 28 Wong Chuk Hang Road, Hong Kong, is the controller who determines the purposes and means of processing of your personal data collected through kapaloasis.com and any related websites owned and/or operated by us or on our behalf (collectively, "our website") or other channels described in this Privacy Policy.
This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to help you make an informed decision before providing us with your personal data.
We intend to collect, use, process and disclose your personal data in the manner set forth in this Privacy Policy.
There are two broad categories of information that we collect from you, (A) personal data and online identifiers and (B) non-personal data.
"Personal data" means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly.
We collect certain types of personal data, including your name, gender, date of birth, identification numbers, company (if applicable), contact information (such as address, phone number and email address), payment information (such as credit or debit card information), photographs and video footage taken at events organised by us and/or our business partners and any other information which you may provide in any forms submitted to us or via other forms of interaction with us.
Personal data is collected by us in various circumstances, including the following:
It is voluntary for you to supply your personal data to us, although you may not be able to use our services or acquire our goods if you do not supply your personal data. We may not be able to process your enquiry or request, and no contract for the provision of goods and/or services will be formed, if you do not supply the personal data required on our relevant forms.
We may also obtain personal data about you from other sources and combine it with information you provide to us. If you provide us with any personal data relating to a third party (such as information about a spouse, children, parents, employees and/or authorised representatives), by submitting such information to us you represent that you have obtained the consent of that third party to your providing us with their personal data for the respective purposes.
When you visit and use our website, we may also collect information about you using online identifiers such as cookies and web beacons.
Cookies are small data files sent to your browser or device to store information about you when you visit our website. Cookies do a number of different jobs, such as letting you navigate between pages efficiently, identifying your behaviour, remembering your preferences and generally improving your user experience. They can also help to ensure that the advertisements you see online are more relevant to you and your interests.
Most browsers automatically accept cookies. You can, however, modify your browser settings to disable cookies. If you choose to do so, some of the functionality of our website may be impaired.
We may also use cookies from third parties to help us provide you and others with social plugins and other customised content and experiences.
Some cookies do not collect information that personally identifies you. They collect more general information such as how users arrive at and use our website, or a user's general location. However some other cookies can identify you and may contain or collect personal data. The type of information we collect as a result of a cookie is specific to your computer and may include, without limitation, the Internet Protocol (IP) address and the date and time you accessed our website. The data stored on a cookie can be retrieved by us when you visit our website.
When you visit our website, you will see a banner seeking your consent to the placing and use of cookies on your device. You may either give such consent or reject the placing and use of cookies. You can also remove existing cookies from your device using your browser options. If you want to block future cookies being placed on your device you can change your browser settings to do this. For more information on managing cookies see aboutcookies.org, which contains comprehensive information about how to restrict or block cookies on a wide variety of browsers. You can also review and update your choices at any time via our Cookie Preferences page.
In addition to cookies, we may also use web beacons and other similar technologies to deliver or communicate with cookies, in order to better understand how you interact with the content on our website.
We may also include web beacons in email messages to determine whether messages have been opened and acted upon, and how.
The information we obtain in this manner enables us to customise the services we offer, as well as measure the overall effectiveness of our online content, advertising campaigns and the products and services we offer through our website.
Our advertising partners may also place web beacons and other similar ad tracking technologies on our website to collect information.
You can refuse web beacons by refusing to accept cookies.
We also collect certain non-personal data when you visit and use our website. Such data is entirely anonymous and is aggregated for statistical analysis ("Aggregate Information"). Like many website operators, we may use an independent company (the "Third Party Market Research Company") to measure and analyse usage across our website. We use the Third Party Market Research Company's services to collect Aggregate Information on the usage of our website, including the following:
This Aggregate Information is collated by the Third Party Market Research Company and provided to us to assist in analysing the usage of our website. This is so that we can improve the content and navigability of our website as well as our services and facilities.
We collect, use and process your personal data for purposes connected with our business, including to respond to your enquiries, to provide you with information about Kapal Oasis and our other developments and services, to process your registration or appointment, to manage events and promotions, to carry out our obligations under any contract with you, to comply with applicable laws and regulations, to detect and prevent fraud, and for the direct marketing purposes described below.
In order to facilitate our business operations and the provision of goods and services, your personal data may be disclosed, for one or more of the purposes listed in this Privacy Policy, to the following third parties (whether located in Hong Kong or abroad):
In situations in which the above third parties receive your personal data from us, we will require the third parties to exercise reasonable care in protecting your personal data so that it is in compliance with the PDPO.
We intend to use your personal data for direct marketing purposes. We may not use your personal data for such purposes unless we have received your consent. Our direct marketing may be conducted via various communication channels such as your email address, correspondence address, phone number and SMS. In this connection, please note that:
We will use and provide your personal data for direct marketing purposes only in accordance with the PDPO. You may indicate your consent to the intended use and provision of your personal data for direct marketing purposes by ticking the relevant box or boxes when providing us with your personal data through our website or through enquiry or registration forms. Please refer to the Opt-Out section below on how to opt out of our direct marketing communications.
You may request to access or correct your personal data in accordance with the PDPO. We may charge a reasonable fee for the processing of such a data access request. Requests should be sent to the contact details below.
We will retain your personal data collected for as long as it is necessary to fulfil the purpose for which it was collected, the legal and/or business purposes of Private Sanctuary Limited, and/or as may be required by applicable law. When destroying personal data, we will take commercially reasonable and technically feasible measures to make the data irrecoverable or irreproducible, as may be required by applicable law.
We take the security and protection of your personal data very seriously. As such, we store your personal data on secure servers and have put in place appropriate security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification and disposal of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which is wholly attributable to factors beyond our control.
In connection with our business, we may use your personal data to make various decisions about you and your eligibility to access our services, to prevent abusive use of our services, to determine what marketing offers are most likely to be of interest, to ensure the security of our systems, to detect fraud or to profile you or assign you to a particular segment. Some of these decisions may be taken on an automated basis, including by matching your personal data against other information in our possession or against data models created for us. If you are assigned to a segment, we may use the segment information to tailor our marketing communications (if permitted under applicable laws) to include offers and content that are more relevant to you. You will not be subject to automated decisions that produce legal effects concerning you or similarly significantly affect you, unless we have a lawful basis for doing so.
The personal data that we collect or obtain from you may be transferred to jurisdictions that offer lesser protection of personal data than that provided in your jurisdiction. In particular, we may transfer your personal data to Service Providers in jurisdictions outside of Hong Kong. Such transfer would be made with appropriate or suitable safeguards or with your explicit consent. Such transfer may present possible risks for you due to the lack of an adequacy decision or appropriate safeguards.
Our website may contain links to other websites operated by third parties such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. You are encouraged to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
We permit a child under the age of 16 to use our website and to provide his or her personal data to us provided that the child has obtained his or her parent's or legal guardian's consent. If you are a child under the age of 16, you warrant and represent that your parent or legal guardian has consented to your use of our website and your provision of personal data.
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. We will notify you of changes to this Privacy Policy by posting the amended policy with the date it was revised on our website. You are encouraged to visit the website from time to time to ensure that you are well informed of our latest policy in relation to personal data protection.
If you have any questions about this Privacy Policy, or wish to access, correct or opt out of the use of your personal data, please contact us at:
Private Sanctuary Limited
1F, 28 Wong Chuk Hang Road, Hong Kong
Email: privacy@kapaloasis.com
This Privacy Policy was last updated on 06 June 2026.