Updated 18/08/2025
This Data Protection Notice (“Notice”) sets out the basis pursuant to which the Aerapass Group of Companies (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data (Privacy) Ordinance (CAP 486) (“PDPO”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1.
As used in this Notice:
"customer" means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a relationship with us for the supply of any goods or services by us; and
"personal data" means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include and may not be limited to name, residential address, email address, telephone number, nationality, date of birth, photographic, employment information and financial information. For example, we will collect some information from you when you visit our websites. How you or the customer use services available to you will determine the amount and type of information that we will collect about you.
3.
Other terms used in this Notice shall have the meanings given to them in the PDPO (where the context so permits).
4.
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your authorised representative) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPO or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5.
We may collect and use your personal data for any or all of the purposes which include and may not be limited to the following:
(a)
performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b)
verifying your identity;
(c)
responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d)
managing your relationship with us;
(e)
processing payment or credit transactions;
(f)
complying with any applicable law, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g)
training our staff;
(h)
collecting payment from you;
(i)
any other purposes for which you have provided the information;
(j)
transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Hong Kong or abroad, for the aforementioned purposes; and
(k)
any other incidental business purposes related to or in connection with the above.
6.
We may disclose your personal data including and not limited to:
(a)
where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(b)
to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
7.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
8.
In compliance with the PDPO, we may collect, use or disclose your personal data without your consent for the legitimate interests of the Aerapass Group or another person. In relying on the legitimate interests exception of the PDPO, the Aerapass Group will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
9.
In line with the legitimate interests exception, we will collect, use or disclose your personal data for the following including and not limited to the following:
(a)
Fraud detection and prevention;
(b)
Detection and prevention of misuse of services; and
(c)
Network analysis to prevent fraud and financial crime, and perform credit analysis.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
10.
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
11.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within twenty-two (22) business days of receiving it.
12.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
13.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
14.
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
15.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
16.
We will respond to your request as soon as reasonably possible. In general, our response will be within twenty-two (22) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPO).
17.
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, controls (such as good password practices, need-based for data disclosure, etc), encryption, secure data back-up and regular patching of open time password(s), software, web security measures against risks, usage of one time password(s) and other authentications (playmulti-factor authentications (mfa)) to secure access and security review and testing performed regularly.
18.
Aerapass stores personal information with an encrypted database on our servers. We will take reasonable steps to protect personal information from loss, misuse, unauthorised access, modification or disclosure.
19.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
20.
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
21.
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
22.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
23.
We generally do not transfer your personal data to countries outside of Hong Kong. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPO.
24.
Where your personal data is held outside of the EEA, we make sure that it is protected to a similar extent as in the EEA by ensuring that at least one of the following protection as the EEA affords is done, and by putting in place a contract with the third part that requires them to protect such data to equivalent standards as the EEA.
25.
When you visit the website, our server places small pieces of data known as ‘cookies’ on your hard drive. Cookies are small pieces of information that are transferred to your computer when you visit a website for record-keeping purposes. We may use cookies to provide us with aggregate (anonymous) information on how people use our websites and to help us improve them. Customer and user-related and usage data is needed. We do not link this information back to customer information that you have provided to us nor provide it to other third parties for marketing purposes.
26.
Most Web browsers are set to accept cookies. However, if you do not wish to receive any ‘cookies’ you may set your Web browser to refuse cookies. Only necessary cookies are used by us to run our site. You consent to these cookies by using our website.
27.
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : Philip Penfold
Contact No. : +852 5801 0003
Email address : privacy@aerapass.com
28.
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
29.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
A.
Controller / Processors. Where we determine the purposes and manner of processing, Aerapass acts as data controller (or the equivalent under local law). Where we process personal data on behalf of a client under that client’s instructions, we may act as data processor in respect of that processing.
B.
Categories of personal data we process. We may process the following categories of personal data, including but not limited to:
(a)
Identity data (name, date of birth, national ID, passport details);
(b)
Contact data (postal address, email address, telephone numbers);
(c)
Financial data (account numbers, transaction history, payment card details, holdings);
(d)
KYC / AML and identity verification data (proof of identity/address, source of funds, beneficial ownership);
(e)
Employment and corporate data (company name, position, corporate registration);
(f)
Technical and usage data (IP address, device identifiers, API usage logs, cookies);
(g)
Communication data (recordings of calls, emails, correspondence); and
(h)
Any other data reasonably necessary to provide our services or required by law.
C.
Purposes of processing & lawful bases (GDPR Article 6). We process personal data for the following purposes and on the corresponding lawful bases:
| Purpose | Typical lawful basis (GDPR) | PDPO / other justification |
|---|---|---|
| To provide and administer accounts, payments, card services and other contracted services | Performance of a contract with the data subject | Provision of services to Customer |
| Identity verification, due diligence, sanctions screening, and AML/CFT compliance | Compliance with a legal obligation | Statutory AML / sanctions obligations |
| Fraud prevention, anti-money-laundering and security and related risk management | Legitimate interests of Aerapass (balanced against individual rights) | PDPO / regulatory requirements |
| Customer support and communications | Performance of a contract / legitimate interests / consent (where required) | Customer service |
| Marketing (where applicable) | Consent (or legitimate interests where permitted) | Consent where required by law |
| Analytics, service improvement and system operation (including logs and performance monitoring) | Legitimate interests | Operational necessity |
| Meeting legal and regulatory obligations (e.g., tax, reporting, lawful requests) | Compliance with a legal obligation | Statutory duties |
Where we rely on legitimate interests, we have undertaken an internal balancing test to ensure such interests are not outweighed by the rights of the data subject.
D.
Recipients and disclosures. We may disclose personal data to:
(a)
Affiliated group companies and service providers (e.g., payment processors, card issuers, banks, IT and cloud providers, KYC/AML vendors);
(b)
Professional advisors (lawyers, auditors) and insurers;
(c)
Regulators, law enforcement and other public authorities where required or permitted by law;
(d)
Successors and assigns in the event of a corporate reorganisation, sale or transfer of business; and
(e)
Other third parties with your consent.
All third-party recipients are required to process personal data only for the purposes we authorise and to maintain appropriate security.
E.
International transfers and safeguards. Personal data may be transferred to, stored and/or processed in jurisdictions outside the EEA. When transferring personal data from the EU/EEA to countries outside the EEA, Aerapass will ensure an adequate level of protection by using one or more of the following safeguards as appropriate:
(a)
an adequacy decision issued by the European Commission;
(b)
EU Standard Contractual Clauses (SCCs) adopted by the European Commission;
(c)
binding corporate rules (BCRs) where implemented; or
(d)
other appropriate technical and contractual measures approved by the relevant supervisory authority.
F.
Data retention. We retain personal data only for as long as necessary for the purposes set out in this Notice, and to comply with legal, regulatory and contractual obligations. Retention periods will vary by category. All retention periods are subject to override by legal or regulatory obligations. If you require a retention schedule for a specific category of data, please contact the DPO.
G.
Your rights. Depending on the law applicable to you, you may have rights, including to:
(a)
Access your personal data and obtain a copy;
(b)
Rectify inaccurate or incomplete data;
(c)
Erase ('right to be forgotten') where lawful grounds exist;
(d)
Restrict processing in certain circumstances;
(e)
Object to processing based on legitimate interests or for direct marketing;
(f)
Data portability — receive personal data in a structured, machine-readable format and transmit to another controller;
(g)
Withdraw consent where processing is based on consent; and
(h)
Not be subject to automated decision-making or profiling that produces legal effects or similarly significant effects.
To exercise your rights, submit a written request to the DPO. We will acknowledge receipt and respond ordinarily within one (1) month of receipt (may extend by two months for complex requests; we will notify you if extension is necessary). We may request proof of identity and may charge a reasonable fee only where permitted by law (e.g., for manifestly unfounded or excessive requests).
If you are an EU resident and are unsatisfied with our response, you have the right to lodge a complaint with your local supervisory authority.
H.
Automated decision-making and profiling. Where we carry out automated decision-making or profiling that produces legal or similarly significant effects (e.g., credit scoring, automated compliance decisions), we will:
(a)
notify affected individuals that such processing is taking place;
(b)
explain the logic involved and the significance and envisaged consequences; and
(c)
provide appropriate safeguards, including human review and the ability to challenge the decision where required by law.
I.
Data security. We implement appropriate technical and organisational measures to protect personal data, including access controls, encryption of stored data, network security, multi-factor authentication for privileged access, periodic security testing, logging and monitoring, and staff training. While we use commercially reasonable measures to protect data, no security system is impregnable. Accordingly we cannot guarantee absolute security.
J.
Personal data breaches. Aerapass has an incident response plan. In the event of a personal data breach, we will:
(a)
investigate and assess the risk to data subjects;
(b)
where required by law, notify the relevant supervisory authority without undue delay and, where feasible, within 72 hours of becoming aware; and
(c)
if the breach is likely to result in a high risk to individuals’ rights and freedoms, notify affected individuals without undue delay and provide guidance on mitigation.
Where notification is not required by law, we may still inform affected individuals at our discretion.
K.
Data Protection Impact Assessments (DPIAs). We conduct DPIAs where processing is likely to result in high risk to data subjects’ rights and freedoms (e.g., large scale processing of special categories of data, systematic monitoring).
L.
Children and minors. We do not knowingly collect personal data from children under the age of 16 without verifiable parental consent. If we learn that we have collected personal data of a child without consent, we will take steps to delete it.
We’d be happy to chat with you and clear things up for you. Anytime!
30c, Morrison Plaza
5-9a Morrison Hill Rd
Wan Chai, Hong Kong
100 Peck Seah St
07-02 PS100
079333 Singapore