Privacy Policy

This Privacy Policy applies to personal information held by WIL as the data user, as described below. It will help you understand how we collect and use your personal information, who we share your personal information with, the circumstances when we will share it and what steps we will take to make sure that it stays private and secure. It should be read alongside the Membership Terms and Conditions and the Additional Terms and Conditions for Prestige Membership, as these include sections relating to the use and disclosure of information.

If you register to become our Member, and/or access or use the App or the Site, then this Privacy Policy is deemed to be agreed by you and will apply to you.

1. Definitions
   

   Capitalised terms not otherwise defined in this Privacy Policy will have the meanings set forth in this Clause 1.

   “Affiliates”

   means any direct or indirect parent companies, our direct or indirect subsidiaries or affiliates, or any other entity that controls, is controlled by or is under common control with us or Wilson Group Limited (whether through direct or indirect ownership of fifty (50%) or more of the shareholding or voting rights, or the right to control the management of the entity or to appoint or remove a majority of the board of directors).

   “Agreement”

   means the Membership Terms and Conditions, the Additional Terms and Conditions for Prestige Membership, and any other terms and conditions which WIL will communicate to Members from time to time.

   “Hong Kong”

   means the Hong Kong Special Administrative Region of the People’s Republic of China.

   “Member”

   means any person who is a member of the Platform; “Members”, “Membership” and “Memberships” shall be construed accordingly.

   “Merchants”

   means good retailers and service providers with whom WIL has made arrangements for Members to earn WIL Points and redeem free parking and other rewards under the WIL Engagement & Rewards Programme.

   “Partners”

   means the participating companies which offer Membership benefits and other special offers, privileges, promotions, discounts and incentives to Members.

   “Platform”

   means the motorist engagement platform administered and managed by WIL to provide services to Members, including but without limitation the designs, text, graphics, pictures, video, information, applications, software, music, sound and other files, and their selection and arrangement, of the Platform.

   “WIL Account”

   means the Membership account of the Platform set up for each Member.

   “WIL Engagement & Rewards Programme”

   means the rewards points programme operated by WIL through which the Platform is made available to Members for WIL Points accrual and redemption.

   “WIL ID”

   means a Member’s identification number for his/ her WIL Account, which is shown as a QR (quick response) code.

   “WIL Points”

   means the reward points that are made available to Members under the WIL Engagement & Rewards Programme.
2. Who We Are
   Let’s Go Limited (“WIL”, “we”, “us” and “our”) is the owner, operator and provider of the motorist engagement platform named “WIL – All-in-one Engagement Platform for Hong Kong Motorists”, which is accessible through the website www.gowil.com.hk and/or its sub-domains (collectively, “Site”), a mobile application (“App”) and other media platforms (altogether, “Channels”). We are a wholly owned subsidiary of Wilson Group Limited.
   
   Let’s Go Limited is the data user in respect of your personal data under the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong).
3. Are You Over 18?
   Our Platform and the Membership are intended only for people over the age of 18. As such, you will be required to provide your date of birth in order to register for the WIL Account.
4. How Do We Collect Data?
   Your personal information will either be provided by you, collected by us or captured under your consent when you use the Platform. We may collect information about you when you interact with us, e.g. when you visit the Channels, call us, or ask about any of our products or services. We may also collect your information from third parties such as our Affiliates, Merchants and Partners, marketing and research agents, organisations which conduct credit and fraud checks, and providers of third-party websites, apps and social media platforms. Details of how we collect your data are set out in Section 5 below.
5. What Information We Collect
   We will only collect your information in line with the relevant law and regulations. It may be necessary for you to provide us with some basic personal information in order to set up the WIL Account and receive benefits from the Membership. We will let you know when such information is necessary to supply. All other personal data is up to you to provide, as you prefer.
   
   
   1. Information you provide
      
      
      1. Personal details. When you open a WIL Account, you provide us with basic personal information such as your name, email address, mobile phone number, gender, address (district) and date of birth so that we can verify your identity and set up a basic profile for you.
         
         Moreover, if you wish to enjoy WIL parking offers, you need to provide us your Octopus number(s) and vehicle profile.
      2. Membership information. On opening the WIL Account, you provide us with your Membership information such as your username, password, membership status, WIL Points balance, records of your accrual and redemption activities, including your transaction history when you make a qualifying purchase or earning of WIL points through specified engagement actions. We associate your Membership information with your WIL ID.
      3. Vehicle profiles. You can build a profile for your car(s) by supplying information such as car brand, car model, car plate number, years of driving and purchase year at “My Car”. We will offer Free Motor Vehicle Personal Property Protection with your consent and recommend the relevant auto products and services to you based on your vehicle information.
      4. Interests and preferences. You can tell us your interests and preferences at “My Interests”, which we will use to customise our offers and rewards to you.
      5. Expense entries. Your expense data is recorded when you make entries at “Expenses”.
      6. Direct communications. When you communicate with us, for example, when you respond to in-App survey questions, report problems or raise queries, we may receive information about your demographic profile and feedback. We use this information to improve our performance, fix problems in the App and/or the Site or reply to your communications.
   2. Information created when you use the Platform
      
      
      1. Location data. We collect and use precise location information from your device with your permission when you choose to use location-related features, for example, when you use “Map” for driving directions, or when you enable “Geolocation” to share your location with us to earn extra WIL Points or to receive special offers. In each case, we will seek your prior permission to grant us access to your device’s location. Once accepted, we will collect information regarding the geographic location of your device. We use the location data to provide you with our services, to personalise your experience, and for marketing and advertising purposes.
         
         You can change your mind anytime and update your preferences through the Settings menu on both Android and iOS devices. However, if you disable your device's location services which is needed to use a feature, the use of such feature will be hindered. We therefore encourage you to allow WIL’s access to your device’s location if you wish to use location-related features so that you can enjoy a smooth user experience.
         
         We may, for research and statistical purposes, retain your location history but that will only take place after data aggregation and anonymisation so any results will not be directly linked to you.
      2. Transaction records. When you make a qualifying purchase, your WIL ID will be scanned to record the transactions in your WIL Account. Such data will then be processed by us to issue WIL Points.
      3. Log and usage information. Each time you open the App, we collect information about how and when you use it, for example, app crashes and other system activity. We use this information to improve the Platform in multiple ways. For example, fixing bugs to prevent future crashes and working out which features our users find most helpful.
      4. Cookies. We may use online tracking technologies such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:
         • your visits to our Platform, such as your browsing history, how long you stay on the App or the Site, and how often you visit the Platform;
         • your location information as provided by your mobile or other device when you interact with the Platform, including your general geographic location; and
         • the device that you use to browse the Platform (e.g. your device ID, operating system, type of device, browser type and version, mobile application crashes and other system activity, and third party sites you were using before interacting with our services).
         To learn more about how we use the above data, please see the section below on Cookies Policy.
   3. Information from other sources
      
      
      1. Payment details. If you wish to be our Prestige Member by paying a subscription fee, you will provide payment details directly to our payment processor which processes online transactions on our behalf. Our payment processor uses your payment details in accordance with its privacy policy. We may have access to your payment information in limited circumstances, for example, to handle your subscription inquiries.
      2. Parking information. To earn WIL Points or redeem free parking hours, we will retrieve your parking information such as parking location, gate-in / gate-out time and parking fees from the relevant Affiliate, Merchant or Partner which possesses such information, based on the Octopus and car plate numbers provided by you.
6. How We Will Use Your Information
   
   
   1. We will use your information for the purposes set out below.
      
      
      1. Account administration. To administer your WIL Account and Membership, such as creating and updating your account information; verifying your identity; creating a single profile about you, including combining your information with any other personal information already held by us and/or our Affiliates; processing WIL Points issuance and rewards redemptions; processing your payments; updating your Membership status and providing Membership benefits.
      2. Provision of services. We use your personal information to deliver our products and services and manage our relationship with you, including (unless you tell us otherwise) telling you about products and services we think may be relevant for you.
      3. Rewards programme. We use your personal information to operate the WIL Engagement ＆ Rewards Programme, e.g. to process your WIL Points balance, track your earning and redemption activities, process WIL Points issuance and rewards redemptions and tailor rewards that we present to you to better match your interests and preferences.
      4. Personalised experience. To provide you with personalised user experience in relation to your use of the Platform, such as recommending driving route options based on your itinerary; supplying traffic information relevant to you; providing relevant information on the products, services, special offers and other benefits offered by our Affiliates, Merchants and Partners.
         
         We may also use data analytics tools to determine whether the advertisements are effective, whether you may be interested in new products or services, or to customise the contents and types of offers and rewards that we present to you.
      5. Customer support. To assist you when you contact us, such as replying to your questions or investigating any of your concerns, and to monitor and improve our customer support services.
      6. Marketing. To provide you with Marketing Communications (as defined below) if you choose to receive them. Please see the section on Direct Marketing below for more information.
      7. Optimisation and improvements. We may use your information to understand and improve the Platform through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us, our Affiliates, Merchants and Partners to enhance the quality of our products and services, or to develop new features for the Platform, or to make marketing and strategic operations and plans.
      8. Market research. We may use your information for market research and to identify trends. Market research agencies acting on our behalf may get in touch with you by post, telephone, email or other methods of communication to invite you to take part in research. We will not invite you to take part in research using a communication method if you have asked us not to get in touch that way. Any responses that you provide whilst participating in market research will be reported back to us anonymously unless you give us permission for your details to be shared.
      9. Legal and administration purposes. We may use your personal data to comply with our legal and regulatory obligations; investigate or handle any incidents, claims or disputes; verify and process payment; screen against fraud, criminal or unlawful activities, or abusive redemption activities or suspicious Membership accounts; accounting, billing and audit purposes; recover money which you owe us; or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. Your personal data may also be used in relation to any legal proceedings concerning you, or used in order for us to exercise our rights under the Agreement.
7. Who We Might Share Your Information With
   There are circumstances where we will share your personal data with third parties within Hong Kong. We will not, however, transfer your personal data to any third parties outside of Hong Kong unless you have consented to such cross-border transfer or if we are under a legal obligation to do so. By opening a WIL Account and/or using the Platform, you agree to allow us to share your personal data with third parties for the specified purposes set out in this section.
   
   To protect your privacy and personal data, we endeavour to only share with third parties your information which has either been aggregated and anonymised, or which otherwise does not contain your name or contact details. Moreover, we undertake to implement safeguards in accordance with this Privacy Policy, the data protection principles and all applicable laws and regulations before allowing such data transfer. This includes imposing contractual obligations on these third parties to ensure that an adequate level of protection is in place to safeguard your rights.
   
   
   1. We may share your information with third parties where lawful to do so including where we or they:
      
      
      1. need to provide you with products or services you have requested, e.g. fulfilling a payment request;
      2. have a public or legal duty to do so, e.g. to assist with detecting and preventing crime;
      3. need to in connection with regulatory reporting, litigation or asserting or defending legal rights and interests;
      4. wish to send marketing communications to you, as long as you have given us your consent;
      5. have a legitimate business reason for doing so, e.g. to manage risk, verify your identity, enable another company to provide you with services you have requested, or assess your suitability for products and services; or
      6. have asked you for your consent to share it, and you have agreed.
   2. We may share your information with the following classes of people and companies:
      
      
      1. Affiliates. Your personal data may be transferred to our Affiliates for the above purposes. Similarly, we may receive your personal data from our Affiliates in order to fulfil a purpose. For example, we may retrieve your parking information from the relevant Affiliate so that we can issue or deduct WIL Points in your WIL Account.
      2. Merchants and Partners. Our Merchants and Partners are businesses which have made arrangements with WIL to provide goods, services, offers and rewards to the Membership. They include, but are not limited to, carpark operators, insurance companies, petrol stations, towing companies and other auto-related merchants and service providers. A full list of our Merchants and Partners are available for viewing on the App.
         
         When you make purchase or redeem rewards with your WIL ID, to the extent that the Merchants and Partners will have records of your transaction and payment details, we do not share your personal data with them except in limited circumstances where we may disclose your Membership information, for example, in the event of refund or dispute, so as to enable us to investigate the case.
         
         Please note that the Merchants and Partners may themselves directly collect personal data from you when you make a transaction with them. The handling of your information collected by the Merchants and Partners will be governed by their privacy policies. WIL is not involved nor are we responsible for the processing of your information so collected.
      3. Insurer Partner. The Free Motor Vehicle Personal Property Protection (“Free Insurance Protection”) is underwritten by Zurich Insurance Company Limited (“Zurich”) and arranged by Hung Kai Insurance Brokers Company Limited (“Broker”). We will share with Zurich via the Broker your information including your name, WIL ID, email address, mobile number and car plate numberin order for them to confirm your registration for the Free Insurance Protection. The data transfer is one-off, which takes place only after you elect to accept the offer.
      4. Search partner. We use Google as our search partner for driving directions. Google receives the place name you have searched for and if you have enabled location services in your device, Google receives your current location so as to make your search results as relevant as possible.
      5. Third-party service providers. Your personal data may be shared with any service providers (including subcontractors and agents) who process personal data on our behalf to help us administer and operate the Membership and the Channels; to process your payments; to conduct data analytics; to help aggregate and anonymise the personal data; or to carry out any of the purposes set out in this Privacy Policy. These service providers may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, payment processing companies, data management and analytics service providers and customer contact services.
         
         We only use trustworthy service providers, which are under an obligation to only use your personal data in accordance with this Privacy Policy.
      6. Professional advisors. When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers.
      7. Assignees. Your personal data may be shared with any people or companies where required in connection with potential or actual corporate restructuring, merger, acquisition, takeover, consolidation, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets, or any of our rights or obligations under the Agreement.
      8. Government and regulatory authorities. This Privacy Policy is governed by the laws of Hong Kong. We strive to handle your personal data in accordance with any privacy and data protection laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
   3. Sharing aggregated and anonymised data
      Aggregated and anonymised data are records which have been stripped of sufficient elements that your identity can no longer be identified, and which have been combined or manipulated to provide generalised, anonymous information. We endeavour to process and store your personal data on an aggregated and anonymised basis to the maximum extent possible.
      
      We may share aggregated and anonymised data with our Affiliates, Merchants, Partners or other third parties for research and statistical purposes in order for us to better understand customer needs, improve our products and services or conduct industry benchmarking. You will not be able to be identified from this information.
8. Direct Marketing
   
   
   1. If you have opted to receive direct marketing communications from us, we may use your personal data (including your contact information, online activities on the Channels and transaction history) to:
      
      
      1. send you the latest news, events, updates, promotions, offers, rewards, products or services offered by WIL and/or our Affiliates; and
      2. analyse your preferences and behaviour in order to gain insights about you, so that we can customise the contents and advertisements that we present to you via the Channels, our direct marketing communications or other communication means.
      (collectively, “Marketing Communications”)
      
      We may send you Marketing Communications and market research invitations by email, through your WIL Account or in-app notifications on your mobile device, when you access the Channels, or through online banner advertisements, social media feeds, push notifications, telephone or SMS.
      
      We cannot provide you with any Marketing Communications unless we have received your consent, and you can withdraw your consent without charge at any time. Please see the section on Your Rights below.
   2. Can Affiliates, Merchants and Partners send you marketing materials?
      We will not provide your personal data to our Affiliates, Merchants or Partners for them to send you marketing materials, unless you allow us to do so.
      
      We may, however, share your personal data including your name, WIL ID, email address, mobile number and direct marketing preference with Zurich for gain for their direct marketing purposes. We cannot do this unless we have received your consent via the App, and you can withdraw your consent without charge at any time.
      
      If any of our Affiliates, Merchants or Partners wish to directly send you any marketing materials regarding their own products or services, then they must obtain your separate consent for this.  We are not involved in any marketing done directly by them that is unrelated to WIL. However, we may send Marketing Communications to you on behalf of our Affiliates, Merchants and/or Partners, subject to your consent and in accordance with the Direct Marketing section above. If you agree to receive any marketing materials directly from the Affiliates, Merchants or Partners, please read their privacy policies carefully.
9. How We Secure Your Information
   We take the confidentiality of your information seriously. We take all practicable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification. All personal data we collected about you is stored on our secure servers located in Hong Kong. We comply with our security policies and standards when accessing or using your personal data and restrict access to only those persons who need to use it for the purposes specified in this Privacy Policy.
10. How Long We Will Keep Your Data
    We will keep your personal data only for so long as is necessary to fulfil the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once the purposes for which your personal data was collected have been fulfilled, we will either irreversibly anonymise or securely delete it on our servers.
    
    We may need to retain your personal data for a longer period where we need the information to comply with legal or regulatory requirements or where we may need it for our legitimate purposes, for example, to help us respond to queries or complaints, fighting fraud and cybercrime, responding to requests from the authorities, etc.
11. Your Rights
    
    
    1. Access and correction
       You have the right to access and correct your personal data held by us, at any time, by email at cs@gowil.com.hk. You can also go to “Settings” to update your personal information and preferences anytime you like.
    2. Opt-out of direct marketing
       At any time, you can ask us to stop using your personal data to send you Marketing Communications, or sharing your personal data to Zurich for their direct marketing purposes, or you can customise how you would like to receive Marketing Communications from us. You can exercise your rights to do this by:
       
       
       1. changing your “Subscription Channels” at “Settings”;
       2. following the unsubscribe instructions in the Marketing Communications we send to you;
       3. turn off the “Notification” setting on your mobile phone;
       4. “Contact Us”; or
       5. contact Zurich directly with respect to direct marketing activities conducted by Zurich.
       We will stop using your personal data for direct marketing purposes in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your WIL Account, and may display general marketing information not specific to you via online advertising banners on any of the Channels.
       
       We are not involved or responsible for any marketing materials sent directly by any third parties that are unrelated to WIL. If you would like to stop receiving any marketing materials from these third parties, please contact them directly.
12. Cookies Policy
    Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.
    
    We use cookies and other similar identification technologies such as web beacons and pixel tags on our Channels, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our Channels; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our Channels; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our Channels and the websites of our Affiliates, Merchants or Partners.
    
    You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.
13. Links
    Our Channels may contain links to other third-party websites and applications, including those of our Affiliates or Partners (“Third-Party Sites”). We do not own or control, and are not responsible for the privacy practices of those Third-Party Sites. We encourage you to remain alert if you follow any links to leave our Channels, and to review the privacy policies of those Third-Party Sites so that you are aware of how your personal data may be collected and used by such third parties.
14. Update of This Policy
    From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by email, and/or by posting a notice of these changes on any of our Channels.
15. How to Contact Us
    If you have any questions or comments concerning this Privacy Policy, you can contact us at cs@gowil.com.hk.