Privacy policy

The Aisle Privacy Policy

Effective Date: 25 August, 2018

The Aisle (“we, us, or our”) respects your concerns about privacy and values the relationship we have with you. We are committed to maintaining your trust by protecting your Personal Information. This Privacy Policy (“Policy”) describes the types of Personal Information we collect, how we use and disclose your Personal Information in connection with the use of our member network or other service that refers to or links to this Policy, as well as any offline products, facilities, events and services (collectively our “Services”). We also describe the measures we take to protect the security of Personal Information and how to contact us about our privacy practices.

Before you use our Services, please read this Policy in its entirety, which helps you make informed decisions about your relationship with us.

  1. INTRODUCTION “Co-working Office Space” means the room number(s) and/or workspace location(s) specified in the Membership Agreement.

Personal Information. “Personal Information” is data that relates to you and can — either on its own or in combination with other information — identify you as an individual. Personal Information does not include data that has been aggregated or made anonymous such that you can no longer be identified using any means reasonably available to us.

Our Services. The Services referenced in this Policy include the Services provided by The Aisle as defined and specified in the Membership Agreement or communicated to you by The Aisle.

References to “you.” In this Policy, “you” means anyone who uses our Services.

Authoritative Version. When the text of this Policy is available in multiple languages, the English version is the authoritative version, except where prohibited by applicable law.


The Personal Information that we collect and how we use that information depend on your relationship with us and the requirements of applicable law as described below.

We collect information:

If you opt in to certain features, we obtain geo-location data, photos and information about your contacts.


We request different types of Personal Information from you, depending on the Services you use and your relationship with us. We may collect the following categories of information, depending on the Services that you use:


ANONYMOUS AND AGGREGATED INFORMATION We also collect and/or generate anonymised and aggregated information from your use of the Services. We use anonymised and aggregated information in various ways, including to measure your interest in and use of portions or features of the Services. Anonymised or aggregated information is not Personal Information.

  1. USE OF PERSONAL INFORMATION How we use your Personal Information depends on your relationship with us. In general, we use your Personal Information to:

If you provide us with your Personal Information, we intend to use it for direct marketing purpose to offer or advertise the availability of our goods and/or services. However, we may not use your Personal Information for such purpose unless we have received your consent to our intended use.

If you do not wish us to use your personal information in direct marketing, you may opt out of our direct marketing at any time by send us an email to our Administrative Officer at We must, without charge to you, cease to use your personal information in direct marketing if you so require.

We will use the personal information supplied by you for direct marketing only in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (“Ordinance”). Our direct marketing materials may come in several forms, including but not limited to marketing emails and text messages.

Remember that in certain circumstances — in particular where we use Personal Information on the basis of our legitimate interests or your consent — and where permitted by applicable law, you have the right to object to our uses of your Personal Information.

  1. SHARING OF PERSONAL INFORMATION We disclose your Personal Information in limited circumstances to our affiliates, our service providers and advertisers, and other end users, in order to provide our Services and to improve ways of working in our Co-working Office Space. We do this for the purposes outlined above. Where required by applicable law, we will only share your Personal Information with particular third parties with your consent.

We share Personal Information in this way either to comply with legal obligations to which we are subject, or to meet our legitimate interests in protecting our business, including from fraud and legal claims.

4.1 THIRD PARTIES THAT PROVIDE CONTENT OR FUNCTIONALITY ON OUR SERVICES We partner with certain third parties to collect, analyse, and use some of the Personal Information described in this Policy. For example:


We value your rights to your data. In accordance with applicable law, you may have the right to (i) request confirmation of whether we store, use or share any of your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us; (iv) restrict our uses of your Personal Information or, as described above, object to those uses; (v) seek correction of inaccurate, untrue or incomplete Personal Information; or (vi) request erasure of Personal Information held about you by The Aisle, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please send us an email to our Administrative Officer at

We will process such requests in accordance with the Personal Data (Privacy) Ordinance (Cap. 486). To protect your privacy, We will take steps to verify your identity before granting access, or making any changes to your Personal Information.

6.OPT-OUT You have the right to opt-out of certain uses and disclosures of your Personal Information, as set out in this Policy, and in specific circumstances, for example related to direct marketing.

6.1 GENERAL Where you have consented to our use of “sensitive” Personal Information (e.g., Personal Information relating to your health, religious or philosophical beliefs, or biometric information which is used to uniquely identify you) (“Sensitive Personal Information”), you are able to withdraw that consent at any time.

Prior to disclosing Sensitive Personal Information to a third party or processing Sensitive Personal Information for a purpose other than its original purpose or the purpose authorised subsequently by the Data Subject, we will endeavor to obtain your explicit consent (opt-in). Where your consent for the processing of Personal Information is otherwise required by law or contract, we will comply with the law or contract.


6.3 COMPLIANCE WITH THE DIGITAL ADVERTISING ALLIANCE Should The Aisle engage in interest-based advertising, it will endeavor to comply with the cross-industry Self-Regulatory Program for Online Behavioral Advertising as managed by the Digital Advertising Alliance (DAA) (, as applicable. As part of this service, The Aisle’s online advertisements may sometimes be delivered with icons that help Individuals understand how their data are being used and provide options to restrict that use. To opt-out of internet-based advertising by all DAA-participating companies, please visit

  1. INTERNATIONAL TRANSFERS We may transfer the Personal Information we collect about you to countries other than the country in which the information was originally collected. Those countries may have privacy protections less stringent than the country or jurisdiction in which you initially provided your Personal Information. In accordance with applicable law, we implement measures, such as standard data protection clauses, to ensure that any transferred Personal Information remains protected and secure. You can obtain further information about these measures by sending an email to our Administrative Officer at

  2. RETENTION The Aisle will retain your Personal Information for as long as you have a relationship with us, and for a period after your relationship with us has ended. When determining how long this retention period will last, we take into account the length of time Personal Information is required to:

  1. INFORMATION SECURITY The security of all Personal Information provided to The Aisle is important to us. The Aisle takes reasonable steps endeavoring to use appropriate technical or organisational measures to protect your Personal Information, including against unauthorised or unlawful processing and accidental loss, destruction or damage. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while The Aisle strives to protect your Personal Information, we cannot ensure or warrant the security of any information that you transmit to The Aisle, and you do so at your own risk. As such, we ask that you help us be safer together by implementing your own security controls, such as a strong password, not sharing your credentials or badge with others, logging out when you leave your desk, and other security best practices.

  2. AUTOMATED PROCESSING We do not currently use your Personal Information in such a way that automated decisions are made about you without any human input.

In the future, we may use automated processes to help us determine your eligibility for new services, alternate space, or other business-related opportunities. In such cases, if and as applicable, and to the extent required by applicable law, we will endeavor to implement suitable safeguards, including, for example, an opportunity for you to request human intervention, express your point of view, contest any decisions made, and request that we restrict the use of your Personal Information for the purposes of these automated decisions.

  1. OTHER RIGHTS AND IMPORTANT INFORMATION 11.1 CCTV Our Premises have CCTV installed to meet our legitimate business interests in protecting the safety of our employees, members, and guests and their property, as well as to improve our products and services, and to analyse how users navigate and use our spaces. These recordings may be accessed by The Aisle and its Members with a need to know. These recordings may be shared with competent authorities in accordance with applicable laws, if required. The recordings are retained for a limited period of time, but may be kept longer for the investigation of an incident or when competent authorities request us to retain them.

11.2 COLLECTION OF INFORMATION FROM CHILDREN Generally our Services are not directed to children under the age of 18, and we do not knowingly collect Personal Information from anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without parental consent, he or she should contact us by sending an email to our Administrative Officer at If we become aware that a child under 18 years old has provided us with Personal Information, we will delete such information from our files.

11.3 LINKS We display advertisements and other content from third parties or partners that links to third party websites that we do not own or operate. We provide links to these third-party sites as a convenience to you. They are not intended as an endorsement of or referral to the linked services. The linked services are subject to their separate and independent privacy statements, notices, and terms. We cannot control or be held responsible for third parties’ privacy practices and content. Please read their privacy policies to find out how they collect and process your Personal Information prior to submitting any Personal Information. The collection, use, and disclosure of your Personal Information will be subject to the privacy policies of the third party and not this Policy. We are not responsible for the data collection, privacy, and information sharing policies and procedures or content of such third-party websites.

11.4 CHANGES TO THIS POLICY IN THE FUTURE Any information that is collected via the Services is covered by this Policy in effect at the time such information is collected. We reserve the right to change, modify, add, or remove portions of this Policy at any time and at our sole discretion. If we make any material changes to this Policy, we will notify you of those changes by posting them on the member network or by sending you an email or other notification, as required by applicable law, and we will update the “Effective Date” below to indicate when those changes will become effective.

We encourage you to review this Policy periodically to remain informed of how we use and protect your information, and to be aware of any policy changes. Your continued relationship with us after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by The Aisle.


If you have any questions or comments regarding our Policy, please contact us at:

The Aisle Limited 6/F, Shui Hong Industrial Building Nos. 543/549 Castle Peak Road, Hong Kong Email:

We will address your concerns and attempt to resolve any privacy issues in a timely manner. Sensitive Information. Because email communications are not always secure, please do not include credit card or other Sensitive Personal Information (e.g., racial or ethnic origin, religion, health, or the like) in your emails to us.