We are committed to protecting your privacy and the confidentiality of your personal data that we collect, use, handle, store and process in connection with the services, products, events, facilities, promotions or marketing or other activities we offer to clients and individuals using our websites. This Statement describes how we collect, use, handle, store, process and protect your personal data, which is any information that is capable of identifying an individual. When an individual provides personal data to us, such individual is agreeing to be governed by this Statement.
Categories of Personal Data which We Collect
The categories of personal data we may collect and use about you will vary depending on your level of engagement with us. Initially, we may collect your name, mailing address, contact numbers and email address, and/or information about the nature of your enquiry. We may also automatically collect information about the devices you use to interact with our websites. The information we automatically collect may include internet protocol addresses, device identifiers, web browser, and browsing information collected through cookies and other similar technologies on our website. The information automatically collected will be associated with any personal data you have provided.
You may provide us voluntarily with information in order to use, or participate in, certain features of our services, such as registering for an account; making a purchase; applying for a job; submitting a survey response; requesting support or assistance; signing up for or registering an activity or a loyalty program; making a donation etc…
Certain personal data are required for specific services or products, and if you fail to supply such personal data as requested for the specific service or product, we may not be able to deliver you the service or product.
Our services are not designed for or targeted at, children younger than 16 years old, and we do not intentionally collect or maintain personal data about anyone under the age of 16. If you are under 16 years old, please ask your parent or guardian to interact with us on your behalf.
The Purpose and Basis of Our Use of Your Personal Data
We may collect personal data directly from you when you:
- visit our websites and/or submit paper or online forms and/or register for an account;
- engage or enquire about the services, products, events, facilities, promotions or marketing or other activities offered by us and/or third parties;
- call us, email us or contact us via social media;
- complete questionnaires or surveys;
- provide feedback;
- make a complaint; or
- enter any transaction with us or request information in relation to entering a transaction.
We may also indirectly obtain personal data of you from third parties when you:
- visit a third-party site that links to our website or an estate agent website and request information about one of our products, services or property developments;
- engage with other property, investment or finance companies that we have arrangements with;
- engage with solicitors, financial advisers, surveyors, and estate agents involved in your search for, and leasing or purchase of, properties or products or services from us; or
- apply for a loan with us where information is collected from credit reference and anti-fraud agencies.
The personal data we collect may be used where we have your specific consent to do so or another legally permitted reason applies, such as having a legitimate business interest in processing such information, or the processing is necessary to comply with our legal obligations. Our use of your personal data depends on how and where you interact with us. In some situations, the collection of personal data may be required for the operation of websites or the provision of certain membership, services, products, events, promotions or marketing or other activities. If we are marketing to you, we will also do so with your consent or where otherwise permitted by law.
Link to Other Websites
Please note also that even if you do not choose to “accept cookies”, certain information will still be automatically collected and stored from your device due to your interaction with our website.
People Who May Process Your Personal Data
Your personal data may be received and processed by the following parties located within or outside Hong Kong or United Kingdom, as the case may be:
- our own employees for the management and administration of our business;
- third-party data processors who provide support services to us and who will process your personal data on our behalf. Such third parties may include IT service providers as well as marketing companies that we use;
- independent financial advisors, estate agents and solicitors that help you with your dealings or leasing or purchase of our products or services;
- third-party service providers who assist us in providing or performing services, functions, and activities on our behalf to support our interactions with you;
- any prospective buyer or lender, as the case may be, being part of certain due diligence processes in the event of a re-organization, merger, sale, joint venture, acquisition, or other transfer or disposition of all or any part of our business or assets; and/or
- parties that we have a legal obligation to disclose information to, for example regulators and law enforcement agencies.
We maintain processes designed to ensure that any processing of personal data by third-party service providers is consistent with this Statement to protect the confidentiality, availability, and integrity of your personal data.
Retaining Your Personal Data
We retain personal data if it is necessary to support our interaction with you. We may also retain personal data for longer than the duration of the business relationship for legal and/or regulatory reasons, or for analysis or historical record-keeping. For requests for access, corrections, or deletion, please refer to the “Your Rights” section of this Statement.
Where you agree (or where otherwise permitted by law), we will send you information about any new services, products, events, facilities, promotions or marketing or other activities which may be of interest to you, according to available methods of communication. Even after you agree and ask us to send you information, you can always unsubscribe or withdraw your consent at any time, and we shall stop sending you marketing materials.
Automated Decision Making and Profiling
We may, in some cases, use automated decision making and/or profiling, if it is authorized by legislation, if you have provided an explicit consent or if it is necessary for the performance of a contract. You can always request a manual decision making and/or profiling process instead, express your opinion or contest a decision and/or profiling based solely on automated processing and/or profiling, if such a decision would produce legal effects or otherwise similarly significantly affect you.
When using automated decision-making we will provide you with further information about the logic involved, as well as the significance and the envisaged consequences to you.
We endeavour to keep your personal data secure. We have set up technical and organizational systems and processes to prevent unauthorized access or disclosure of your personal data. We also check that any third parties that we deal with maintain reasonable measures to safeguard the security of the personal data they process.
You have certain rights regarding how we use and keep your personal data. These include:
- A right to be informed whether and how we process your data.
- In certain circumstances, you may also request to withdraw your consent previously given to us or object to the use or processing of your personal data. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
- Where permitted by law, you may have the right to request access to your personal data for the purposes of reviewing, modifying, or requesting deletion of the data.
- You may have a right to request a copy of your personal data and to have any inaccuracies in that data corrected.
- You may unsubscribe from mailing lists or any paper or online registration.
You can exercise your rights by contacting us using the details below. However, we will require you to produce satisfactory proof of your identity and we may charge you a reasonable fee for the administrative costs in certain circumstances. If a fee is necessary, we will inform you of the fee before processing your request.