Personal Information Collection Statement

Sun Hung Kai Real Estate (Sales and Leasing) Agency Limited ("SHK", "we", "us" or "our"), takes the privacy and protection of your personal information seriously. We collect personal information from you that is necessary or helpful for us to either provide you with the product or service you have requested or to comply with statutory or contractual requirements. We respect personal information and are committed to implementing and complying with the data protection principles and the relevant provisions of Hong Kong’s Personal Data (Privacy) Ordinance (“PDPO”).

This Personal Information Collection Statement (“PICS”) applies to personal information collected on the Resident Information Form as part of residential leasing or service apartment services provided.

This PICS should be read in conjunction with our Privacy Policy linked https://www.shkp.com/en-US/customer-data-privacy-policy.

In this PICS, we may refer to information about you as your "personal data" or “personal information”. We may also sometimes collectively refer to handling, collecting, protecting, and storing your personal information as "processing" such personal information.

The governing version of this PICS is the English version and shall prevail when there are inconsistencies between the English version and the Chinese version.  

We typically collect or obtain personal information because you volunteer it to us in the Resident Information Form that provided a copy or link to this PICS and our Privacy Policy, or it was obtained as part of the related Tenancy Agreement which supports the residential leasing or service apartment services provided. We also usually collect or obtain personal information from you because we generate and compile, observe or infer that information about you from the way you interact with us or others.

The personal information that we collect or obtain typically includes, but not limited to:

(a) your personal details (e.g. salutation title, given name and surname, HKID or passport number, HK permanent residency status, nationality, birthday, signature, etc.);

(b) the personal details of other accompanying residents (e.g. salutation title, given name and surname, HKID or passport number, HK permanent residency status, birthday, etc.) (if applicable);

(c) your relationship(s) with the other accompanying residents (e.g. spouse, children and other household members, etc.);

(d) your contact details (e.g. email address, mobile number, current residential address, etc.);

(e) the contact details of other accompanying residents (e.g. email address, mobile number, correspondence address, etc.) (if applicable);

(f) your employment details (e.g. company name, job position, work email address, office number, office address, income range, etc.);

(b) the personal details of other accompanying residents (e.g. salutation title, given name and surname, HKID or passport number, HK permanent residency status, birthday, etc.) (if applicable);

(g) the employment details of other accompanying residents (e.g. company name, job position, work email address, office number, office address, income range, school name for children and students, etc.) (if applicable);

(h) your documentary evidences for validation (e.g. HKID or passport copy for identity verification, etc.);

(i) your leasing or long stay details and intentions including relevant tenancy agreement details (e.g. leasing/long-stay unit, date and duration of stay/contract, leasing price, etc.) (if applicable);

(j) your bank details of deposit refund information (e.g. address to be refunded to, information of bank account to be refunded to, etc.);

(k) additional details that facilitate your lease or long-stay(e.g. number of vehicles, vehicle registration number, number of pets, broadband services, housekeeping services, etc.) (if applicable);

(l) the personal details of an alternative contact person and/or emergency contact (e.g. name, relationship with you, contact phone numbers, email address, etc.) (if applicable);

(m) the details you may provide when you complete our voluntary questionnaire in the application form (e.g. hobbies, preferred activities, how you heard about us, etc.);

(n) your personal information whenever we communicate with you (e.g. email content, etc.) and

(o) the details you may provide when you complete our voluntary surveys and questionnaires in relation to the purposes noted below that we may send you from time to time (e.g. your demographic information and feedback, etc).

We will only collect the data necessary for us to fulfil the purposes outlined in this PICS. 

Note that if you are unable to supply your personal information denoted by the mandatory field asterisk “*” symbol in our application form, we may be unable to process your application or provide you with products and services.  Providing us with other optional personal information will enable us to provide you with better experience and tailored products, services or marketing promotions.

We may collect, use and retain your personal information for the following purposes:

(a) to process your leasing or long-stay registration herein;

(b) to create account(s) for your and maintain such account(s);

(c) to communicate with you in respect of matters related to or arising from this registration and thereafter on all administrative matters;

(d) to provide customer services (e.g. respond to enquiries, investigate complaints, etc.); 

(e) to provide information related to SHK including the activities, products, facilities services and other privileges, benefits and other advantages from time to time offered to you and arranging the same to be provided;

(f) to enhance the activities, products, facilities services and other privileges, benefits and other advantages from time to time offered by SHK to you; 

(g) to facilitate communications between you and SHK and encourage feedback from you on your needs and expectations of activities, facilities, services and/or products offered by SHK;

(h) to analyse or research your consumer behaviours, enabling us to better understand our customers so that we can provide products and services that have been customised based on your user experiences (e.g. preference on leisure activities, etc.);

(i) to carry out market and customer analysis using data analytic tools in order to generate customer insights, segmentations, statistical reports and/or marketing insights which we may use ourselves or share with any subsidiaries and/or associated companies of Sun Hung Kai Properties Limited together with Sun Hung Kai Properties Limited (“SHK Group”) for their own use to determine whether you may be interested in new products or services, or to customise the content and types of offers, products, services, incentives and discounts that we present to you. These reports and/or insights are in aggregated form or will be anonymised, secured, and will not contain information that identifies you;

(j) to evaluate and improve our business operations and management (including IT resources and infrastructure management, business continuity and risk management, audit, training, statistical analysis for business or security purposes, and any other supporting administrative services and similar purposes);

(k) with your consent, we may also use your personal information to send you marketing communications (refer to the “Direct Marketing” section below for further details);

(l) to enable us or our affiliates of such personal information to provide electronic services verification of your identity; and

(m) to meet any requirements to disclose under any applicable regulation or law (e.g. fraud and crime prevention, etc.).

Some of the purposes above are necessary to allow us to provide products and services, in alignment with your requests, to you and to enable us to comply with applicable laws and regulations. 

Cookies are small text files that are stored on your browser or device by websites, applications, online media, and advertisements when you visit it. We use cookies across our websites in order to improve their performance and enhance your online experience. 

We use cookies on our Website to identify and verify users, to improve our products and services performance, to enhance user experience, to optimise the operation of our Website, and to analyse traffic on our Website. Examples of collected data in cookies include session details to enable you to use essential functions on our website like maintaining login details. Google Analytics are used to recognize repeat visitors to our websites in order to enable us to better understand how our users browse to and through our websites, the time they spend and how often they visit our websites, relying on which we can improve our websites. Font size cookies are used to provide proper appearance of characters when you browse our websites. 

You can exercise your right to choose whether 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. 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.

We will not collect any personal data from you when the cookies are being used.

To protect your privacy, all personal information held by us will be kept confidential. However, there may be circumstances where we share data (which may include your personal data) with third parties who may be located overseas. 

To protect your privacy, we are committed to only sharing data with third parties which has either been aggregated, anonymised or does not contain your name or contact details per the purpose of sharing. By agreeing to this PICS, you agree to allow us to share and use your personal data for the outlined purposes. We are committed to protect your personal data and will take reasonable steps to safeguard it in accordance with our Privacy Policy, this PICS and all applicable laws.

We may disclose and share details about you within or outside Hong Kong to:

(a) All members of SHK Group;

(b) Our ultimate parent company’s data processor company(ies), wholly owned by Sun Hung Kai Properties Limited, for the purposes of customer data analysis and generation of customer insights, in line with the outlined purposes and use of collected data. Results may be shared with other SHK Group members on an aggregated, anonymised and secured basis, where you as an individual will not be identifiable;

(c) Third parties that provide services to us (e.g. market research companies, printing, mailing, public relationship service providers, IT systems providers, hosting providers, payroll providers, recruitment, background check providers, IT support providers, customer service providers, debt collection service providers, online platforms for downloading our mobile software applications, etc.) all of which are under a duty of confidentiality to us;

(d) professional advisors that provide services to us (e.g. lawyers, accountants, financial advisors, insurers, etc.); and

(e) local or overseas government and regulatory authorities as required by laws and regulations.

We do not sell or trade your personal information with any third parties and will only be used, disclosed, or transferred for purposes for which it was collected and is allowed under the PDPO. 

In addition, we intend to use your personal information in direct marketing with your consent.  

We would like to send you direct marketing communications:

• on our products and services in connection with the latest news, events, updates, promotions, offers, products, services and rewards in relation to SHK’s residential leasing, serviced apartments services, hospitality or travel promotions, food & beverage promotions, loyalty programs, rewards programs, wellbeing promotions, surveys by e-mail, WhatsApp or telephone on our service quality, Hong Kong and worldwide properties including residential, offices, commercial and industrial buildings, shops, hotels, shopping malls and the events therein, theme park and observatory deck, property management, construction, insurance, financial services, telecommunication, information technology, transport infrastructure operations and management, port business, transport and logistics, waste management, educational, recruitment, reward/loyalty/privilege programmes, corporate social responsibility activities, charitable and non-profitable causes, retail and consumer products and services (including general consumer goods, food and beverages, books and stationery, children goods, fashion and accessories, optical products, watches, jewellery, luxurious goods, personal care, health and beauty products and services, home furnishing and appliances, household services and products, florists, sports gear and products, electronic products and appliances, groceries stores, convenient stores, supermarkets, department stores, cinemas and theatres, cultural and entertainment facilities and activities, and car parking facilities, etc.;
• relating to the latest news, events, updates, promotions, offers, products, services and rewards offered by our business partners and affiliates of SHK Group, which relate to Hong Kong and worldwide properties, shops, hotels, shopping malls and the events therein, property management, financial services, telecommunication, information technology, transport infrastructure operations and management, transport and logistics, waste management, recruitment, reward/ loyalty/ privilege programmes, charitable and non-profitable causes, etc.

We also intend to share your personal information with all members of SHK Group for their use in direct marketing purposes as outlined above. We may not share your personal information to other parties for their use in direct marketing unless we have received your consent. 

We will not disclose your personal information to any third parties (other than those listed in this PICS) for direct marketing purposes without your consent. 

If you do not agree to such use of your personal information, please indicate your objection in the acknowledgment form. 

If you do not want to continue receiving any marketing materials from us, you can exercise your opt-out right by utilising the “unsubscribe” function or notifying us in writing to our Data Protection Officer as per the “Contact Us” section below.

We have put in place measures to keep your personal information secure, accurate, and up-to-date. These measures include:

• education and training to relevant staff to ensure they are aware of our privacy obligations when handling personal information;
• controls to restrict access to personal information on a need-to-know basis;
• technological security measures, including firewalls, encryption, and anti-virus software; and
• physical security measures, such as staff security passes to access our premises.

Whilst there are always risks associated with the transmission of data over the internet (including by e-mail), we take proactive steps to manage these risks and work with business partners who share our view on the importance of protecting your data. We endeavour to protect personal information, but we cannot guarantee the security of data transmitted to us or by us.

We will hold your personal information on our systems for no longer than is necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory or internal policy requirements.  The information will either be irreversibly anonymised or securely disposed when it is no longer needed.

You have various rights concerning your personal information. In particular, you have a right to: 

(a) voluntarily terminate services provided to you by SHK and the related data collection and processing of your personal information; 

(b) request access to your personal information from time to time;

(c) request an update of the personal information we hold about you, or correct such personal information that you think is incorrect or incomplete; and

(d) withdraw consent to our processing of your personal information (to the extent such processing is based on consent).

If you have any questions about our Privacy Policy, this PICS, make a complaint in relation to your privacy, or would like to exercise your rights as noted above, please contact our Data Protection Officer at info@townplace.com.hk or write to the following address: Sun Hung Kai Real Estate (Sales and Leasing) Agency Limited, TOWNPLACE, 3rd Floor, Sun Hung Kai Centre, 30 Harbour Road, Wanchai, Hong Kong.

We strive to respond to your questions or complaints within 40 days of receiving the communication. In accordance with the terms of the PDPO, we have the right to charge a reasonable fee for processing a data access request. We will clearly inform you what fee, if any, will be charged as soon as possible and in any event not later than 40 days after receiving your request.

This PICS was last updated on Nov 2022.

It may be subject to amendments. Any future changes or additions to the processing of personal information as described in this PICS affecting you will be communicated to you through an appropriate channel.