Statement of Policy
CRE Properties (Hong Kong) Limited (“CRE Properties”) respects the personal data privacy of all individuals and pledges to be in compliance with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong (“PDPO”) so that the privacy of your personal data is protected in accordance with the standard required by law. In doing so, we require all our staff and agents to comply with the PDPO in the same manner as the PDPO applies to CRE Properties as a whole and adhere to the strictest standards of security and confidentiality.
Statement of Practice
1. Kinds of personal data held
The following explains the types of records / personal data held by CRE Properties.
• name, email address, contact number, nature and information of the enquiry, and/or business information (e.g. company name);
• Records of devices that use to interact with our websites, which may include internet protocol addresses, device identifiers, web browser, and browsing information collected through cookies and other similar technologies; and
• Records collected from CRE Properties’s external / internal websites, which include but are not limited to records containing email addresses and personal details, preferences of web-users, location information (including IP addresses), time and duration of website visits and the pages visited.
2. Main purposes of collecting and keeping personal data
Personal data will only be used for the purposes stated at the time the data is collected, which broadly speaking, covers business or commercial, administrative, marketing and related activities that are consistent with CRE Properties’s objectives. However, specific purposes will vary depending on the nature of the personal data held. Examples of specific purposes are explained further below.
Personal data held in:
• Records of customers, suppliers / wholesalers, contractors and service providers are collected and kept for purposes including but are not limited to providing services, evaluating and maintaining business relationships, managing transactions, monitoring and improving the quality of performance, keeping MPIdit records, responding to enquiries, resolving problems, researching and developing products, marketing and promotion;
• Records of investors and business partners are collected and kept for purposes including but are not limited to providing services, responding to enquiries, understanding investors’ and business partners’ needs, compiling statistical data, facilitating access to information, evaluating and maintaining business relationships, business planning, monitoring and improving the quality of performance, marketing and promotion;
• Records collected from CRE Properties’s external / internal websites are collected and kept for purposes including but are not limited to handling various applications or enquiries submitted through CRE Properties’s external / internal websites, sending newsletters to subscribers registered through CRE Properties’s external website, responding to requests submitted through CRE Properties’s external / internal websites, facilitating website access and compiling statistics on website usage; and
• Other records are collected and kept for purposes which vary according to the nature of the record, including purposes such as facilitating administration or office functions, organizing and delivering activities, compiling, summarizing, aggregating and/or de-personalizing personal data in connection with research or statistical/analytical activities carried on by CRE Properties in furtherance of CRE Properties’s Business Objectives, conducting direct marketing activities (such as communicating information to individuals about CRE Properties’s services and products) in connection with furthering CRE Properties’s Business Objectives.
3. Collection of personal data
• General: When CRE Properties collects personal data from individuals, CRE Properties will provide them with a Personal Information Collection Statement (“PICS”) on or before the collection in an appropriate format and manner in compliance with the PDPO.
• Personal data of minors: When CRE Properties needs to collect personal data from minors, CRE Properties will seek the express consent from the parent or guardian of the minor before collecting the personal data.
• Personal data from CRE Properties’s external / internal websites: In order to provide web-users with a smooth browsing experience, we may need to use technical means (such as cookies) to collect information from web-users when they visit CRE Properties’s external / internal websites. If you are given the option whether or not to accept cookies and you do not accept, you may not be able to take full advantage of our external / internal websites.
• Direct marketing: Where it is intended that the personal data collected will be used for direct marketing purposes, CRE Properties will provide the individual with all the necessary information required to be given by law such as information about the direct marketing means and the classes of marketing subjects before making the collection. CRE Properties will not use an individual’s personal data in direct marketing unless it has obtained the express consent of the individual concerned and such consent has not been withdrawn.
4. Duration of retention of personal data
CRE Properties will only hold personal data for as long as it is necessary to fulfill the purpose or a directly related purpose for which they are collected.
5. Disclosure of personal data
CRE Properties will take all practicable steps to keep the personal data you have provided confidential. However, CRE Properties may need to disclose personal data collected by it to such third-parties to facilitate the purpose for which the personal data was collected. In general, the parties to which we may transfer / assign personal data to any agent, contractor or third-party service provider engaged by CRE Properties to provide services to or on behalf of CRE Properties (e.g. bankers, IT service providers, marketing companies) and any person to whom CRE Properties is under an obligation to make disclosure under any requirements of any law or for the purposes of any guidelines or codes of practice with which CRE Properties is expected to comply. We may also transfer personal data internally within CRE Properties or to such parent or subsidiary companies of CRE Properties or their respective associates or subsidiaries (on a need-to-know basis) to facilitate the purpose for which the personal data was collected or a directly related purpose.
6. Security of personal data
CRE Properties will take appropriate steps to protect the personal data held by it against unauthorized or accidental access use, loss, processing, erasure, transmission, modification or disclosure. When CRE Properties needs to disclose personal data to outside third-parties, CRE Properties will take appropriate steps to protect the privacy of the personal data to be disclosed (for example, requiring our service providers to keep confidential any personal data with which it comes into contact).
7. Personal data access and correction
Individuals have the right to request access to and to correct their personal data held by CRE Properties. Individuals who wish to access their personal data should make their request by completing the prescribed Data Access Request Form (https://www.pcpd.org.hk/english/publications/files/Dforme.pdf) and send the completed form Personal Data (Privacy) Officer – Marketing by post: 39/F, China Resources Building, 26 Harbour Road, Wanchai, Hong Kong or email to email@example.com.
Depending on the nature and extent, a reasonable fee may be charged for requests for data access. There is no prescribed form for making a request to correct personal data held by MPI; individuals may submit their requests in the above manner.
This PPS has been translated into Chinese. If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.