© 2019 Swire Properties Limited All rights reserved
SWIRE PROPERTIES LIMITED
Data Privacy and Security Policy
This policy (“Policy”) sets out how Swire Properties Limited and its subsidiaries (collectively, “SPL”, “we”, “our” or “us”) collect, use, store and handle personal data.
A. Commitment to Personal Data Protection
We are committed to protecting the privacy of the personal data (“Personal Data”) we hold. To ensure that you can make informed decisions and feel confident about providing your Personal Data to us, we outline in this Policy our practices and the choices you have concerning the collection and use of your Personal Data.
B. The Personal Data We Collect
The types of Personal Data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of Personal Data may include (without limitation) the following:
Certain Personal Data (e.g. relating to your personal information and contact information) are required for specific services and if you fail to supply such Personal Data as requested from each specific service, we may not be able to deliver you the services or products. By providing your Personal Data to us, you acknowledge that such provision is fair and reasonable in the circumstances.
C. Purposes for which your Personal Data are Collected and Used
The purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:
We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes (or purposes as specified in a personal information collection statement when we collect your Personal Data) without your prior consent.
D. Disclosure and Transfer of Personal Data
To facilitate the purposes mentioned under “C. Purposes for which your Personal Data are Collected and Used”, we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Hong Kong, and your Personal Data may be transferred within or outside Hong Kong. These third parties may include the following:
The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above.
E. Direct Marketing
If we intend to use your Personal Data (including your name and contact details) collected from you for direct marketing purposes (e.g. to send you marketing communications about news, offers or promotions in relation to the Services or Activities of Swire Properties Group or its Merchants), we will first obtain your consent (or an indication of no objection) before doing so.
If we intend to provide your Personal Data (including your name and contact details) collected from you to third parties for their use in direct marketing, we will first obtain your consent (or an indication of no objection) before doing so.
If you agree to receive marketing communications but do not wish to receive them in the future, you may opt out of receiving them at any time, free of charge, by the following applicable means:
We may issue service-related announcements to you when necessary (e.g. when we suspend a service due to system maintenance). You may not be able to opt out of these announcements which are service-related and not promotional in nature.
F. Our Commitment to Children's Privacy
Protecting the privacy of children is our primary concern. Hence, we will not knowingly collect or maintain Personal Data in our database from persons who are under 16 years of age without prior consent from a parent or guardian.
Cookies contain information about you and your preferences. For example, if you inquire about rates and availability, the site might create a cookie that contains the details you entered. Or it might only contain a record of which pages within the site you visited, to help the site customise the view for you the next time you visit.
Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.
We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your Personal Data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.
If you use the WiFi available at our properties, we may collect your location data (if you have consented to this on your device). We may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information we receive from third parties to provide you with better service and, where you have consented to receive direct marketing, we may provide you with targeted advertisements, content, features, deals and offers in relation to the classes of marketing subject as set out in the relevant personal information collection statement when your Personal Data is being collected.
If you interact with us on social media platforms (for example if you "Like" our Facebook Page or post on our timeline), we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform's rules but we are not responsible for how the platform operators collect and handle your Personal Data. We are not responsible for what third parties post on our social media accounts.
H. Data Retention
Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above after which it will be destroyed.
I. Data Security
In order to ensure the correct use and to maintain the accuracy of the Personal Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Personal Data, we have implemented various internal policies (including physical, electronic and management measures) to safeguard and secure the Personal Data we collect.
For example, where we collect Personal Data online, we use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Personal Data.
Our websites have firewalls in place, which should protect the Personal Data collected from you against unauthorised or accidental access. However, complete confidentiality and security is not yet possible over the internet, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorised access to your password and credit card details. Make sure you sign out from your account when finished particularly when using a shared computer.
J. Other Websites
In order to anticipate your needs, our websites may contain links to third party sites that are operated under different privacy practices.
All such websites are independent from our websites. We have no control over the contents of such other websites or their privacy policies or compliance with the law. You should therefore be fully aware the provision of such links does not constitute an endorsement, approval, or any form of association by or with Swire Properties Group. We have no control over Personal Data that is submitted to these other websites. You should remain alert when you leave our websites, and read the privacy statements of other websites.
K. Your Rights and Contacting Us
You are entitled to access or correct your Personal Data held by us. You may also:-
If you would like to exercise any of the above rights or obtain a copy of any of your Personal Data, or if you believe that any of your Personal Data which we collect and maintain is inaccurate or would like to request for information regarding our policies and practices and the kinds of Personal Data held by us, please contact us at the following address:
Data Protection Officer
Swire Properties Limited
64/F, One Island East, Taikoo Place,
18 Westlands Road, Quarry Bay
We will endeavour to use appropriate technical means to ensure that you can access, update and correct your Personal Data. In accessing, updating, correcting and/or deleting your Personal Data, we may ask you to authenticate your identity in order to protect the safety of your Personal Data.
To the extent permitted by relevant laws and regulations, we reserve the right to refuse unreasonable requests (for example, requests which infringe the privacy of others). To the extent permitted by relevant laws and regulations, we reserve the right to charge a reasonable fee for the cost of processing any request set out above.
This Policy may be amended from time to time. You may access and obtain a copy of this Policy, as amended from time to time, at www.swireproperties.com so that you are always informed of the way we collect and use Personal Data.
This Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.