General Statement of Policy
- This Statement is made by HONG KONG REITS ASSOCIATION LIMITED (“HKREITA”, “we”, “our” or “us”) in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region (“PDPO”). We are committed to ensuring that your personal data are handled in accordance with the provisions of the PDPO. We collect and use your personal data to provide you with better services. When we collect personal data from individuals, we will provide them with a Personal Information Collection Statement ("PICS") on or before the collection in an appropriate format and manner.
- We collect adequate, but not excessive, personal data by lawful and fair means only for lawful purposes related to our business and activities.
- We take all reasonably practicable steps to ensure that personal data collected or retained are accurate, having regard to the purposes for which they are to be used.
- We take all reasonably practicable steps to ensure that the personal data are not kept longer than is necessary for the purposes for which they are to be used.
- We use the personal data collected only for the purposes or directly related purposes for which the data were to be used at the time of collection, unless the individual concerned has given express consent for a change of use or such use is permitted by law.
- We take all reasonably practicable steps to ensure that personal data are protected against unauthorised or accidental access, processing, erasure or other use.
- We take all reasonably practicable steps to ensure that a person can be informed of the kinds of personal data that we hold and the purposes for which the data are to be used.
- We permit persons to request access to and/or correction of personal data held by us which they are the data subjects. We process any such access/correction requests in a manner permitted or required by law.
- All our staff are required to observe our security and confidentiality obligations.
Collection - Why We Collect Your Data
- From time to time, we may collect your personal data to provide our services to you and in an effort to improve your user experience of our services. You are not obliged to provide your personal data to us but if you do not, we may not be able to provide you with some of the information, materials, services of HKREITA and you may not be entitled to join some or all of our events and/or activities.
- We will indicate in the relevant forms or applications if the required personal data are obligatory or voluntary. If the supply of the personal data is obligatory, you MUST provide your personal data to us if you want us to provide the information, materials, services or to join our events and/or activities for which you are applying. If the supply of personal data is voluntary, you are not obliged to provide us with such personal data.
- If you are under the age of 18, you must seek your parent or guardian’s consent before providing any personal data to us.
Use - How Your Data May Be Used
- Personal data held by us will be used:
(a) to facilitate the daily administration and operation of our business and improvement to our services as an association for members (including the staff and/or representatives of corporate and associate members) (collectively “Service Users”);
(b) for processing membership applications, subscriptions or renewals and the record thereof, booking of services, events and activities, and billings, keeping record of guests’ visits and handling media and general enquiries;
(c) for identity verification, matching and/or records and for maintaining communication with our Service Users and updating of their profiles and for members’ communications and organisation of events and activities;
(d) for handling enquiries and feedback for better services to Service Users;
(e) for internal statistical and analysis and preparation of reports;
(f) for keeping Service Users updated with news, activities and events and the latest developments of HKREITA;
(g) for making disclosure so required by law, regulation or court order of any jurisdiction and / or so requested by the government, regulatory or law enforcement authority or administrative organisation within or outside Hong Kong Special Administration Region;
(h) for establishing legal claims or defences; obtaining legal advice; and / or exercising, defending and / or protecting the rights of properties of HKREITA, HKREITA’s affiliates and contractors, agents and third party service providers, including identifying contracting or bringing legal action against any person who may be interfering with such rights or properties (whether intentionally or otherwise and / or whether any other third party may be harmed or property of any third party may be damaged by such interference).
Personal Data Security
- We strive at all times to ensure that your personal data will be protected against unauthorised or accidental access, processing, erasure or other use. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
Your personal data will be kept in the office of HKREITA, or by agent, contractors or third party service providers engaged by us (whether in Hong Kong or overseas) and will be accessible only to our authorized staff, employees and service providers on a “need-to-know” basis. However, we give no warranty against third parties hacking into the data.
Unless prevented by law, in the event that HKREITA provides your personal data to agent, contractors or third party service providers they will be placed under a duty of confidentiality to HKREITA and will be required to use your personal data consistent with the agreements entered with HKREITA and in accordance with this policy and in compliance with the PDPO. They will be required to ensure adequate security of your personal data and will be required not to keep your personal data longer than necessary.
- Your visit to the Official Website may be recorded for analysing the number of visitors to the Official website and general usage patterns. Some of the information will be gathered through the use of "cookies". "Cookies" are small bits of information that are automatically stored on a user's web browser in his/her computer that can be retrieved by the Official Website. Cookies can make websites more useful by storing information about your preferences on particular websites, thus enabling website owners to provide customised and personalised services or products for users. The information collected by "cookies" is anonymous aggregated research data and contains no personal information such as name or domain name server address information that will enable anyone to contact you via telephone, email or any other means. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies or inform you when they are set. However, by disabling cookies, some functionality may not be available and you may not be able to fully enjoy the functions of the Official Website.
Use of Personal Data in Direct Marketing
- We may from time to time collect personal data from you when you use the Official Website and the contents thereof and we intend to use your personal data in direct marketing. We may not so use your personal data unless we have received your consent (which includes an indication of no objection to the intended use).
- We would like to use your name and contact details (such as telephone number, email address and/or correspondence address) for marketing the following services, events and activities of HKREITA through various communication means such as direct-mail, email, telephone, SMS, printed matter, newsletter, brochure and leaflets. Such services, events and activities include:
(a) events for the promotion of the industry of real estate investment trusts in Hong Kong;
(b) social events and activities for members of HKREITA;
(c) seminars, webinars and courses offered to members of HKREITA;
(d) joint promotion initiatives undertaken by the association; and
(e) research or survey on issues of common concern in the industry of real estate investment trusts in Hong Kong
- If you object to our use of your personal data for direct marketing purposes, please see paragraph 21 below.
Retention of Data
- We will keep your personal data for a reasonable time to fulfil the purpose for which the data was collected or comply with the relevant rules, regulations and laws of Hong Kong. Personal data which is no longer required will be destroyed.
Disclosure / Transfer of Personal Data
- Personal data held by us will be kept confidential, but we may disclose / transfer such data to the following parties (whether within or outside the Hong Kong Special Administrative Region) for the purposes set out in this policy:
(a) subsidiary and/or affiliates (if any) of HKREITA (collectively “HKREITA Entities”) in connection with the operation of our business, events services, and / or activities;
(b) professional advisors, service providers or contractors of HKREITA providing organisational management services and event organisation services;
(c) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment, content, information, or other marketing and promotional services to us in connection with the operation of our business, events, services and activities;
(d) any person under a duty of confidentiality to us or who has undertaken to keep your personal data confidential and use them in strict compliance with the requirements of the PDPO (including but not limited to accountants, legal advisors and other advisors);
(e) any government, law enforcement or administrative organisation;
(f) any person to whom we are under an obligation under law to make disclosure;
(g) those parties who we consider it necessary to do so in order to protect and defend our rights and properties, comply with applicable law, regulations, including but not limited to judicial proceedings, court orders or legal services; and
(h) any actual or potential assignee(s), transferee(s), successor(s) or purchaser(s) of all or any part of HKREITA’s businesses or of all or any part of our rights in any business or assets of HKREITA and/or its subsidiaries (if any).
Contact Details for our Corporate Data Privacy Officer
- If you wish to access or correct your personal data held by us or if you do not wish or opt of direct marketing or that you have questions on this policy, please send your request to:
Corporate Data Privacy Officer
Hong Kong REITS Association Limited
1 Connaught Place,
or by email: [email protected]
- In accordance with the PDPO, we may charge data subjects reasonable charges incurred in relation to administering and complying with their data access or correction requests.
- Hyperlinks on the Official Website may link to websites maintained by other third parties. These third parties may have their own privacy policies which might not be bound by this policy. We make no representation or warranty of the content on such websites. Access and use of such other websites are at your own risk and subject to the terms and conditions applicable to such websites.
- In case of discrepancies between the English and Chinese versions of this data privacy statement, the English version shall apply and prevail.