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PERSONAL INFORMATION COLLECTION STATEMENT

Personal Information Collection Statement
 
Please read the following Personal Information Collection Statement (“PICS”) to understand how the Hysan Group handles your personal data and your rights under the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the "Ordinance"). The Hysan Group comprises Hysan Development Company Limited and each of its subsidiaries including Hysan Leasing Company Limited, Hysan Marketing Services Limited, Hysan Property Management Limited, Stangard Limited, Hysan Corporate Services Limited, Bamboo Grove Recreational Services Limited, as well as their holdings companies, branches, representative offices and affiliates (collectively the "Group", "Hysan", "we", "us" or "our").

1. Data collection

1.1 The types of personal data ("Data") we collect from you may include:
a) your personal information, e.g. your salutation, name, gender, marital status, month of birth, age range, bank details, photograph, identification proof or numbers;
b) your contact information, e.g. telephone number, residential address, office address, mailing address, email address, and fax number;
c) your business and educational information, such as company name, business title and education background;
d) your membership numbers and relevant log-in information that you will use to access our products and services;
e) if you log-in to our websites, applications or WiFi services via your social media accounts, we may collect such log-in details and other information you have made available on the relevant social media site (note that Hysan does not operate those third party social media platforms, and you are advised to review their privacy policies as to how they handle your information);
f) browsing preferences, MAC address and IP address (in so far as they may be deemed to amount to personal data). Note that if the WiFi function on your device has been enabled, the MAC address and IP address of your device may be collected, even if the device is not connected to our WiFi services; and
g) other information as may be set out in the relevant form or collection channel.

1.2 We may also collect non-personally identifiable information about you, such as browsing preference of our websites or mobile applications, personal preferences and comments, and responses to promotional offers and surveys.

1.3 In certain situations, we may ask you to provide the Data of other individuals to us, e.g. emergency contacts, information of your family members. By providing us with such Data, you represent to us that you have obtained those individuals' authorisation and/or consent to the use, disclosure and transfer of their Data. We shall not be responsible for any claim whatsoever from any party in the absence of such consent.

1.4 In the relevant form or collection channel it may be indicated whether any Data is obligatory or voluntary. If you fail to supply Data that is marked as obligatory, we may not be able to engage with you for the intended purposes or provide the relevant products and services fully or at all.

2. Purposes for which the Data are Collected and Used

2.1 We may use the Data you provide for one or more of the following purposes (or any directly related purpose):
a) for the supply of any products and/or services which we, our Partners may offer to you or you may require from us or such other parties from time to time; "our Partners" include our retail merchants, office tenants, co-branding partners, and business partners (who may be engaged in businesses such as retail, banking, finance, credit/smart/stored value cards, insurance, charity/not-for-profit causes, entertainment, food & beverage, and other businesses as we may notify you);
b) for use of the online services available at any of our websites, mobile applications and/or through other telecommunication channels;
c) for market research and/or data analytics, including to better understand customer behaviour, for customer and tenant relationship management purposes, and to improve the business operations and marketing strategy of Hysan and our Partners;
d) subject to your consent, for sending you marketing and promotional updates on our and our Partners' activities, products and services from time to time;
e) for identification and verification purposes in connection with any of the services or products that may be supplied to you and creating and maintaining any accounts you may hold with us;
f) for reservations with or through us;
g) for administration and use of any membership clubs or loyalty or reward programmes;
h) for communicating with you by post, email, digital media (including through push notification), telephone, SMS or other means in respect of your use of our products, services, mobile applications and/or websites;
i) for daily operation and administration of our business and premises;
j) for enforcing our rights under contracts, including for collection or recovery of any debt owed by you to us;
k) for complying with legal or regulatory obligations applicable to any Group member;
l) To connect to our WiFi services;
m) for the use of any member of the Group in connection with any of the above purposes and/or any of the services such entities may be offering to you from time to time;
n) for handling your enquiries or requests, e.g. lost & found; and o) for any other purposes to which you may from time to time agree.

2.2 We will not sell or rent the Data provided to us, or knowingly or intentionally use or share the Data in ways unrelated to the purposes aforementioned.

3. Disclosure and Transfer of Data

3.1 We may disclose and transfer the Data you provide or which are otherwise collected by us to the following parties (whether local or overseas) in connection with the purposes set out above (or any directly related purpose):
a) any member of the Group (including different divisions within each Group entity);
b) any of our agents, professional advisers (including lawyers and auditors), contractors, subcontractors or third party service providers who provide administrative, financial, data processing, telecommunications, computer, payment, marketing and research, information technology, data analytics or other services in connection with the operation and maintenance of our business, or any persons under a duty of confidentiality to us;
c) our Partners;
d) our successors or assigns (whether actual or proposed) under an acquisition, sale or restructuring of the business and/or assets of any member of the Group, or any assignee of our rights;
e) any person to whom we are under an obligation to make disclosure under the requirements of law or a court order of any jurisdiction or to any government or law enforcement authorities or administrative organs as requested;
f) any person to whom we believe in good faith that disclosure is otherwise necessary or advisable including to protect our rights or properties or in circumstances which we consider to be related to any of the purposes for which the Data are collected; and
g) to any person when we have reason to believe that disclosing the Data to such person is necessary to identify, contact or bring or defend legal action against someone, e.g. anyone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.

3.2 The Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above, and you explicitly consent to and accept all risks of such transfer. We will try to ensure, as far as possible and practicable, that Data sourced or transferred outside Hong Kong is protected to standards in line with the requirements of the Ordinance, subject to any other requirements and limitations of the particular jurisdiction.

4. Direct Marketing

4.1 We intend to use your Data (and transfer your Data to the parties set out in paragraphs 3.1(a)-(d) above) to send you marketing and promotional materials through post, email, digital media (including through push notification), telephone, text/SMS messaging and other means, in relation to activities in Hong Kong or overseas such as:
a) Retail Events and Promotions: (i) promotions and events hosted, sponsored or organised by us or any member of the Group or by our Partners; (ii) any rewards or discounts, offers, membership, privileges, advantages or benefits offered by each member of the Group or our Partners;
b) Tenants / Residents Events and Promotions: promotions and events which we or any member of the Group host, sponsor, organise or participate in, e.g. clubhouse activities for residents, privileges and events for tenants.
c) Properties for Sale or Leasing: office, retail and/or residential properties offered for sale or leasing by us or any member of the Group and related services;
d) Charity and Community: solicitations for donations or contributions for charitable, social enterprise or non-profit making purposes, or community / social corporate responsibility events or activities which we or any member of the Group host, sponsor, organise or participate in; and
e) Others: other activities, events, businesses or promotions as may be carried out by the Group and notified to you (as set out in the relevant form or collection channel) from time to time. collectively the "Marketing Activities". We will only use your Data for the purposes of Marketing Activities if you have consented to such use.

4.2 You always have ultimate choice and control over the type of information you would like to receive from us. When you complete and return your membership application or other forms to us or use our online services, you can indicate your consent to us to use your Data for the purposes of the Marketing Activities. You can withdraw your consent for use by us of your Data for the Marketing Activities at any time by sending an email to our Data Privacy Officer at data.officer@hysan.com.hk or as indicated in the relevant materials.

5. Cookies and Other Tracking Mechanisms

5.1 We may automatically collect information about your computer or device, including where available your IP address, device ID, MAC address, operating system and browser type. This is statistical data which does not reveal your identity. Similarly, cookies may be left on the hard drive of your computer, mobile phone or other devices.

5.2 Cookies are small text files that are stored on your browser and the hard drive of your computer, mobile or other handheld device. We use cookies and other tracking mechanisms mentioned above for system administration, to track information about your use of our websites or mobile applications and to automatically improve and personalise your browsing and user experience. Please refer to our Privacy Policy for further information regarding how we use cookies: www.hysan.com.hk/privacy-policy-statement/. By accessing our website or applications, you provide your consent to the use of cookies pursuant to our Privacy Policy. You may choose to accept or refuse cookies by adjusting the settings of your web browser. However, if you select to refuse cookies, you may not be able to fully access certain functions or information contained on our website or applications.

5.3 We use analytics tools to automatically measure how visitors interact with content on our websites and applications, or in relation to your use of our WiFi services. If you log-in to our websites or applications or WiFi services via your social media accounts, we may collect information you have made available on the relevant social media site and link your interaction with us to such information. Where you have consented to direct marketing, we may also engage social media sites to show you advertisements that are customised (which may be automatic) based on your interactions with us.

5.4 We may feature embedded links, “share” buttons or widgets on our websites or applications to enable you to connect to third party sites, including social media sites. These third party sites may set cookies which can identify you as an individual when you are logged in to their services. We do not control these cookies or how these sites collect and handle your Data. You should read the relevant third-party sites for their privacy policies before submitting any Data to these sites. We have no control over and are not responsible or liable for the contents of third party sites or third party posts on our social media accounts.

5.5 We may use analytic technologies to collect non-personally identifiable information about you on an aggregated and anonymous basis, such as information captured by devices in real-time during your visit (e.g. visitor counts and information), and those which are collected via our WiFi services through your WiFi enabled device (even if it is not connected to our WiFi services) (e.g. IP address, MAC address, location data, visitor statistics and preferences, activity patterns and device information). If you do not wish us to collect the aforesaid information via our WiFi services, then you can disenable the WiFi function on your device. This data will not be linked to any Data we may retain in relation to you, and cannot be used to identify or re-identify you. We use this data for research and analytics purposes, including helping us to study activity patterns and visitor preferences in order to improve service experience.

6. How to Access or Correct Your Data or Contact Us

6.1 You are entitled to access or correct any Data related to you held by us. If you wish to obtain a copy of any of your Data or if you believe that the Data related to you which we collect and maintain is inaccurate, please contact our Data Privacy Officer at data.officer@hysan.com.hk or at the following address:

Data Privacy Officer
Hysan Development Company Limited
50/F, Lee Garden One
33 Hysan Avenue
Causeway Bay
Hong Kong

6.2 In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.
6.3 You may also contact us at the above details for any other data privacy related matters.

8. Language

This PICS 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 PICS, the English version shall prevail.

Last version date: Jan 2019
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