Swire Properties Limited
Personal Information Collection Statement
Collection of your personal
data
1. From time to time, it is necessary for you
to supply Swire Properties Limited ("us",
"our" or "we") with personal information and
particulars to enable us to carry out the activities described in paragraph 3
below. We may be unable to carry out such activities if you do not provide the
necessary information and particulars.
2. We may also generate and compile
information and collect information from publicly available sources about you. Personal
information and particulars provided by you and all information collected,
generated and compiled by us about you from time to time is collectively
referred to as "Personal Data".
Purposes for
which your Personal Data are used
3. We may use your Personal Data for one or
more of the following purposes:
(i)
(a) marketing and
promoting services, products, facilities and other subjects, and/or (b)
promoting and soliciting donations or contributions for charitable or
non-profit making causes (please see further details in "Use and transfer of your Personal Data in direct marketing" section below);
(ii)
for payment purposes
for any services, products and/or facilities, including verification of credit
card details with third parties;
(iii)
for use of the online
services available at any of our websites and/or through other
telecommunication channels;
(iv)
for leasing,
development, sale or purchase of products or
facilities and/or for management or other related services;
(v)
for identification and
verification purposes in connection with any of the services, products and/or
facilities that may be supplied to you;
(vi)
for reservations with
or through us and/or any of Swire Properties Limited, its
subsidiaries, holding companies and joint venture and associated companies (together,
“Swire Properties Group”);
(vii)
communicating with you
by email, mail, fax, phone or other means, including contacting you regarding
your enquiries;
(viii)
conducting research
and/or analysis from time to time to better understand your shopping, dining,
spending and/or other consumption needs, preferences, interests, experiences
and/or habits;
(ix)
(a) designing new
and/or enhancing existing services, products, facilities, activities, contests,
lucky draws and/or other events (together, the “Activities”) relating to
Swire Properties Group’s
portfolios of properties or tenants in such portfolios of properties (“Merchant(s)”), and/or (b)
administering any of the Activities conducted by Swire Properties Group (or on its/their
behalf) or by the Merchant(s);
(x)
managing customer
relationship and relationship with Swire Properties Group’s Merchants;
(xi)
operating and
administering any membership clubs or loyalty or reward programmes;
(xii)
making disclosure when
required by law, regulation, or court order of any jurisdiction, and/or as
requested by any government, regulatory or law enforcement authority or
administrative organisation, which may be within or outside The Hong Kong
Special Administrative Region of the People’s Republic of China (“Hong Kong”);
(xiii)
(a) establishing legal
claims or defences, (b) obtaining legal advice, and/or (c) exercising,
defending and/or protecting the rights or properties of any member of Swire Properties Group, including identifying, contacting or
bringing legal action against any person who may be causing interference with
such rights or properties (whether intentionally or otherwise) or where any
other person could be harmed or property of any other person could be damaged by
such interfering activities;
(xiv)
for the use by any member
of Swire Properties Group in connection with any of the above purposes and/or
any of the services, products and/or facilities that any member of Swire
Properties Group may offer or supply to you from time to time; and/or
(xv)
any other incidental or
associated purposes relating to the above, or any other purpose which you may
from time to time agree.
Transfer of your Personal Data
4. To facilitate the purposes set out in
paragraph 3 above, we may transfer, disclose, grant access to or share your
Personal Data with the following parties (whether within or outside Hong Kong),
and your Personal Data may be transferred within or outside Hong Kong:
(i)
any member of Swire
Properties Group;
(ii)
any agent, contractor
or third party service provider who provides administrative, marketing,
research, distribution, data processing, telemarketing, telecommunications, computer,
payment or other services to or support the operation of Swire Properties
Group’s business (including its/their direct marketing activities);
(iii)
other business
associates such as loyalty programme operators and other companies involved in
providing customer service or fulfilling customer requests;
(iv)
credit reference
agencies, credit, debit and/or charge card companies and/or banks;
(v)
medical professionals, clinics,
hospitals, insurers and/or loss adjustors;
(vi)
any person, government
or law enforcement authority or administrative organisation;
(vii)
any person under a duty
of confidentiality to any member of Swire Properties Group (including
accountants, legal advisers or other advisers);
(viii)
any actual or proposed
assignee or purchaser of all or any part of the business and/or asset of Swire
Properties Group; and/or
(ix)
charitable or
non-profit making organisations.
We may also share
information or statistics with third parties in an aggregated or anonymised
form that does not directly identify you (e.g. we may share aggregated
information about your preferences and location with advertisers for marketing
purposes).
Use and transfer of your Personal Data in direct marketing
5. We are allowed to use and/or transfer your Personal Data in direct marketing only if you
consent or do not object in
writing.
6. In connection with direct marketing, we
intend
(i)
to use your name,
contact details, location data, customer profiling information (including information
about your use of our website and activity on social media platforms, including
your shopping preferences and online behaviour), services and products
portfolio information, and transaction pattern and behaviour collected,
compiled, generated or held by us from time to time (a) for marketing,
research, questionnaires, promotional and customer relationship management
purposes including sending you information relating to Swire Properties Group’s
and/or its Merchant’s products, facilities, services, membership clubs, reward
programmes (including joint collaborations with different brands), activities,
contests, lucky draws, promotions, blogs, newsletters and/or events in the
following categories: cultural, entertainment and sporting facilities and
activities, commercial and residential properties, hotels, restaurants, spa, consumer
goods, food and beverages, books and stationery, fashion and accessories,
children’s goods, watches, jewellery and other luxurious goods, optical
products, personal care, health and beauty products and services, home
furnishing and appliances, florists, sports gear and products, electronic
products and appliances, bank outlets and financial services, charity
activities, motor vehicles and car parking facilities, and/or (b) to promote or solicit donations or
contributions for charitable or non-profit making causes including relief of
poverty, advancement of education or religion, promotion of health, saving of
lives, relief of victims of disaster or epidemic, relief of disabled persons,
relief of those in need by reason of youth, age, gender, race, ill-health,
financial hardship or other disadvantage, protection of animals, preservation
or improvement of the environment or any other charitable purpose that is of
benefit to the community, (together, "Classes of Marketing Subject");
and
(ii)
to provide your name
and contact details to (a) providers
(whether within or outside Swire Properties Group) of any of the Classes of
Marketing Subject, (b) Swire
Properties Group’s Merchants and call centres, (c) any member of Swire
Properties Group, and/or (d) marketing or research services providers, so that
they can send you information in relation to the above Classes of Marketing
Subject. Information may be sent to you by email, mail, fax, phone or other
means.
7. 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:
(i)
unsubscribing by
following the "Reply To" instructions contained in the marketing text
message;
(ii)
following the
unsubscribe instructions or hyperlink in the email;
(iii)
following the
unsubscribe instructions in the mobile application;
(iv)
notifying us that you
no longer wish to receive marketing communication when receiving our marketing
calls; or
(v)
contacting us at the
address stated in paragraph 13 below to tell us that you no longer wish to
receive marketing communication through any channel.
8. 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.
Cookies, Log -
Files, Location Data and access to Personal Data through social media platforms
9. If you visit any of our websites, we may
use cookie files to store and track information about you and your preferences.
A cookie is a small text file that our website transfers to your device. The
use of cookies means we can better serve you and/or maintain your information
across multiple pages within or across one or more sessions. Most web browsers
automatically accept cookies, but if you prefer, you can edit your browser
options to block them in future. 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 address 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 device, and only the site
that created the cookie can read it.
10. We may also collect information regarding
your Internet Protocol (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.
11. 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 set out in paragraph 6 above.
12. 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.
Your Rights and
Contacting Us
13. You are entitled to access or correct your
Personal Data held by us. You may also:-
(i) request deletion or erasure of
your Personal Data;
(ii) object to the sharing of your
Personal Data; and/or
(iii)
object to the profiling
of your Personal Data.
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:-
Customer Support Officer
Swire Properties Limited
64/F One Island East, 18 Westlands Road, Taikoo Place, Hong Kong
14. 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.
15. 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 in paragraph 13
above.
This Statement 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 Statement, the English version shall prevail.
