KERRY PROPERTIES LIMITED ("KPL")
A. Our Commitment To Data Protection
Kerry Properties Limited, its subsidiaries and the associates the businesses of which Kerry Properties Limited has daily management control (collectively the “Kerry Properties Group” or “we”) are committed to protecting your privacy. We pledge to comply with the requirements of the applicable privacy and data protection laws (“the applicable law”). We will also try to ensure, as far as possible and practicable, that data sourced from and/or transferred to and from outside the jurisdiction where you are located is protected to standards in line with the applicable law. For the purposes of this Personal Data (Privacy) Policy, “personal information/ personal data” shall have the meaning as given to it by the applicable law.
Subject to the requirements of the applicable law, your continued use of our website(s) will constitute your deemed consent to the terms of this Personal Data (Privacy) Policy.
B. Our Collection Of Information
We receive and collect two basic types of information, namely, (i) information you provide to us; and (ii) information we collect automatically when you use our website.
Information you provide to us. Depending on the specific types of services or information requested by you this may include but are not limited to:
- Your name, gender, date of birth, nationality, family status, passport or other identification numbers.
- Your telephone numbers, correspondence addresses, email addresses and fax numbers.
- Your credit card numbers and expiry date and bank account numbers.
- Any other personal data you choose to provide to us.
When we need to collect personal data from you to provide you with a particular service, we will ask you to voluntarily supply us with the information we need and notify you the specific purposes for the data collection under a Personal Information Collection Statement (“PICS”) upon collection of such data and information. By providing us with your personal information, you are agreeing and accepting the terms of our Personal Data (Privacy) Policy. If you choose not to provide the personal information to us, we may not be able to supply you with the relevant information, services or products.
Information we collect automatically when you use our website(s). The types of non-personal data we collect includes information/data about your use of our website(s) such as your access time, page(s) visited, IP address, browser type, operating system, demographics, clickstream data, referring/exit pages and duration of your visit. Such information does not individually identify you and is collected for customizing, enhancing, maintaining, improving and optimizing the quality of our website(s) and to compile statistics to analyse site usage.
C. The Purposes For Which The Personal Data Are Collected
Subject to the requirements of the applicable law, there are various legitimate and lawful grounds on which we may rely on when using and processing your personal data. The personal data collected will be used for the purposes set out below. You will find more specific details of the purposes of data collection in the PICS that will be made available to you upon collection of such data.
For the performance of our agreement with you, in order to:
- lease and/or sell our products and/or services to you;
- facilitate payment for products and services supplied to you;
- facilitate your use of online services available at any of our website(s), software(s), or through other telecommunication channels;
- verify identity in connection with any of the products, services or information that may be supplied to you or required from us; and
- any other incidental or associated purposes relating to the above.
For our legitimate commercial interests, in order to:
- facilitate communication with you to conduct our own marketing research to identify market trend and preference to improve our service and product quality; and
- any other incidental or associated purposes relating to the above.
To comply with legal obligations to which we are subject for:
- facilitating compliance with relevant legal and regulatory requirements;
- preventing, detecting and investigating crime and analysing and managing commercial risks; and
- conducting investigations.
Use of information based on your consent, in order to:
- promote and market our products, services, facilities benefits and offers to you; and
- for any other purposes for which we have obtained your consent, in accordance with the requirements of the applicable law.
In addition, we collect, use anddisclose your personal data for the following purposes depending on the nature of our relationship:
- facilitating your use of any membership or clubhouse facilities and participation in interest classes, events and functions;
- facilitating our management of membership accounts and records;
- facilitating our management of our customer relationship by sending you updates on Kerry Properties Group or on latest offers and promotions, benefits and offers in relation to any of our products and services from time to time; and
- any other incidental or associated purposes relating to the above.
If you are our job applicants:
- facilitating recruitment and other human resources related purposes; and
- any other incidental or associated purposes relating to the above.
D. Who We May Disclose Your Personal Data To
We will inform you in the PICS that are made available to you on collection of personal data should there be any data transfer and seek your voluntary consent or indication of no objection in respect of the data transfer. Subject to the provisions of the applicable law, our data transfer is for the purposes set out below (where applicable). The parties to whom the data transfer are made may have places of business outside the jurisdiction where you are located, your personal data may therefore be transferred overseas.
- To a limited number of our subsidiaries and associated companies that we consider appropriate and relevant in connection with the purposes and /or any of the services that are stated in the relevant PICS, but we shall only do so on a need to know basis.
- To our subsidiaries and associated companies or third party service provider(s) engaged by us who need access to such information to provide services for or in relation to the website(s) or to provide information technology support to us, and /or to conduct maintenance of our servers, data banks, data bases and data management system.
- To third party services provider(s), coach(es) trainer(s), organizer(s) of events, interest classes, activities and functions organized for the relevant event, interest classes, activities and functions which will be provided to you.
- To (actual or prospective) purchaser(s)/assignee(s) as part of, or during negotiation of, reorganisation, merger or transfer of our business or interest in our subsidiaries and associated companies.
- To our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations.
- To government or other law enforcement or regulatory authorities for the purpose of complying with any applicable laws or regulations or court orders or lawful requests or to protect our rights or properties.
- To any other party at your consent or at your direction or whom you authorise us to disclose your personal data to.
- Otherwise as permitted or required by any applicable laws or regulations.
We may also disclose aggregate or de-identified data that is not personally identifiable with third parties, including our commercial and strategic partners whereas theparties to whom the data transfer are made are not allowed to use or disclose your personal data other than the purposes set out in this Personal Data (Privacy) Policy or the PICS.
Your personal data will be transferred to, and stored at, locations within or outside the Hong Kong Special Administrative Region (“HKSAR”). It will also be accessed and processed by our personnel and the personnel of our partners, affiliates and third party service providers, who may operate within or outside HKSAR. Your personal data will only be transferred to other jurisdiction(s) outside of HKSAR where we are satisfied that adequate or comparable levels of protection are in place to protect personal data held in that jurisdiction, and (where we are required to do so) with your consent.
E. How Do We Protect Your Personal Data
We are committed to protecting the personal data that we collect from you. We will store the physical records of your personal data in secured places with restricted access. We have implemented appropriate safeguards and precautions to protect the server(s) that store your personal data as well as to protect the security, integrity, accuracy, privacy and completeness of the personal data we collect from you from unauthorized or accidental access, processing, erasure, loss or use. However, whilst we would try our best to protect your personal data once we receive it, no data transmission over the internet or any other public network can be guaranteed to be 100% secure.We shall not be liable for damages that may result from the use of electronic means of communication, including, but not limited to, damages resulting from the failure or delay in delivery of electronic communications, interception or manipulation of electronic communications by third parties or by computer programmes used for electronic communications and transmission of viruses.
Subject to local laws and regulations, we will not retain your personal data for a period longer than necessary for the fulfilment of the purposes for which they are used or when requested by you. We may keep your personal data for longer periods where extended retention periods are required by law or regulation and in order to establish, exercise or defend our legal rights.
F. Children and Minors
Except where the applicable laws permit or require, we will not knowingly collect or maintain data in our data base from minors without prior consent from a parent or guardian.
G. Use Of Cookies
Cookies are small computer text files that are sent from a website to the browser of your device (e.g. computer, smart-phone, tablet, as the case may be) and are stored on your device to improve your browsing experience on those websites and to provide the website operator with non-personal data/analytical information to help improve your website browsing experience and the quality of the relevant website(s).
Most browsers are initially set up to accept cookies. You may choose not to accept cookies from the website(s) by changing your cookies setting (see our Cookies Policy). However, if you choose to disable cookies on your device, you may find that some features and functions of the website(s) may not work properly.
H. Links To Other Websites
When you are browsing on the website(s) and when you click on the hyperlinks to the other companies, government departments etc. listed in the information provided in the website(s) and be directed to those websites that are not controlled or managed by us, this Personal Data (Privacy) Policy does not apply to those other websites and those other websites may send their own cookies and/or other tracking technologies to your device and may also independently collect or solicit personal data from you. If you visit those other websites, you should consult their privacy policies before providing your personal data on those other websites. We shall not be liable in relation to your activities on those other websites.
I. Your Rights and Contact Us
Subject to the applicable law, you may have the right to access, correct/ rectify, request deletion/erasure, or restrict or withdraw your consent to processing your personal data, the right to object against profiling and the right to data portability, under certain circumstances in accordance with the applicable law. If you wish to exercise these rights, or if you have any enquiries on our privacy policy and practice, please contact our Personal Data Privacy Officer by email or in writing to the address below or to the address as set out in the PICS in respect of the original source of data collection. Please also mark “Confidential: Personal Data Access / Correction / Enquiries” on your correspondence and be sure to include your full name, telephone number and/or address so we can ascertain your identity and specify clearly and precisely the description of your request and the original source of data collection.We may charge for a request to access your information, if permitted by the application law. In addition, you may also have the right under the applicable law lodge a complaint with your local supervisory authority (as applicable) for data protection matters.
By Email
communication@kerryprops.com
By Post:
Kerry Properties Limited
25/F Kerry Centre
683 King's Road
Quarry Bay
Hong Kong
By Fax:
(852) 2967 2200
If our processing of your personal data is subject to laws and regulations of the Mainland China, please refer to the 《嘉里建设中国大陆地区隐私政策》, which shall prevail for such processing.
J. Responsibilities
This policy has been reviewed by the Sustainability Steering Committee (the “Committee”). The Committee will review and update this policy periodically while management and divisional heads are responsible for its implementation. Any breach of this policy may be reported to the Committee.
K. Revision and Interpretation
We reserve the right to change the terms of our Personal Data (Privacy) Policy from time to time. The latest version of our Personal Data (Privacy) Policy will be posted on the website(s). You may also obtain a hard copy by writing to our Personal Data Privacy Officer and we encourage you to review this Personal Data (Privacy) Policy whenever you access the website(s) or otherwise interact with us to stay informed about our information practices and the ways you can help protect your data privacy. Any changes to our Personal Data (Privacy) Policy will become effective upon posting of the latest version on the website(s). Your continued visit and/or logging into our website(s) or provision of your personal information to us following the posting of the changes to the terms of our Personal Data (Privacy) Policy means you agree with and accept our changes and the latest version of our Personal Data (Privacy) Policy.
If there is any inconsistency or ambiguity between the English version and the Chinese version of this Personal Data (Privacy) Policy, the English version shall prevail.
Last updated: 28 February 2024