(Extracted from Annual Report 2019)
With respect to procedures and internal controls for the handling and dissemination of inside information, the Company:
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 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 and 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;
(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
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.