PRIVACY POLICY AND PERSONAL INFORMATION COLLECTION STATEMENT

1. Your Privacy

Henderson Real Estate Agency Limited (“we” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy and Personal Information Collection Statement (the “Statement”) explains our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People's Republic of China (“Hong Kong”).

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Statement applies to users of our website (the “Websites”) and may from time to time be revised or otherwise changed where we deem necessary.

If there is any inconsistency between the English and Chinese version of this Statement, the English version shall prevail.

Throughout this Statement, the meaning of the term “personal data” is defined in the Ordinance.

2. Data Collection and Use

We may collect your personal data including but not limited to name, telephone number, address and email address in order to provide you the various services and features. You are not obliged to supply the data, but if you do not, the services and features may not be available.

The purposes for which we may use your personal data are as follows:-

(i)	following up on comments, inquiries and complaints that users submit to the Website;
(ii)	following up and processing your applications, registrations or subscriptions;
(iii)	monitoring use of the Website to help its further development;
(iv)	understanding users' needs so as to provide better services;
(v)	compiling aggregate statistics about users to analyze usage of the Website;
(vi)	operating internal control, resolving disputes, troubleshooting problems and enforcing terms of use;
(vii)	contacting users regarding administrative notices and communication;
(viii)	collecting data for identity verification and record and maintaining contact lists for correspondence;
(ix)	designing, providing and marketing to users our facilities, services and/or products, and that of the Henderson Land Group and any of its subsidiary, associated and/or related company;
(x)	promoting, improving and/or further the provision of our facilities, services and/or products, and that of the Henderson Land Group and any of its subsidiary, associated and/or related company;
(xi)	delivering information that users may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;
(xii)	recruitment and other human resources related purposes;
(xiii)	communicating with our investors and/or potential investors, and that of the Henderson Land Group and any of its subsidiary, associated and/or related company;
(xiv)	complying with any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply; and
(xv)	any other purpose(s) which has been agreed by or notified to you.

If you are under the age of 13, you must ask your parent or guardian before providing any personal data to us.

When you use the Website, cookies will be stored in your computer. The purpose of using cookies is for internal navigation/ programming only. We will not collect any personal data from you under this circumstance. You have a choice not to accept the cookies, but if you do, certain functionality may not be available.

3. Disclosure

We will take all practicable steps to keep your personal data confidential but for any one or more purpose(s) named in paragraph 2 above, we may transfer/assign your personal data to or exchange such data with any of the following parties irrespective of whether such parties are located inside or outside Hong Kong:

(i)	any agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services to us with respect to the operation of our business;
(ii)	the Henderson Land Group and any of its subsidiary, associated and/or related company; or
(iii)	any person to whom we are under an obligation to make disclosure under the requirement of any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply.

Unless expressly stated in this statement or with prior consent, personal data collected from you will not be disclosed to any third party other than the above-named parties.

4. Links to Other Websites

This Statement only applies to the Website. If you click on any advertisement or hyperlink linking to other website(s), you will leave this Website for another location. At any other website, the protection of your privacy, personal data and your exposure to cookies are not our responsibility and you are advised to refer to the privacy policy of that other location (if any).

5. Web Logs

When a user visits the home page of the Website, the visit will be counted and included in the total number of visits to the Website for statistical purpose. This information does not identify you as an individual. No personal data will be collected.

6. Security

Except as mentioned in paragraph 3 above, your personal data, however stored, will be accessed only by our employees or contractors who are authorized to do and under a duty of confidentiality to us. Such authorized personnel or contractors designated to handle personal data will be instructed to do so only in accordance with this Statement.

7. Use of Personal Data in Legal Proceedings

If it becomes necessary that we have to take action against you for any reason whatsoever including but not limited to recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and take legal action against you.

8. Your Right to Access and Retention

You may at any time request access to and correct personal data relating to you in any of our records. To exercise any of your rights, contact us at the address below marking your communication “Confidential”. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days and we will endeavor to do so wherever possible, but we may charge you a reasonable fee for doing so.

9. Personal Data Privacy Officer

The person to whom (1) requests (a) for access to data or correction of data; (b) for general information regarding our policies and practices with respect to personal data; and (c) about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:-

Henderson Real Estate Agency Limited

Personal Data Privacy Officer (Portfolio Leasing Department)

(Marked Confidential)

Address: 73/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong

10. Retention of Data

We will only keep your personal data for as long as necessary to fulfill the purpose for which the data was collected unless the personal data is also retained to satisfy any applicable statutory or contractual obligations. Personal data which no longer required will be destroyed.