Data collection

1. The types of personal data (“Data“) we collect from you may include:

   1. your personal information, e.g. your salutation, name, gender, age group, marital status, month and date of birth, spending record, your interest, your geographical location, bank details, photograph, identification proof or numbers;

   2. your contact information, e.g. telephone number, residential address, office address, mailing address, email address, and fax number;

   3. your business and educational information, such as company name, business title and education background;

   4. your membership numbers and relevant log-in information (e.g. user names or account numbers), credit card/debit card/stored value card information, mobile payment and other payment information, vehicle registration number, vehicle/plate photo that you will use to access our products and services or in relation thereto;

   5. if you log-in to our websites or applications via your social media accounts, we may collect such log-in details and other information you have made available on the relevant social media sites (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);

   6. photos of and information regarding your spending and purchase of goods and/or services via our websites or applications;

   7. browsing preferences and behaviours, MAC address and IP address (in so far as they may be deemed to amount to personal data).and

   8. other information as may be set out in the relevant form or collection channel.

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.

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.

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.

Purposes for which the Data are Collected and Used

1. We may use the Data you provide for one or more of the following purposes (or any directly related purpose):

   1. to enable us or our Partners to provide rewards or benefits or privileges to you in relation to your LGA membership; “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);

   2. for use of the online services available at any of our websites, systems, mobile applications and/or through other telecommunication channels;

   3. for our own market research, data analytics to better understand customer behaviour and customer and tenant relationship management purposes, and to improve the business operations and marketing strategy of Hysan and our partners;

   4. subject to your consent, for sending you marketing and promotional updates on our and our Partners’ activities, products and services from time to time and to customise and tailor such marketing communications to you;

   5. to confirm your identity and verify that you are a member of the LGA;

   6. to administer your LGA membership;

   7. for use of the services, systems, facilities, functions or features provided by us or our Partners;

   8. for participation of the events, promotions, campaigns, or activities organised by us or our Partners;

   9. for reservations with or through us

   10. for communicating with you by email, mail, fax, phone SMS, digital media (including through push notification) or other means regarding your LGA membership or your use of our products, services, mobile applications, systems and/or websites (if any);

   11. to handle your requests for services, membership, redemption or benefits;

   12. for daily operation and administration of our business;

   13. for enforcing our rights under contracts, including for collection or recovery of any debt owed by you to us;

   14. for complying with legal or regulatory obligations applicable to any Group member;

   15. 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;

   16. for any other purposes to which you may from time to time agree; and

   17. to carry out our obligations to you under the terms and conditions for membership of the LGA.

2. We will not sell or rent the Data provided to us, or without your prior consent knowingly or intentionally use or share the Data in ways unrelated to the purposes aforementioned.

Disclosure and Transfer of Data

1. We may disclose, grant access, share or 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):

   1. any member of the Group (including different divisions within each Group entity);

   2. any of our agents, professional advisers (including lawyers and auditors), contractors, subcontractors or third party service providers who provide administrative, financial, data processing, data storage, telecommunications, computer, payment, system operation, 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;

   3. our Partners;

   4. 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;

   5. 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;

   6. any person to whom we believe in good faith that disclosure is otherwise necessary or advisable including and without limitation 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

   7. 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.

2. The Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong or mainland China or jurisdictions where Data is being collected for the purposes mentioned above. We will try to ensure, as far as possible and practicable, that Data sourced or transferred outside Hong Kong or mainland China or jurisdictions where Data is being collected is protected to standards in line with the requirements of the Laws, subject to any other requirements and limitations of the particular jurisdiction, for example, we may seek your consent to the cross-border transfer of personal information as appropriate, or implement security measures such as data de-identification before transfer. If you are located in mainland China, you can email us at data.officer@hysan.com.cn for further information about the recipients of the Data.

Our Commitment to Children’s Privacy
Protecting the privacy of children is our primary concern. If you are under the age of 18, you should obtain consent from your parent or guardian before providing us with your Data.

1. For the purpose of this PICS, we regard minors under the age of 14 as children. Protecting the privacy of children is our primary concern.

2. Our site and services are primarily intended for adults. If you are under the age of 14, you should obtain consent from your parent or guardian before providing us with your Data. We will only use or disclose the Data as permitted by laws, with the explicit consent of your parent or guardian, or as necessary to protect children.

3. In addition to complying with the provisions of this PICS, we will also uphold the principles including necessity, informed consent, clear purpose, security, and lawful use, and also strictly abide by the requirements in respect of the protection of children’s personal information by the relevant laws and regulations. However, please note that in most cases, we cannot identify or ascertain whether the personal information collected and processed is children’s personal information and its accuracy.

4. In the event that we become aware of the collection of personal data of children without the prior consent of the parent or guardian, we will take appropriate measures to delete such personal data as soon as possible. If you are the parent or guardian of the relevant children and wish to report any such potential unauthorised collection, please contact us at data.officer@hysan.com.hk (for members located in Hong Kong)/ data.officer@hysan.com.cn (for members located in mainland China) to request to delete personal information of children.

Direct Marketing

1. We intend to use your Data (and transfer your Data to the parties set out in paragraphs 3.1(a)-(d) above) for sending you marketing and promotional materials through the post, email, digital media (including through push notification via the applications), telephone, SMS and other means, in relation to activities in Hong Kong or overseas such as:

   1. Retail Events and Promotions: (i) promotions and events hosted, sponsored or organised by us or any member of the Group or our Partners; (ii) any rewards or discounts, offers, membership, privileges, advantages or benefits offered by each member of the Group or our Partners;

   2. 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.

   3. 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;

   4. 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

   5. 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.

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 membership application or other forms to us or use our online services, you can indicate your consent to our use of 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 (for members located in Hong Kong)/ data.officer@hysan.com.cn (for members located in mainland China) or as indicated in the relevant materials.

3. Please note that surrender of membership does not mean withdrawal of consent to use of your Data for the purposes of Marketing Activities. All withdrawal of consent must be made in accordance with clause 5.2 above.

Cookies and Other Tracking Mechanisms

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.

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 systems 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.leegardens.hk/privacy-policy/. By accessing our websites, systems 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 or device. However, if you select to refuse cookies, you may not be able to fully access certain functions or information.

3. We use analytics tools to automatically measure how visitors interact with content on our websites, systems and applications. If you log-in to our websites, systems or applications via your social media accounts, we may collect information you have made available on the relevant social media sites and link your interaction with us to such information. Where you have consented to direct marketing, we may also engage social media sites or send you push notifications via the applications to show you advertisements that are customised (which may be automatic) based on analysis of any Data we may retain in relation to you, your interactions with us and/or aggregated and anonymous non-personally identifiable information we collect via analytics technologies.

4. We may feature embedded links, “share” buttons or widgets on our websites, systems 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 websites, systems, applications or social media accounts.

Data Security and Retention

1. The Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes (or a directly related purpose) mentioned above, after which it will be destroyed. We will retain your personal data for fifteen (15) months following the termination of your membership, in order to enable us to address any enquires or disputes that arise between us and you concerning your membership. Only anonymised data, where it is not possible to ascertain your identity, is retained for analytical and statistical purposes for more than fifteen (15) months following the termination of your membership.

2. In order to ensure the correct use and to maintain the accuracy of the Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Data, we have implemented various physical, electronic and management measures to safeguard and secure the Data we collect.

How to Access or Correct Your Data

1. You are entitled to access, correct or delete any Data related to you held by us or exercise your other rights in relation to your Data under the applicable laws. 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 or wish to request to delete, or if you wish to exercise your other rights under the applicable laws, please contact our Data Privacy Officer at data.officer@hysan.com.hk (for members located in Hong Kong)/ data.officer@hysan.com.cn (for members located in mainland China) or at the following address:

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

2. In accordance with the terms of the Ordinance (if applicable) and other applicable laws, we have the right to charge a reasonable fee for the processing of any data access request.

3. You may also contact us at the above details for any other data privacy related matters.

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.