AP Assets Limited (the "Company")
The Company is committed to protecting the personal data of individuals and therefore it is the Company’s policy to ensure its policies and practices in relation to the collection, use, transfer, retention and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance, Cap.486 (the “Ordinance”).
2. Types of Personal Data Collected
For the purpose of provision of real estate agency services by the Company, customers may be requested to provide personal data including but not limited to the name, contact details (including but not limited to telephone number, fax number, email and/or correspondence address), identification document number and copy of any document which may contain the personal data of the customers, such as identity card, passport, bank statements and utility bills. Provision of personal data is on a voluntary basis. Failure to supply such personal data may result in the Company being unable to provide real estate agency services.
3. Use of Personal Data
The personal data provided by the customers may be used by the Company for the purpose of:
(a) provision of real estate agency services;
(b) direct marketing of the real estate agency services of the Company;
(c) direct marketing of the services, reward and/or promotional programmes and/or events provided by the institutions or individuals listed in paragraph 6 below (the “Third Parties”) in relation to the classes of marketing subjects specified in paragraph 5 below (the “Services”);
(d) compliance with the applicable laws, rules and regulations as well as the guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company;
(e) collection of outstanding debts from customers; and/or
(f) legal proceedings and/or enforcement of judgments and/or orders.
4. Use of Personal Data for Direct Marketing
The Company intends to use the name and contact details (including telephone number, fax number, email and/or correspondence address) of the customers for direct marketing of the real estate agency services provided by the Company.
5. Transfer of Personal Data for Direct Marketing
The Company intends to transfer the name and contact details (including telephone number, fax number, email and/or correspondence address) of the customers to the Third Parties for use in direct marketing of the following Services and the Company may derive gain as such:
Personal data of customers held by the Company may be transferred to the following parties:
(a) co-operative estate agents;
(b) service providers of the Company offering rewards and/or promotions;
(c) law firms, banks, financial institutions, insurers, service providers for mortgage referral, financial planning, property valuation, immigration consultancy and/or wealth management;
(d) government agencies, regulatory bodies and/or other lawful authorities;
(e) courts, tribunals and/or parties to the legal proceedings; and/or
(f) debt collection agencies.
7. Request to Cease the Use of Personal Data for Direct Marketing
Even if customers have given consent to the Company on the use and/or transfer to the Third Parties of their personal data for direct marketing, customers may still have the right, at any time without charge, to request the Company to cease to use and/or transfer their personal data to the Third Parties for direct marketing. Customer may write to the Data Protection Officer of the Company firstname.lastname@example.org in Hong Kong for making such request. The Company will cease using their personal data for such purpose.
8. Web Logs
When you visit the Company’s website, the Company’s webserver makes a record of your visit that includes your source IP address, access time, URL, browser type and your device type (webserver access log). The Company uses the webserver access log for the purpose of maintaining and improving the Company’s website such as to determine the optimal screen resolution, which pages have been most frequently visited etc. The Company does not use, and has no intention to use the visitor data to personally identify anyone. Most web browsers are initially set up to accept cookies. You have a choice not to accept the cookies and continue to browse the Company’s website, but if you do, certain functionality may not be available.
9. Security and Retention of Personal Data
The Company has implemented internal control measures to ensure the security of personal data and to prevent unauthorized or accidental access, process, erasure, loss or use of personal data. Personal data provided by you are retained until the completion of the purposes for which such data were collected and will not exceed 7 years in general, or such longer period as prescribed by applicable laws, rules and regulations as well as guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company.
10. Access to and Correction of Personal Data
Under the Ordinance, customers have the right to access and/or correct their personal data. Accordingly, customers may at any time write to the Data Protection Officer of the Company at email@example.com. In accordance with the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
All enquiries about this statement or personal data shall be addressed in writing to the Data Protection Officer of the Company at firstname.lastname@example.org
The Company reserves the right to change this Statement and/or any part thereof.