Henderson Property Agency Limited

PRIVACY POLICY STATEMENT

for "Henderson eHome"

Henderson Property Agency Limited (“we” “our” or “us”) are committed to protecting the privacy, confidentiality and security of the personal data we hold and pledge to comply with the requirements of Personal Data (Privacy) Ordinance (the “Ordinance”) with respect to the management of personal data.  We are committed to ensuring that all our employees and agents uphold these obligations.

Kinds of Personal Data held and Purposes

The kinds of personal data held by us and the purposes for which it may be used are explained in our Personal Information Collection Statement (“PICS”). Please refer to our PICS for details.

Personal data held by us usually includes the names of users of Henderson eHome (“App”) and their contact details. Additional kinds of personal data will be collected and held for App users who enquire or intend to purchase properties, usually including identity document numbers and information about the property transactions and related arrangements.

The personal data will be processed and used for the purposes for which it is collected and directly related purposes.  Such purposes may include providing the App and registering users for using the App and verifying user identity, handling property transactions and related matters including enquiries or registration for mortgage loans and other credit facilities, and handling enquiries or applications for other products or services, etc.

Security Measures

Personal data collected is stored securely in our system, and only trained, authorized staff shall have access.

Retention of Personal Data

We will take all reasonably practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purposes for which it is to be used.

Sharing of Personal Data

We do not disclose or transfer App users' personal data to third parties without their prior consent, except to the parties and for the purposes specified in the PICS or unless required or permitted by the Ordinance.

Use of Personal Data for Direct Marketing

Under no circumstances shall we use App users' personal data, or disclose or transfer their personal data to third parties for direct marketing without their prior consent.

Outsourcing Arrangement

We may appoint service providers to process personal data. These service providers may include information technology contractors, software suppliers, and data analytics service providers. All service providers are required by us to comply with the applicable requirements and restrictions under the Ordinance in processing the personal data.

Links to Third Party Websites

The App may provide links to third party websites. Our data privacy policy is not applicable to these third parties. Use of personal data by any third party will be subject to that party's data privacy policy and practices.

Access to and Correction of Personal Data

Under and in accordance with the Ordinance, an App user has the right:-

1. to check whether we hold personal data about him/her and to access such data;
2. to require us to correct any personal data held by us relating to him/her which is inaccurate; and
3. to ascertain our policies and practices in relation to personal data and to be informed of the kinds of personal data held by us.

Such requests can be made in writing to our Personal Data (Privacy) Officer at the following address:-

Data Protection Officer

71/F – 76/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong

We may charge a fee for processing a data access request which must not be excessive.

Amendment of this Policy

We may from time to time amend and update this policy as we consider appropriate. The revised policy will be effective upon being posted in the App. Please check the policy posted in the App on a regular basis.

Enquiries

If you have any questions about our privacy policy and practices, please contact our Data Protection Officer at sales.hk@hld.com, or by post at 71/F – 76/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong.