Last Updated: 26 August 2022

Hong Kong PropTech Association Limited (“HKPTA”, ”we”, “us”, or the “Company”) respects your privacy and is committed to protecting it through the adoption of this document (“Personal Data (Privacy) Policy” or “Policy”).

The purpose of this Policy is to inform you how HKPTA manages your Personal Data (defined below) through the use of our services (“Services”) including but not limited to accessing our website www.hkproptech.org (“Website”) which is owned and operated by us. 

Please take a moment to read this Personal Data (Privacy) Policy so that you know and understand the purposes for which we collect, use, store, share, transmit, delete or otherwise process (collectively, “process”) your personal data. Personal data means any information relating to you directly or indirectly, from which it is practicable for your identity to be directly or indirectly ascertained, or such wider definition as may be prescribed in the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) and its subsidiary legislations and regulations as amended from time to time  (“Personal Data”).

We understand that some of our users may be from jurisdictions other than Hong Kong and may require us to provide additional information to you about our data processing activities. Please refer to the appendix to this Privacy Policy that applies to you. We acknowledge that laws in certain jurisdictions not expressly mentioned in this Privacy Policy may afford additional rights to you in respect of your personal data. We anticipate that the rights set out in this Policy also provide you with such protection in relation to your personal data.

Types of Personal Data we collect

We collect the following types of Personal Data which may include but not limited to the following:

• personal contact information such as your photograph, name, telephone number, fax number, email address and mailing address and other personally identifiable information such as your bank account details;
• work-related information such as your job title, the name of your company, your registration details and the nature of your business; and
• information related to your use of the Website/ services (e.g., behavioural information, location information, browser details, IP addresses or user acquisition data) – please also see our Cookies Policy for details.

This Policy may, in our sole discretion, be updated, modified, and changed from time to time without notice to you. Your continued use of the Website after we make such updates, modifications, and changes is deemed to be acceptance of such. It is your responsibility to check our latest Policy periodically for changes.

Purpose of Collecting your Personal Data

We (or third party data processors, agents and sub-contractors acting on our behalf) may collect, store and use your Personal Data by way of different methods to collect data from and about you including through direct interactions with us. This includes Personal Data:

• when you navigate through the Website;
• when you correspond with us directly by telephone, mail, email or otherwise;
• when you submit such data to us on the Website for any reasons (for example, by registering your membership with us and completing and submitting any forms to us);
• when you interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;
• when we receive references from business partners or third parties in marketing events;
• from publicly available sources of information;
• when our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
• when we are required to do so by law or regulation.

We may use your Personal Data in the following ways:

• to process your membership application or renewal and to maintain your membership;
• to verify your identity or age;
• to deliver or perform the products or services you purchased or subscribed;
• for direct marketing purposes to send you information, newsletters and other materials about us, our business partners, and event invitations both in print and in electronic forms (see “Direct Marketing” below);
• to make your Personal Data available to other members of HKPTA to facilitate networking among members (see “Direct Marketing” below);
• to collate data and prepare reports in relation to our operations;
• to process billing and payment, to determine amounts outstanding, and, if necessary, to collect outstanding payments;
• to communicate with you regarding your membership and to assist you with your queries; and
• to make such disclosures as required by applicable laws or regulations.

While the supply of your Personal Data is voluntary, if you choose not to provide your Personal Data to us, we may not be able to provide you with the information or our services you require.

Our Website is hosted on Glue Up. They provide us with the online platform that allows us to provide our Services to you. In your interaction on our Website, your Personal Data may also be stored and processed by Glue Up as a “data processor” and a “service provider”. How Glue Up processes and protects your Personal Data is also governed by their privacy policy available at https://www.glueup.com/legal/privacy-policy/, which may be updated by Glue Up in its own discretion from time to time. You should be responsible for reviewing the privacy policy for any changes to your rights and obligations.

We will process your Personal Data fairly and only for those purposes we have told you, for purposes permitted by you or as permitted by applicable laws or regulations. In addition, you may object to certain types of processing as expressly permitted by applicable laws or regulations.

If you provide us with Personal Data about another person, you confirm that you have obtained their consent to the processing and transferring of their Personal Data to us and that you have informed them of our identity and the purposes (as set out above) for which their Personal Data will be processed and used by us. 

Cookies

We use cookies to distinguish users and to improve our Website. Please read our Cookies Policy at http://hkproptech.org/en/cookie-policy for more cookies information.

Direct Marketing

We intend to use your name, mailing address, facsimile number, telephone numbers and email address for direct marketing purposes to send you information, newsletters and other materials about us and event invitations. We will not use your Personal Data for direct marketing without your consent (or indication of no objection). If you consider this use of your Personal Data unacceptable, please indicate your objection clearly by emailing us at enquiries@hkproptech.org. However, by doing so, you acknowledge this will limit our ability to provide the best possible services to you.

We intend to display your photograph, name, company and contact details (telephone numbers and email address) on the members’ area at https://www.hkproptech.org. Only HKPTA members will have access to the members’ area. Other HKPTA members may view your Personal Data and use them to contact you for purposes including direct marketing. We will not display your Personal Data without your consent (or indication of no objection). If you consider this use of your Personal Data unacceptable, please indicate your objection clearly by emailing to us at enquiries@hkproptech.org.

At any stage thereafter you may choose not to receive any or all of our promotional or marketing materials of us and event invitations (whether in the form of email or mailings). You may do this by again by contacting us at enquiries@hkproptech.org.

We may also share your Personal Data with our business partners or other HKPTA members for marketing purposes or we may send you information about other organisations’ goods and services. We, our business partners and other HKPTA members may contact you by mail, telephone, fax, e-mail or other electronic messaging service with offers of goods and services or information that may be of interest to you. By providing us with your postal address, fax number, telephone numbers or email address, you consent to being contacted by these methods for these purposes.

If you do not want us to share your Personal Data with our business partners and/or other HKPTA members, kindly send an email to enquiries@hkproptech.org stating your desire for us not to share your Personal Data for the purposes listed in the above paragraph.  

Transfer or Disclosure of Personal Data

We will never sell your Personal Data to any third party.

We will not transfer your Personal Data to third parties without your consent except the specific classes of data transferees listed in this paragraph. Personal Data collected and held by us will be kept confidential, but where disclosure is necessary for us to (a) comply with legal or regulatory obligations or requirements, (b) provide services to you, or (c) carry out the original purposes or a directly related purpose specified above, for which the Personal Data were collected, those Personal Data may be provided to the following parties (whether within or outside Hong Kong):

• staff or other members of HKPTA as well as our business partners such as other associations, universities, start-up accelerator programmes (see “Direct Marketing” above);
• competent court of law, law enforcement agency, the Office of the Communications Authority or other governmental, statutory or regulatory authority, institution or organization; or
• any person you have authorised to interact with us on your behalf.

Some of the persons to whom we disclose Personal Data may be situated outside Hong Kong. As such, the collected Personal Data may be transmitted to and stored in the data centres of third party data storage provider(s) within or outside of Hong Kong. 

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 the 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 taking legal action against you. 

Access, Correction and Queries

You are entitled to ask for a copy of the Personal Data we hold about you and to have any inaccuracies in your Personal Data corrected. If you wish to access or correct your Personal Data or if you have any queries about how we use your Personal Data or about this Policy, please contact the Board Members of Hong Kong PropTech Association Limited at enquiries@hkproptech.org.

When you request access to or correction to your Personal Data, we may need to take measures to verify your identity. We reserve the right to charge a reasonable fee for complying with your data access request.

For quality control and training purposes, we may also monitor or record your communications with us.

Retention of Data

We will keep your Personal Data for as long as necessary to fulfil the purpose for which the Personal Data was collected and for as long as we are no longer obliged to retain such Personal Data by law or regulation. We will destroy any of your Personal Data that we no longer require as soon as practicable. 

We will not retain your personal data if you request us to terminate your membership with HKPTA. In the case of termination, we will erase your personal data as soon as practicable after we are no longer obliged to retain such data by law.

Security

We take appropriate measures to ensure that the Personal Data disclosed to us is kept secure, accurate and up to date and kept only for so long as is necessary for the purposes for which it is used or required to be kept by law or regulation.

Online purchases involving credit card are transacted via secure protocols. 

Protecting your Privacy

Whilst we take all reasonable steps to adequately protect and secure your Personal Data and to limit the uses of your Personal Data, we cannot guarantee that your Personal Data will remain constantly secure due to the open nature of the internet. There is always a possibility that your Personal Data could be lost due to technical problems or stolen from our databases by malicious computer users. We will not be held responsible for any theft, loss of, damage or unauthorized access of any data or communications attributable to factors beyond our control. By using our Website, you acknowledge that you understand and agree to assume these risks.

Our Website links to a wide variety of other websites and they may display advertisements from third parties’ websites.  We do not endorse the products or services of such third parties.  We are not responsible for the content or the privacy policies of third party websites and third party advertisers, nor for the way in which information about their users is treated. In particular, unless expressly stated, we are not agents for these websites or advertisers, nor are we authorised to make representations on their behalf. 

Governing Law 

This Policy and your use of the Website shall be governed in all respects by the laws of the Hong Kong Special Administrative Region of the People’s Republic of China. Any dispute, controversy, difference or claim arising out of or relating to this Policy, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

Miscellaneous

Nothing in this Policy shall limit your rights under the applicable laws.

The provisions of this Policy shall be severable, and if any provision, or part-provision, of this Policy shall be held or declared to be illegal, invalid, or unenforceable, such illegality, invalidity, or unenforceability shall not affect any other provision, or part-provision, of this Policy, and the remainder of this Policy, disregarding such illegal, invalid or unenforceable provision, or part-provision, shall continue in full force and effect as through such illegal, invalid, or unenforceable provision, or part-provision, had not been contained in this Policy.
 

Appendix

Mainland China

This section applies (in addition to the general Privacy Policy) to the processing of personal information of data subjects staying within the mainland People’s Republic of China. Individuals located in Mainland China may have certain rights relating to their Personal Information that is not otherwise unavailable in other regions or countries. HKQAA respects each data subject rights and shall all times protect your Personal Information in accordance with the applicable laws.

Personal Information. In this Section, Personal Information means any type of information (recorded via electronic means or otherwise) associated with an identified or identifiable natural person, but excluding information after anonymisation handling. Personal Information may include Sensitive Personal Information (defined below).

Consent. We will collect, store, use, process, transmit, provide, disclose or delete your Personal Information in accordance with this Privacy Policy and the applicable sections. If the applicable Mainland data protection laws and regulations require us to obtain separate consent, we will only process your Personal Information upon obtaining the requisite consent.

Sensitive Personal Information. We will collect and handle sensitive Personal Information, for example your credit or debit card information, account information for the processing of your payment. Your visit and activities on our Website, collected through cookies or other tracking technologies. It is necessary for you to provide us with such Sensitive Personal Information for the purpose of providing Services to you. If you do not provide us with your consent, your user experience and use of our Website may be limited.

Storing your Personal Information. Your Personal Information shall be stored in Hong Kong as well in other regions or countries. If applicable Mainland Chinese laws require us to provide you with further notice and obtain your separate consent for the cross-border transfer, we will further provide such notice and obtain your separate consent. 

You can exercise any of the rights above by contacting us at email address enquiries@hkproptech.org.