Privacy Policy‍

1. Privacy Policy Statement

This Privacy Policy Statement sets out the privacy policy and practices of WTP Investment (Hong Kong) Limited and its subsidiaries, affiliates and associated companies (collectively “we”, “us”, “our”), for the purposes of complying with the requirements of applicable personal data protection laws and regulations for personal data collected through our website(s). We are committed to protecting your privacy and the confidentiality of your personal data that we process in connection with the services, products, events, facilities, promotions or marketing or other activities we offer to clients and individuals using our website(s). This Privacy Policy Statement describes how we collect, use, handle and protect your personal data, which is any information that is capable of identifying an individual. When an individual provides personal data to us, they are agreeing to be governed by this Privacy Policy Statement. The collection of your personal data will also be subject to our Personal Information Collection Statement.

2. Categories of Personal Data which We Collect

The categories of personal data we may collect and use about you will vary depending on your level of engagement with us. We may collect the information about the devices you use to interact with our website(s), which may include internet protocol addresses (“IP addresses”), device identifiers, web browser, and browsing information collected through cookies and other similar technologies on our website(s). The information automatically collected will be associated with any personal data you have provided. The categories of Personal Data may include (without limitation) the following:

• your personal information (e.g. your name, gender, date of birth, passport or other personally identifiable number);
• your contact information (e.g. telephone numbers, mailing addresses, email addresses, and fax numbers);
• your business information (e.g. company name, business title, and associated contact information);
• your interests, personal preferences, or comments;
• your comments and responses to market surveys, contests, and promotional offers conducted by us or on our behalf; and/or
• information when you use our websites or other services or products (e.g. behavioral information, location information, browser details, IP addresses).

You may provide us voluntarily with information in order to use, or participate in, certain features of our services, such as registering for an account; submitting a survey response; requesting support or assistance; signing up for or registering an activity or a loyalty program; making a donation; making an enquiry or contacting us etc.

Certain personal data are required for specific services or products and if you fail to supply such personal data as requested for the specific service or product, we may not be able to deliver you the service or product.

Our services are not designed for or targeted at, children younger than 18 years old, and we do not intentionally collect or maintain personal data about anyone under the age of 18. If you are under 18 years old, please ask your parent or guardian to interact with us on your behalf.

3. The Purpose and Basis of Our Use of Your Personal Data

We may collect personal data directly from you when you:

• visit our website(s) ;
• engage or enquire about the services, products, events, facilities, promotions or marketing or other activities offered by us and/or third parties;
• call us, email us or contact us via social media;
• provide feedback; or
• make a complaint.

We may also indirectly obtain personal data of you from third parties when you:

• visit a third-party site that links to our website(s) or an estate agent website and request information about one of our products, services or property developments;
• engage with other property, investment or finance companies that we have arrangements with; or
• engage with solicitors, financial advisers, surveyors, and estate agents involved in your search for, properties or products or services from us

Our use of your personal data depends on how and where you interact with us. We may require the collection of personal data for one or more of the following purposes:

• to operate, and provide support to your use of, our website(s);
• to process your application(s) or request(s) for services, products, facilities or privileges;
• to verify your identity and the accuracy of certain other personal data that you have provided;
• to provide services, products, facilities or privileges to you, and handle the necessary arrangements and matters (including legal, administrative and other matters) for maintaining and managing such services, products, facilities or privileges, including the operation, maintenance and administration of your membership in or the processing of your exercise of any rights under our website(s);
• to communicate with you and for overall relationship management and maintenance;
• to investigate, handle and respond to any comments, messages, requests, enquiries, complaints or incidents made by you, made against you or involving you in any manner;
• to conduct survey, research and analysis to facilitate the provision of services, products, facilities, privileges, activities or events to you or to your customers generally;
• to market and promote services, products and facilities with your consent or where otherwise permitted by law;
• to comply with any obligations or requirements for using or disclosing personal data by any law or regulations, or by any governmental agency, regulatory authority, law enforcement agency, court or judicial body, whether in or outside of Hong Kong existing currently or in the future; and
• as otherwise permitted by applicable laws.

4. Link to Other Websites

We may provide links to third-party websites or information as a service to our users. This Privacy Policy Statement does not cover third-party websites or services that we link to, nor the collection and processing of your personal data by those applications and devices. Linked sites and those applications and devices may have their own privacy policies and terms of use which you should review. We do not endorse or sponsor, nor are we responsible for, any third-party websites/applications/devices, the content or information contained therein, or their privacy practices.

5. People Who May Process Your Personal Data

Your personal data may be received and processed us of and/or the following categories of third parties, located within or outside Hong Kong:

• any member of Wing Tai Properties Limited, its subsidiaries, affiliates and associated companies (“Wing Tai Properties”);
• any agent, contractor, or third-party service provider who provides administrative, marketing, research, distribution, data processing, or other services;
• any person, government, regulatory or law enforcement authority or administrative organisation;
• any person under a duty of confidentiality to any member of Wing Tai Properties;
• any actual or proposed assignee or purchaser of all or any part of the business and/or asset of Wing Tai Properties; and/or

We maintain processes designed to ensure that such third-parties and other members of Wing Tai Properties will provide the same or equal protection of user data as stated in this Privacy Policy Statement to protect the confidentiality, availability and integrity of your personal data.

6. Retaining Your Personal Data

Your personal data will be stored securely in our system and all practical steps will be taken to ensure that your personal data will not be kept longer than is necessary for fulfilling the purpose of collection (including any directly related purpose). We retain personal data if it is necessary to support our interaction with you. We may also retain personal data for longer than the duration of the business relationship for legal and/or regulatory reasons, or for analysis or record-keeping. For requests for access, corrections or deletion, please refer to the “Your Rights” section of this Privacy Policy Statement.

7. Direct Marketing

Where you agree (or where otherwise permitted by law), we will send you information about any new services, products, events, facilities, promotions or marketing or other activities which may be of interest to you, according to available methods of communication. Even after you agree and ask us to send you information, you can always unsubscribe or withdraw your consent at any time, and we shall stop sending you materials by way of direct marketing.

8. Data Security

We endeavour to keep your personal data secure. We have set up technical and organizational systems and processes, including encryption over the internet to prevent unauthorized access or disclosure of your personal data. We also check that any third parties that we deal with maintain reasonable measures to safeguard the security of the personal data they process.

9. Your Rights

You have certain rights regarding how we use and keep your personal data. These include:

• A right to be informed whether and how we process your data.
• A right to withdraw your consent at any time if your personal data is processed on the basis of your consent. The withdrawal of your consent does not affect the lawfulness of processing based on consent before its withdrawal.
• Where permitted by law, you may have the right to request access to your personal data for the purposes of reviewing, modifying or requesting deletion of the data.
• You may have a right to request a copy of your personal data and to have any inaccuracies in that data corrected.
• You have a right to lodge a complaint with a supervisory authority. However, if you have a complaint about our handling of your personal data, please contact us as we would appreciate the opportunity to deal with your concerns before you approach a regulator.

You may also have the right, in certain circumstances to:

• object to the processing of your personal data;
• be provided with a copy of any personal data that we hold about you. The exceptions to this right include if the information is legally privileged or the information can reveal personal data about another person;
• require us to delete your personal data without undue delay;
• “restrict” our use of your personal data, for example if you want us to establish its accuracy or the reason for processing it;
• object to decisions based exclusively on the automated processing of your personal data;
• require your personal data which we have obtained by automated means to be provided to you in a machine-readable format so that they can be ported to a replacement service provider.

You can exercise your rights by contacting us using the contact details on the website. If a fee is necessary, we will inform you of the fee before processing your request.

10. Changes to this Privacy Policy Statement

We may revise this Privacy Policy Statement from time to time. All versions of the Privacy Policy Statement are dated with the effective date of that version of the Privacy Policy Statement. Our processing of personal data we collected about you will be governed by the most recent Privacy Policy Statement in effect.

If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.

This Privacy Policy Statement was last updated in Nov 2023.