This statement is made by the Eagle Property Management (CP) Limited (together with Three Garden Road, “we”, “us” or “our”), in accordance with the Hong Kong Personal Data (Privacy) Ordinance and where applicable, the European General Data Protection Regulation ("GDPR"). We are committed to ensuring that all Personal Data (as defined below) are handled in accordance with the Ordinance and where applicable, in accordance with the GDPR. We respect the privacy of every individual whose Personal Data we handle and are committed to protecting your privacy and ensuring security for your Personal Data.
This statement explains the types of Personal Data we collect, how and for what purpose we use that information, who we share it with, and how we protect that information.
For the purposes of applicable data protection law, the data user is Eagle Property Management (CP) Limited.
We will process Personal Data about you in your capacity as an investor and/or a visitor to this website ("Website").
“Personal Data” means any personal information which on its own or combined with other information relates to and identifies (directly or indirectly) a living individual.
We believe it is important that you know what Personal Data we collect, what we use it for and on what basis. It's also important we set out the rights you have in relation to your Personal Data. Where applicable, you have the right to know what information we hold and to request copies of that information, as well as object to us holding such information, request that any inaccurate information we may hold about you is rectified, and in certain circumstances request that we delete such information.
Personal Data we may collect and use including your contact details and identity information (for instance, your name, address, e-mail address, telephone and fax numbers, company name, industry, occupation)
We collect this information when you provide it to us, or we create it ourselves or collect it from other organisations.
You may provide information to us when you:
We may receive information about you that you authorise third parties (such as credit reference agencies, fraud detection agencies, and registration or stockbroking industry exchanges) to provide to us.
We also may obtain information about you from third-party sources (e.g. publically available sources) and service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.
Different rules apply to the processing of data concerning race, ethnic origin, political opinions or beliefs, religious or other beliefs, trade union membership, physical or mental health, sexual life or orientation and any offences committed and sentences or court proceedings relating to actual or potential offences. This is known as sensitive or special categories of data.
During our relationship with you, we should not require any such sensitive or special categories of data. Therefore please do not send us such data.
We will have a specific purpose to collect, store and use your Personal Data. The Personal Data we collect will depend on our relationship with you.
We process your Personal Data for the following purposes:
The processing of your Personal Data is necessary for our legitimate interests when we process your Personal Data to provide our services to you; to verify your identity, to contact you when necessary or appropriate, to provide customer support (including to respond to your comments and questions), to safeguard our legal rights and interests, and to seek and receive advice from our professional advisers, including accountants, lawyers and other consultants.
Where necessary to comply with applicable laws, we will seek your consent to process your Personal Data.
In some cases it will be necessary for us to process your Personal Data in order to comply with our legal and regulatory obligations, for example where we process your Personal Data to comply with our regulatory and legal obligations, including assessing and managing risk.
Where we process your Personal Data to provide a product or service, we do so because it is necessary in order for us to provide such product and service.
Refusal to provide your information may make it impossible for us to provide the products, services or information requested.
You have the right to ascertain whether we hold your Personal Data, to obtain a copy of your Personal Data, and to rectify any Personal Data that is incomplete or inaccurate. You may also request that we inform you of the type of Personal Data held by Eagle Property Management (CP) Limited.
Requests for access and correction or for information regarding policies and practices and kinds of data should be addressed in writing to:
Data Protection Officer, Suites 806-7, ICBC Tower, Three Garden Road, Central, Hong Kong
A reasonable fee may be charged to offset our administrative and actual costs in complying with your access requests.
For individuals in the EU you have additional rights (where applicable) - for further information please see the "Your rights under the GDPR" section below.
We may share your Personal Data with third parties in the following circumstances:
We will only provide our service providers with Personal Data which is necessary for them to perform their services to us, assist us with the provision of our services, or respond to your enquiries or complaints, and we require them not to use your Personal Data for any other purpose. We will use reasonable commercial efforts to ensure that all our service providers keep your Personal Data secure.
Your Personal Data may be transferred to and processed by us, our affiliates and third parties which may be located in countries outside the European Union and /or the European Economic Area ("EEA"). In particular, Personal Data we collect about you will be stored in Hong Kong. We will take all steps that are reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Notice as well as applicable data protection laws, including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA.
For the purposes of applicable data protection law, the data controller is Eagle Property Management (CP) Limited.
If you are in the EU and the processing of your Personal Data is subject to the GDPR, then you have the following rights (if applicable):
You can make a request to exercise any of these rights in relation to your Personal Data by sending the request in writing to Data Protection Officer, Suites 806-7, ICBC Tower, Three Garden Road, Central, Hong Kong.
You also have the right to make a complaint at any time with your national data protection authority or other public authority governing the protection of your Personal Data.
While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.
The period for which we retain Personal Data will vary depending on what purpose it has been collected for, as well as the requirements of any applicable law or regulation. We will only retain your Personal Data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable law. When we no longer need to use Personal Data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.
We will not knowingly collect Personal Data from children under the age of 16 years. If you are under the age of 18, consent from your parent or guardian is required before you provide us with any personal data.