This Statement is made by Link Asset Management Limited (“Link Asset Management
”) as manager of Link REIT and Link Properties Limited (collectively “we
” or “us
”), in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region ('the PDPO'
). This Statement intends to notify you why your personal data is collected, how it will be used, to whom the personal data will be transferred and to whom data access requests are to be addressed.Types of Personal Data Held
We hold four broad categories of personal data, namely customers’ and tenants’ personal data, business associates’ personal data, employment-related personal data and website users’ personal data.Collection - Why We Collect Your Data
From time to time, we may collect your personal data to provide our services to you and in an effort to improve your customer experience. You are not obliged to provide your personal data to us but if you do not, we may not be able to provide you with some of the information, materials, services and/or products of Link Asset Management and/or Link Properties Limited.
We will indicate in the relevant forms or applications if the required personal data is for obligatory or voluntary purposes. If personal data is to be used for an obligatory purpose, you MUST provide your personal data to us if you want us to provide the service for which you are applying. If personal data is only to be used for a voluntary purpose, you can tell us not to use your personal data for that purpose and we will refrain from doing so.
If you are under the age of 13, you must ask your parent or guardian before providing any personal data to us.Use - How Your Data May Be Used
Personal data held by us will be used:
1. to facilitate the daily administration and operation of our business and improvement to our services and products for customers and tenants;
2. for the application, administration, continuation and termination of leases, tenancies and licenses of Link REIT’s shopping centers, fresh markets, cooked food stalls and car parks (“Link Premises
”) and the services thereat;
3. for identity verification, matching and/or records and for maintaining communication with our customers and tenants and updating of their profile;
4. for handling enquiries and feedbacks for better services to tenants and shoppers who patronize Link Premises;
5. for internal statistical and analysis purposes; and
6. to update our tenants and shoppers with news and events at Link Premises, and the latest developments about Link REIT.Use of Personal Data in Direct Marketing
We intend to use your personal data in direct marketing, and we may not so use your personal data unless we have received your consent (which includes an indication of no objection to the intended use).
We would like to use your name and contact details (such as telephone number, email address and/or correspondence address) for marketing the following services, products and promotional events through various communication means such as direct-mail, email, telephone, SMS, printed matter, newsletter, brochure and leaflets. The services, products and promotional events include:
1 offer of lettable shopping spaces, fresh market spaces, and car-parks at Link Premises by us, and leasing promotion, or other incentive programs thereat for our tenants, shoppers, and car park users;
2 events in relation to corporate social responsibility programs of Link REIT such as (without limitation) Link Sports Academy and Link Together Initiatives and similar sustainability/community engagement/charity initiatives at Link Premises;
3 products and services offered by our co-branding partners, service providers, community engagement partners and tenants of Link Asset Management and/or Link Properties Limited at any of Link Premises;
4 promotions on food, wine and beverages, or entertainment, leisure, and sports or similar events at Link Premises;
5 our asset enhancement initiatives and other initiatives by Link Asset Management at Link Premises for shopping environment improvements; and
6 other services, products and events relating to our retail facilities, business and activities in Link Premises.If you object to our use of your personal data for the relevant direct marketing purposes, please TICK THE BOX indicating your OBJECTION to receiving direct marketing materials in the relevant part of the form. If you do not tick the box, by signing the form you agree that we may use your personal data for the relevant direct marketing purposes.
You may, at any time without charge, choose to opt-out from us using your personal data for direct marketing by writing to us at Link Asset Management Limited, 33/F, AXA Tower, Landmark East, 100 How Ming Street, Kwun Tong, Kowloon, Hong Kong (Attention: Corporate Data Privacy Officer), or by email to email@example.com.
Transfer of Your Personal Data
Personal data held by us will be kept confidential but we may disclose/transfer such data to the following parties (whether within or outside the Hong Kong Special Administrative Region) for the purposes set out in this Statement:
1. the entities comprising all the special purpose vehicles of Link REIT and the subsidiary (if any) of Link Asset Management and/or Link Properties Limited in connection with the operation of our business and activities at Link Premises;
2. professional advisors, service providers or contractors of Link Asset Management and/or Link Properties Limited providing property management services, letting or licensing services at Link Premises;
3. any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment, content, information or other marketing and promotional services to us in connection with the operation of our business and activities at or in relation to Link Premises;
4. any person under a duty of confidentiality to us or who has undertaken to keep your personal data confidential and use them in strict compliance with the requirements of the PDPO; and
5. any person to whom we are under an obligation under law to make disclosure.
Personal Data Security
We strive at all times to ensure that your personal data will be protected against unauthorized or accidental access, processing, erasure or other use. We have implemented appropriate physical, electronic and managerial measures to safeguard and secure your personal data.
Retention of Data
We will keep your personal data for a reasonable time to fulfill the purpose for which the data was collected or comply with the relevant rules, regulations and laws of Hong Kong. Personal data which is no longer required will be destroyed.
Your personal data will be kept in the office of Link Asset Management and/or Link Properties Limited or by the service providers engaged by Link Asset Management and/or Link Properties Limited and are accessible only to our authorized employees and service providers.
Data Access/Correction Requests
Under the PDPO, any individual has the right to request access to and correction of his or her personal data held by us. In accordance with the terms of the PDPO, Link Asset Management or Link Properties Limited has the right to charge a reasonable fee for the processing of any data access request.
If you wish to access or correct your personal data held by us, please send your request to:
Corporate Data Privacy Officer
Link Asset Management Limited
33/F, AXA Tower, Landmark East
100 How Ming Street
or by e-mail: PersonalDataPrivacy@linkreit.com
In case of discrepancies between the English and Chinese versions of this Statement, the English version shall apply and prevail.
NOTE: This Personal Information Collection Statement is subject to change.