This Statement is made by Link Asset Management Limited ("Link Asset Management") as manager of Link Real Estate Investment Trust (“Link REIT”) and all special purpose vehicles under the same including but not limited to Link Properties Limited (collectively "Link", we", "our" 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, Link Asset Management and/or Link Properties Limited.
We will indicate in the relevant forms or applications if the required personal data is obligatory or voluntary. If the supply of the personal data is obligatory, you MUST provide your personal data to us if you want us to provide the service for which you are applying. If the supply of personal data is voluntary purpose, you are not obliged to provide us with such personal data.
If you are under the age of 18, you must seek your parent or guardian’s consent before providing any personal data to us.
Use - How Your Data May Be Used
Personal data held by us will be used:
- to facilitate the daily administration and operation of our business and improvement to our services and products for customers and tenants (including their staff) (collectively “Tenants”);
- for the application, administration, continuation and termination of leases tenancies and licenses as well as services, events and products that are held, organised and / or provided by us or our partners at of Link REIT's shopping centers, fresh markets, cooked food stalls and car parks ("Link Premises");
- for identity verification, matching and/or records and for maintaining communication with our customers and Tenants and updating of their profile;
- for handling enquiries and feedbacks for better services to Tenants and shoppers who patronize Link Premises;
- for internal statistical and analysis purposes;
- to update our customers and Tenants with news and events at Link Premises and the latest developments about Link / Link REIT.
- matters relating to transfer or assignment of any Link Premises, or any part of Link’s right, business or asset in respect of Link’s Premises including but not limited to changes in business of or significant shareholding in Link or amalgamation of Link with another body;
- for making disclosure so required by law, regulation or court order of any jurisdiction and / or so requested by the government, regulatory or law enforcement authority or administrative organization within or outside Hong Kong Special Administration Region;
- for establishing legal claims or defences; obtaining legal advice; and / or exercising, defending and / or protecting the rights of properties of Link, Link’s affiliates and contractors, agents and third party service providers, including identifying contracting or bringing legal action against any person who may be interfering with such rights or properties (whether intentionally or otherwise) and / or whether any other third party may be harmed or property of any third party may be damaged by such interference.
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:
- offer of lettable shopping spaces, fresh market spaces, and carparks at Link Premises by us, and leasing promotion, or other incentive programs thereat for our Tenants, shoppers, and car park users;
- events in relation to corporate social responsibility programs of Link REIT such as (without limitation) Link Together Initiatives and similar sustainability/community engagement/chanty initiatives at Link Premises;
- 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;
- promotions on food, wine and beverages, or entertainment, leisure, and sports or similar events at Link Premises;
- our asset enhancement initiatives and other initiatives at Link Premises for shopping environment improvements; and
- other services, products and events relating to our retail facilities. business and activities in Link Premises.
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, 20/F., Tower 1, The Quayside, 77 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong (Attention: Corporate Data Privacy Officer), or by email to PersonalDataPrivacy@linkreit.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:
- 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;
- 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;
- 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, event, services or products and activities at or in relation to Link Premises;
- 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(including but not limited to accountants, legal advisors and other advisors);
- any government, law enforcement or administrative organization;
- any person to whom we are under an obligation under law to make disclosure;
- those parties who we consider it necessary to do so in order to protect and defend our rights and property, comply with applicable law, regulations, including but not limited to judicial proceedings, court orders or legal services; and
- any actual or potential assignee(s), transferee(s), successor(s) or purchaser(s) of all or any part of Link Premises or of all or any part of our right in any business or assets.
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.
Your personal data will be kept in the office of Link, Link Asset Management and / or Link Properties Limited or by agent, contractors or third party service providers engaged by us (whether in Hong Kong or overseas) and will be accessible only to our authorized employees and service providers on a “need-to-know” basis. However, we give no warranty against third parties hacking into the data.
Unless prevented by law, in the event that Link provides your personal data to agent, contractors or third party service providers they will be placed under a duty of confidentiality to Link and will be required to use your personal data consistent with the agreements entered with Link and in accordance with this PPS and in compliance with the PDPO. They will be required to ensure adequate security of your personal data and will be required not to keep your personal data longer than necessary.
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 am 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 , Link Asset Management or Link Properties Limited has the right to charge a reasonable fee for the processing of any data access or correction request.
If you wish to access or correct your persona data held by us, please send your request to:
Corporate Data Privacy Officer
Link Asset Management Limited, 20/F., Tower 1, The Quayside, 77 Hoi Bun Road, Kwun Tong, Kowloon, Hong Kong
or by email: PersonalDataPrivacy@linkreit.com
Please read the below terms if you provide your personal data for the use of our services in Mainland China.
Cross-border data transfer
Provision of personal data (i.e. name, email address, company name) to us is obligatory should you subscribe to our email alerts or any contents thereto.
Since the email alerts are sent from Link Asset Management in Hong Kong, transfer of your personal data to Hong Kong is necessary for us to send you email alerts on your interested section(s). During such cross-border data transfer and storage, we are committed to protecting the security of your personal data. If you object to our cross-border transfer of your personal data, we may not be able to provide you with the services for the relevant purposes listed above.
Other than the rights to request access and correction, in accordance with the Personal Information Protection Law of the People’s Republic of China, you will also have the rights to copy, supplement and deletion of your personal data held by us.
To Change the scope of consent
We respect your right to know and right of decision on the processing of your personal data. You can change the scope of your consent to our processing of your personal data at any time, however this might affect your use of our services. If you wish to access, copy, correct, supplement or delete your personal data in relations to email alerts subscription held by us or to change the scope of your consent, please send your request to: 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.