General Statement of Policy
1. 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'). We are committed to ensuring that your personal data are handled in accordance with the provisions of the PDPO. We collect and use your personal data to provide you with better customer services and products.
2. We collect adequate, but not excessive, personal data by lawful and fair means only for lawful purposes related to our business and activities.
3. We take all reasonably practicable steps to ensure that personal data collected or retained are accurate, having regard to the purposes for which they are to be used.
4. We take all reasonably practicable steps to ensure that the personal data are not kept longer than is necessary for the purposes for which they are to be used.
5. We use the personal data collected only for the purposes or directly related purposes for which the data were to be used at the time of collection, unless the individual concerned has given express consent for a change of use or such use is permitted by law.
6. We take all reasonably practicable steps to ensure that personal data are protected against unauthorised or accidental access, processing, erasure or other use.
7. We take all reasonably practicable steps to ensure that a person can be informed of the kinds of personal data that we hold and the purposes for which the data are to be used.
8. We permit persons to request access to and/or correction of personal data held by us which they are the data subjects. We process any such access/correction requests in a manner permitted or required by law.
9. All our staff are required to observe our security and confidentiality obligations.
Collection - Why We Collect Your Data
10. 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.
11. We will indicate in the relevant forms or applications if the required personal data are 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, you are not obliged to provide us with such personal data.
12. 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
13. Personal data held by us will be used:
(a) 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”);
(b) for the application, administration, continuation and termination of leases, tenancies and licences 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”);
(c) for identity verification, matching and/or records and for maintaining communication with our customers and Tenants and updating of their profile;
(d) for handling enquiries and feedback for better services to Tenants and shoppers who patronize Link Premises;
(e) for internal statistical and analysis purposes;
(f) to update our customers and Tenants with news and events at Link Premises and the latest developments about Link / Link REIT;
(g) 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;
(h) 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;
(i) 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.
Personal Data Security
14. We strive at all times to ensure that your personal data will be protected against unauthorised or accidental access, processing, erasure or other use. We maintain this commitment to data security by implementing 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.
15. Your visit to this website may be recorded for analysing the number of visitors to the website and general usage patterns. Some of the information will be gathered through the use of "cookies". "Cookies" are small bits of information that are automatically stored on a user's web browser in his/her computer that can be retrieved by this website. Cookies can make websites more useful by storing information about your preferences on particular websites, thus enabling website owners to provide customised and personalised services or products for users. The information collected by "cookies" is anonymous aggregated research data and contains no personal information such as name or domain name server address information that will enable anyone to contact you via telephone, email or any other means. Most browsers are initially set to accept cookies. If you prefer, you can set your browser to disable cookies or inform you when they are set. However, by disabling cookies, you may not be able to take full advantage of our website.
Use of Personal Data in Direct Marketing
16. We may from time to time collect personal data from you when you use this website and we intend to use your personal data in direct marketing. 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).
17. 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:
(a) offer of lettable shopping spaces, fresh market spaces, and car-parks at Link Premises and leasing promotion, or other incentive programmes thereat for our Tenants, shoppers, and car park users;
(b) events in relation to corporate social responsibility programmes of Link REIT such as (without limitation) Link Together Initiatives and similar sustainability/community engagement/charity initiatives at Link Premises;
(c) 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;
(d) promotions on food, wine and beverages, or entertainment, leisure, and sports or similar events at Link Premises;
(e) our asset enhancement initiatives and other initiatives at Link Premises for shopping environment improvements; and
(f) other services, products and events relating to our retail facilities, business and activities in Link Premises.
18. If you object to our use of your personal data for direct marketing purposes, please see paragraph 21 below.
Retention of Data
19. We will keep your personal data for a reasonable time to fulfil 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.
Disclosure / Transfer of Personal Data
20. 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 PICS:
(a) 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 and / or Link in connection with the operation of our business as well as events, services, and / or products at Link Premises;
(b) professional advisors, service providers or contractors of Link, Link Asset Management and / or Link Properties Limited providing property management services, event organization services or licensing services at Link Premises;
(c) 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, events, services or products at and activities or in relation to Link Premises;
(d) 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);
(e) any government, law enforcement or administrative organization;
(f) any person to whom we are under an obligation under law to make disclosure;
(g) 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
(h) 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.
Contact Details for our Corporate Data Privacy Officer
21. If you wish to access or correct your personal data held by us or if you do not wish or opt of direct marketing or that you have questions on this PPS,. please send your request to:
Corporate Data Privacy Officer
Link Asset Management Limited
20/F., Tower 1, The Quayside
77 Hoi Bun Road
or by email: PersonalDataPrivacy@linkreit.com
22. In accordance with the PDPO, we may charge data subjects reasonable charges incurred in relation to administering and complying with their data access or correction requests.
23. Links on this website may link to websites maintained by other third parties. These third parties may have their own privacy policies which might not be bound by this policy. We make no representation or warranty of the content on such websites. Access and use of such other websites are at your own risk and subject to the terms and conditions applicable to such websites.
24. In case of discrepancies between the English and Chinese versions of this data privacy statement, the English version shall apply and prevail.