Sinic Holdings (Group) Company Limited, its subsidiaries and affiliates (collectively referred to as the “Group”, “we”, “our” or “us”) have created this Statement to demonstrate our firm commitment to protect your privacy and to provide you with information in relation to the personal data the Group may collect from you (“Personal Data”) as required by local laws and regulations and those of other applicable laws and regulations in the different jurisdictions that the Group may collect, use or transfer your Personal Data.
The principal activities of the Group include property development, property investment, hotel operations and management, car park operations and facilities management, gaming and related operations and securities and financial product investments.
The Group may collect your Personal Data from time to time in its dealing with you, for example, when you complete forms and questionnaires or make enquiries in connection with the provision of products, services, activities or facilities by the Group at your request.
Depending on the purpose of the collection, the Personal Data the Group may collect from you includes but is not limited to your name, address, contact numbers, and email address. Personal Data may also relate to other persons relevant to the information, products, services, activities or facilities you have requested. The provision of Personal Data or any information is voluntary and we may not use your Personal Data unless with your consent. However, if you do not provide the mandatory data required, we may not be able to process your enquiries or requests or provide you with the requested products, services, activities or facilities.
We may use your Personal Data collected by us for one or more of the following purposes from time to time: providing and processing your requests for our products, services, activities or facilities; providing you with access to all parts of our website; direct marketing of products, services, activities or facilities by the Group and our related entities or third parties including business associations in connection with our operations (you may elect to opt out from receiving any marketing materials - see below); conducting market research, surveys and analysis; billing and debt collection; dealing with your suggestions, enquiries or complaints; communicating with you generally; preventing, detecting or investigating suspicious or illegal activities; and meeting legal and regulatory requirements and/or making disclosure when required by any law, court order, direction, code or guideline applicable in or outside Hong Kong.
Your Personal Data held by the Group will be kept confidential. Except with your prior consent or as required by law, we will not transfer or disclose your Personal Data to any third party except to our subsidiaries, affiliates and/or business associations; our service providers, data processors or advisors in connection with our operations and our provision of your requested products, services, activities or facilities; and those as required by any applicable laws, rules or regulations, subject to a duty of confidentiality.
We endeavour to deal only with responsible third parties but as we have no control over the acts of such third parties for example the data processors, the privacy protection stated in this Statement ceases to apply to any information which is disclosed to such third parties in accordance with this Statement and we assume no responsibility for the privacy protection provided by such third parties.
If you wish to exercise any such right, please contact our Personal Data Privacy Officer at firstname.lastname@example.org or by post to “Suites 1016, 10/F, Two Pacific Place, 88 Queensway, Hong Kong”. This Statement may be revised from time to time. If there is any inconsistency between this Statement and the Policy, the Policy shall prevail.
Please read the Statement and the Policy carefully before submitting any Personal Data to us. If, after reviewing the Statement and the Policy, you have any privacy questions or concerns or would like to exercise your rights under the Statement and the Policy, please send your request and/or question in writing to our Personal Data Privacy Officer at email@example.comI or by post to the following address:
Sinic Holdings (Group) Company Limited
Suite 1016, 10/F
Two Pacific Place
Please allow us 30 days to process your request.
Except for direct marketing, use of our website signifies your consent to the Statement and the Policy, including the collection and use of your Personal Data as described in the Statement and the Policy. We reserve the right to change, modify or amend the Statement and the Policy from time to time. Any changes will be included in the latest Statement and the latest Policy published on our website so that you will always understand our current practices with respect to the information we gather, how we might use that information and disclose that information to third parties. Any changes to the Statement and the Policy will become effective upon its posting on our website. Continued access and use of our website and/or services following any changes also constitutes your acceptance of the revised Statement and the revised Policy then in effect. Nevertheless, we will seek your consent to any substantial changes if required by relevant laws and regulations or any changes made to the use of Personal Data you provided to us in a manner different from that stated at the time of collection.
1. Purposes of collecting your Personal Data
We limit the collection, use and retention of your Personal Data to the specific information we need. We might use your Personal Data collected from you or gathered from our website, strictly for the performance of our agreements with you and for our legitimate purposes such as:
Unless you have expressly opted not to participate when providing us with your Personal Data, we may share these with third parties including our business associations, service providers, data processors or advisors in connection with our operations and our provision of your requested products, services, activities or facilities.
Where you have consented, we might also use your Personal Data for direct marketing purposes, for example, we may periodically contact you by post or via email and provide information about our special offers and promotions that may be of interest to you. If you have changed your mind in receiving such promotional materials, please let us know.
2. Personal Data we collect and how we use it
You are always offered options as to whether to provide your Personal Data to us and/or our business associations during our collection of your Personal Data. The provision of Personal Data or any information is voluntary and we may not use your Personal Data unless with your consent. However, if you do not provide the mandatory data required, we may not be able to process your enquiries or requests or provide you with the requested products, services, activities or facilities.
2.1 Anonymous browsing
Visitors to our website do soon an anonymous basis. We do not collect Personal Data from you unless you voluntarily and knowingly provide us, for example when you reach our website through our electronic direct mail, and/or when you are making inquiry through our website.
2.2 Our services
Our business includes but is not limited to property development, property investment, hotel operations and management, car park operations and facilities management, gaming and related operations and securities and financial product investments. We may ask for your Personal Data in connection with the provision of products, services, activities or facilities by the Group, including payment purposes.
2.3 Third party providers
The Statement and the Policy do not apply to our processing of your Personal Data on behalf of third party providers who may collect your Personal Data from you and provide it to us. In this situation, we would merely act as a data processor and thus you should review applicable third party providers’ privacy policies before submitting your Personal Data to them.
2.4 Fraudulent emails
Please note that we will never send you an email requesting your Personal Data, for example password, credit card number or passport, personal identity card or social security number. If you receive any suspicious emails that look like they are from us but ask for your Personal Data, it is likely a fraudulent email or ‘phishing’. We recommend that you do not reply to the email or click onto any links or pop-up messages and report to the local authorities which handle fraudulent emails. If you believe ‘phishers’ have gained access to your Personal Data or financial information, we recommend that you change your password(s), alert your credit card service provider and bank and review credit card and bank account statements to check for unauthorised charges.
2.5 Unsecure communication
It is important to note that all email communication is not secure. There is a risk inherent in the use of email. Please be aware of this and when requesting information or sending forms to us by email, or when using email or using any public computers/public Wifi, we recommend that you do not include any Personal Data or sensitive information including credit card details. Our email responses to you may not include any sensitive or confidential information. Please bear in mind that no security system or system of transmitting information over the internet is guaranteed to be secure.
3. Internal controls
The Statement and the Policy are updated as required to reflect any changes in applicable laws and developments in best practice procedures. Further, we limit the access to your Personal Data and only share your Personal Data with our internal staff who are directly involved in the process of providing quality service to you.
4. How we store and transmit Personal Data
All Personal Data gathered are stored in our secure server and all practicable steps have been taken to ensure that your Personal Data is protected against unauthorised or accidental access, disclosure or alteration and to keep such Personal Data up to date. However, we cannot be held responsible for unauthorised or accidental access which is beyond our control.
4.1 Our databases and operating & marketing systems
We may store your Personal Data in our databases used by operation and marketing systems. These systems, owned and managed by us or by selected third party vendors, are carefully selected to secure your Personal Data. Laws and regulations applicable to Personal Data protection vary by country, therefore we may put in place additional measures that vary depending on the applicable legal requirements.
4.2 Secure transmission and storage of data
We treat all the Personal Data that you provide to us as confidential information. We use an industry standard for encryption over the internet to protect your Personal Data.
4.3 Data transmission across international borders
As a global company, we endeavour to provide you with the outstanding services. To achieve this goal, we have established a global network comprised of properties, offices, trusted service providers, and trained associates in locations where we operate. The nature of our business and our operations require us to transfer your Personal Data to other Group companies, properties, centers of operations, data centers, or service providers that may be located in countries outside of your own for the purposes mentioned in the Statement and the Policy. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, we will take appropriate steps to ensure that your Personal Data is protected and handled as described in the Statement and the Policy. Therefore, in addition to the implementation of the Statement and the Policy, we will implement, where necessary appropriate measures, including contractual clauses, to secure the transfer of your Personal Data to recipients (which may be our internal or external parties) located in a country with a level of protection which may be different from the one existing in the country in which your Personal Data is collected.
Please note that we endeavor to deal only with responsible third parties, but we have no control over the acts of these third parties. The Statement and the Policy cease to apply to any information which is disclosed to such third parties in accordance with the Statement and the Policy and we assume no responsibility for the privacy protection provided by such third parties.
4.4 Disclosure of information to third parties
In addition, we use the services of third party agents, such as email service providers and mail houses for the purpose of mailing materials to you. These parties are contractually prohibited from using your Personal Data for any purpose other than for the purpose specified in their respective contracts. We do provide non-Personal Data to certain service providers for their use on an aggregated basis for the purpose of performing their contractual obligations to us. We do not permit the sale of Personal Data to business units/entities not owned by, managed by, and/or affiliated with us for any use unrelated to our group operations or use of Personal Data by third party for their own purposes. We will implement, where necessary appropriate measures, including contractual clauses, to secure the transfer of your Personal Data to the third party service providers located in a country with a level of protection though different from the one existing in the country in which your Personal Data is collected.
5. How we track your usage on our website
We may have engaged some web analytics services providers (“Web Analytics Services Providers”) to design and provide us web analytics services. They may use small invisible images known as “web beacons” or “tracking pixels” (in the paragraph 5.4 below) in their digital products and services when providing us those services. These web beacons are used to count the number of times something has been seen but are anonymous and do not contain or collect any of your Personal Data.
Cookies allow our Web Analytics Services Providers to recognize your browser or device and, for example, identify whether you have visited our website before, what you have previously viewed or clicked on, and how you found us. The information is anonymous and only used for statistical purposes. Such information allows us to track information, such as how many individual users we have and how often they visit our website. It also helps us to analyze patterns of user activity and to develop a better user experience.
Web analytics data and cookies cannot be used to identify you as they never contain your Personal Data such as your name or email address.
Although these cookies can track your visits around the web they don’t know who you are. Without these cookies, online advertisements you encounter will be less relevant to you and your interests.
5.2 Other third party cookies
Please note that on some pages of our website you may notice that cookies have been set that are not related to us or our authorised service providers. When you visit a page with content embedded from, for example, YouTube or Facebook, these service providers may set their own cookies on your web browser. These anonymous cookies may be set by that third party to track the success of their application or to customize their application to you. We do not control the use of these cookies and cannot access them due to the way that cookies work, as cookies can only be accessed by the party who originally set them. You should check with these third-party websites for more information about their cookies.
5.3 How to control your cookies
5.3.1 Managing cookies in your browser
Most modern browsers will allow you to:
5.4 Pixel tags
We and our third-party service providers may use pixel tags (also known as ”clear gifs”, ”beacon gifs” etc.), tracking links and/or similar technology to:
5.5 Google and Baidu analytics
Google and Baidu analytics are web analysis services provided by Google and Baidu respectively. Google and Baidu utilize the data collected to track and examine the use of domain owned by us (i.e. our website) and all website pages under our domain to prepare reports on its activities and share them with other Google and Baidu services respectively.
6. Emails about special offers and promotions
When you indicate that you would like to receive promotional material or our newsletter, and provide your email address to us specifically and expressly consent to receive marketing communications, we may periodically contact you via email and provide information about special offers and promotions that may be of interest to you. We typically use third party email service providers to send emails. These service providers are contractually prohibited from using your email address for any purpose other than to send emails related to our operations. Your Personal Data will not be shared with third parties for their own marketing purposes.
7. How long will Personal Data be retained for?
Your Personal Data will be stored by us for the period of time required or permitted under relevant laws and regulations or when it is no longer necessary in relation to the purposes for which they were collected or otherwise processed.
8. Your rights
8.1 Right to access to and/or correction of your Personal Data
You have the right to make a request to us on whether we hold or are processing your Personal Data and if so, what kind of Personal Data is held by us, the purposes of using such kind of Personal Data, to whom we have transferred your Personal Data and be supplied with a copy of your Personal Data. You are also entitled to make necessary correction(s) to your Personal Data held by us. In order to protect your Personal Data, we might require you to prove your identity which may consist of your name, contact number, passport or other identification document details so that we can check them against our records and satisfy ourselves as to your identity. However, we may refuse to comply with your request if you fail to provide us verification information or with reference to relevant laws and regulations. The mentioned Personal Data is required to create an audit trail of how the request has been handled. Where a request is made, any correspondence or application may be kept and added to your Personal Data. In any case, please allow us 30 days to process.
8.2 Right to restriction of processing
You have the right under relevant laws and regulations to block or suppress our processing of your Personal Data, for example, when you contest the accuracy of your Personal Data in our record, you object to the processing and/or you require your Personal Data to establish, exercise or defend a legal claim etc.
8.3 Right to data portability
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format if the process is carried out by automated means and, where technically feasible, the right to have your Personal Data transmitted from us to another data controller.
8.4 Right to unsubscribe or opt-out
We will not use your Personal Data for direct marketing purposes unless with your consent, for example, when you subscribe for our newsletter and provide your Personal Data to us specifically and expressly for receiving marketing communications. If, at any time, you would like to unsubscribe or opt-out from any of the marketing communications, kindly contact us. Please allow us 30 days to process your request.
8.5 Right to be forgotten
Once you have withdrawn your consent, we will erase your Personal Data. We will also erase your Personal Data when it is no longer necessary in relation to the purposes for which they were collected or otherwise processed unless such erasure is prohibited under relevant laws and regulations. However, we may not be able to continue providing our products, services, activities or facilities to you if you ask us to delete your Personal Data entirely to the extent we can do so under relevant laws and regulations.
9. Notifications in the event of breach
In an unlikely event of Personal Data breach, where feasibly and applicable under relevant laws and regulations, we will, within 72 hours after having become aware of such breach, notify the relevant supervisory authority. We are also prepared to follow relevant laws and regulations which would require us to notify you without undue delay after having become aware of such breach.
10. Links to other websites
11. Policy on people under the age of 18 and minors
Our website is not intended for persons under the age of 18 and minors. We do not and will not knowingly solicit or collect Personal Data from them. As a parent or legal guardian, please do not allow any person under the age of 18 and minors to submit their Personal Data without your permission.
Should you have any comments on the Statement and the Policy or Personal Data protection, please contact us. You may also lodge your complaints with a supervisory authority in your country.
13. Legal disclaimer
The Statement and the Policy are designed to provide compliance with all relevant applicable laws and regulations, in particular those our businesses are subject to. We recognize that certain laws and regulations might be modified to require more stringent standard than those described in the Statement and the Policy, in which case the more stringent standards shall apply. If applicable laws and regulations provide for a lower level of protection of Personal Data than the Statement and the Policy, then the Statement and the Policy shall prevail.
As an international business with operations in different parts of the world, we may need to disclose your Personal Data when required by relevant law or court order, or as requested by other government or law enforcement authorities. This also applies when we have reason to believe that disclosing your Personal Data is necessary to identify, investigate, protect, contact or bring legal action against someone who may be causing interference with our rights or properties (including our website), or to others, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
The Policy may be revised from time to time. If there is any inconsistency between the Statement and the Policy, the Policy shall prevail.