PRIVACY POLICY STATEMENT

  1. 1. Your Personal Data Privacy

H•COINS (“H•COINS”) is an integrated membership rewards programme managed and operated by Henderson Leasing Agency Limited (“Henderson Leasing Agency” or “We”). We respect your legal rights of privacy when collecting, storing, using, and transferring personal data and this Privacy Policy Statement (the “Statement”) explains our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). We collect personal data only for lawful and H•COINS related purposes, and we shall take reasonable and practicable steps to protect your personal data and prevent unauthorised or accidental access, deletion, or other use. However, given the open nature of the internet, we cannot guarantee that risks can be completely eliminated.

 

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Statement applies to personal data collected through the H•COINS mobile application and website. H•COINS mobile application and website are designed to facilitate and promote the management and operation of the following seven shopping malls managed and operated by Henderson Leasing Agency, namely MCP CENTRAL and MCP DISCOVERY (Metro City Plaza Phase 2 and Phase 3), MOSTown, KOLOUR Tsuen Wan, KOLOUR Yuen Long, Shatin Centre, Shatin Plaza, Trend Plaza, Square Mile (collectively “HLD Malls”). We have the right to modify and update this statement as may be necessary from time to time, so please review it regularly. If you have registered for H•COINS membership and/or used our services, and each time you login to the H‧COINS mobile application and/or website, you are deemed to have agreed to accept the privacy policy and personal information collection statement applicable at that time.

If there is any inconsistency or ambiguity between the English version and the Chinese version, the English version shall prevail.

 

  1. 2. Collection of Data and Use

 

We shall collect your personal data as reasonably necessary, including but not limited to your name, residence, contact information, gender and birthday month so as to provide you with events, promotions, products and/or services. You are not obliged to supply us with the data, but if you do not, we may not be able to provide you with our products and/or services.

 

We shall use your personal data primarily for membership registration and the subsequent H•COINS related purposes, including provision of promotional offers, products, services, facilities and information; arranging and hosting events; management and operation of H•COINS, as well as H•COINS mobile application and website. Please refer to the “Personal Information Collection Statement” for details.

 

 

If you are under the age of 18, you must seek the consent of your parent or guardian before providing us with any personal data.

 

  1. 3. Disclosure and transfer of Personal Data

 

We shall take all practicable steps to ensure the security of your personal data. For the purposes of H•COINS operation and related arrangements, we may disclose or transfer your personal data to third parties. Please refer to the “Personal Information Collection Statement” for further details.

 

 

  1. 4. Use or Provision of Personal Data for Direct Marketing

 

We intend to use and transfer your personal data for direct marketing. Direct marketing is regulated by the Ordinance, and we are required to obtain your written consent and comply with other regulatory requirements before we can use and transfer your personal data for direct marketing. Please refer to the “Use and Provision of Personal Data for Direct Marketing” section under the “Personal Data Collection Statement” about the scope and arrangements in Direct Marketing.

 

 

You may decide whether or not to accept direct marketing and have the right to change your choice at any time. If you would like to change your choice, please notify us in writing (please refer to section 10 below for the address). If we receive your notification to refuse direct marketing, we shall process it in due course so that you will not be included in subsequent direct marketing, without charge.

 

We may send you promotional information about products and services from time to time according to your choice of direct marketing. During the marketing process, we shall provide an appropriate option of “refusal of direct marketing”. If you do not want to receive promotional news for H•COINS members and/or information about the group and/or its subsidiaries, associated and/or related companies and/or third-party service providers, please send an email to H•COINS@hld.com or notify us in writing (please refer to section 10 for the address).

 

  1. 5. Links to Other Websites

 

H•COINS may use third parties for the provision of content, services, and products; and provide hyperlinks connecting to their applications or websites; and we also provide hyperlinks connecting to other third parties’ applications or websites. This Statement only applies to the H•COINS mobile application and website. If you click on any hyperlink linking to third party application(s) or website(s), you will leave the H•COINS mobile application or website and enter the third party application or website. This Statement is not applicable to mobile applications or websites owned by third parties. We are not responsible for the collection and protection of personal databy the third party applications or websites; and you are advised to read the privacy policy of the third parties’ application or websites to understand the arrangements.

 

 

 

  1. 6. Web Logs

 

When a user visits the homepage of the H•COINS website, the visit will be counted and included in the total number of visits to the website for statistical purposes. This information does not identify you. No personal data will be collected.

 

  1. 7. Cookies

 

We use cookies across our mobile application and website in order to improve their performance and enhance users’ online experience. Session cookies are used to enable users to browse and use the basic functions on our H•COINS mobile application and website, such as maintaining login details for the session so that the need to transfer information across the internet may be reduced. We shall not collect any personal data from users when the cookies are being used.

 

  1. 8. Security

 

We shall take all practicable measures to ensure the security of personal data. Your personal data, irrespective of how it is stored, will only be accessed or processed by our employees, agents, contractors and/or third-party service providers who are authorised to do so and under a duty of confidentiality to us. Such authorised personnel or contractors designated to handle personal data must follow our instructions.

 

 

  1. 9. Your Right ofAccess to and Correction of Your Personal Data

 

In accordance with the provisions of the Ordinance, you have the right to request access to and to correct personal data relating to you in our records at any time. If you need to exercise your rights, you may contact us at the address stated in section 10 below and mark your communication “Confidential”. While processing your request, we may request you to provide certain personal information about yourself, so as to verify your identity. We shall respond within the time specified in the Ordinance. We may charge you a fee not more than necessary for processing your request of access to information.

 

  1. 10. Personal Data Privacy Officer

 

The person to whom (1) requests (a) for access to data or correction of data; (b) for general information regarding our policies and practices with respect to personal data; and (c) about the kinds of personal data that we hold, or (2) general enquiries and complaints should be addressed is as follows:

 

Personal Data Privacy Officer (Portfolio Leasing Department)

Henderson Leasing Agency Limited

(Marked Confidential)

Address：73/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong

 

  1. 11. Retention of Data

 

We shall take all reasonably practicable steps to ensure that we do not retain your personal data beyond the time required to complete the purpose for which the data was collected, except where the continued retention of personal data is required or permitted by the Ordinance.

 

 

 

 

 

PERSONAL INFORMATION COLLECTION STATEMENT

 

This personal information collection statement is applicable to the mobile application and website of the “H•COINS” integrated membership reward programme (“H•COINS”) managed and operated by the Henderson Leasing Agency Limited (“Henderson Leasing Agency” or “We”).

 

This statement is applicable to the seven shopping malls managed and operated by the Henderson Leasing Agency, namely MCP CENTRAL & MCP DISCOVERY (Metro City Plaza Phase 2 and Phase 3), MOSTown, KOLOUR Tsuen Wan, KOLOUR Yuen Long, Shatin Centre and Shatin Plaza, Trend Plaza, Square Mile (collectively “HLD Malls”).

 

We are committed to complying with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance”) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”) in relation to the collection, storage, use and transfer of personal data.

 

We may collect your personal data as reasonably necessary, including your name, place of residence, contact information, gender and birthday month so as to provide you with events, promotions, products and/or services offered by H•COINS. You are not obliged to supply us with such data, but if you do not supply us the information marked with (*) that must be completed, we may not be able to provide you with our products and/or services.

 

 

FOR THE PURPOSES OF THIS STATEMENT:

 

“Henderson Land Group” or “Members of Henderson Land Group” refers to the Henderson Land Group Development Company Limited, its subsidiaries and its associated companies, and any related other entities managed by Henderson Land Group Development Company Limited or its subsidiaries or associated companies from time to time. An entity is considered to be managed by another entity in the following circumstances:

(i)        This other entity may direct the affairs, or manage the composition of its board of directors, or its governing bodies; or

(ii)       This other entity holds not less than 20% of its issued shares, or owns an interest in its shares, which entitles this entity the right or control to exercise not less than 20% of the voting rights at its general meeting of shareholders.

 

“Group Partners” refers to (i) a person who cooperates with or assists us in providing H•COINS and/or providing products and services offered by H•COINS, (ii) any joint venture company established by a member of Henderson Land Group together with any other property developer or other persons, to provide products, services or facilities related to real estate properties, or (iii) a person who appoints us to promote, sell or lease real estate property for him/her.

 

 

A       Use of Personal Information

 

We may use your personal data for one or more of the following purposes:

  • Providing, marketing and promoting products, services, and/or facilities of HLD Malls, and managing, maintaining, processing, operating, improving and introducing these products, services and/or facilities (please refer to the “Use or Provision of Personal Data for Direct Marketing” section below);
  • Delivering information to users of the mobile application and website (“user” or “users”) that the users may have interest in, such as banners of targeted promotional events, new products and services and other promotions and marketing materials of HLD Malls (please refer to the “Use or Provision of Personal Data for Direct Marketing” section below);
  • Processing billing and payments;
  • Monitoring use of the H•COINS mobile application and website to help facilitate the development of the H•COINS mobile application and website;
  • Compiling aggregate statistics about our users to analyse the H•COINS mobile app and website usage;
  • Operating internal control, following up on comments and enquiries, investigations and handling complaints and disputes, and enforcing terms of use and related legal matters in relation to H•COINS;

 

  • Processing applications, provision and maintenance of H•COINS memberships, and processing users’ registration, setting up and maintaining Users’ accounts of H•COINS mobile application and website;
  • Identifying and verifying the identity/eligibility of a user who uses/used the H•COINS mobile app and website, and services provided by H•COINS;
  • Collecting statistics, conducting research and analysis, including market research by H•COINS, HLD Malls and/or Members of the Henderson Land Group;
  • Contacting and communicating with users in respect of matters and arrangement related to H•COINS membership or the use of the H•COINS mobile application and website and/or the use of services provided by H•COINS;
  • Providing users with products and/or services offered by H•COINS, and/or the information and updated information in relation to these products and/or services;
  • Processing, following up and evaluating the provisions by H•COINSof services, privileges, rewards, promotions, discounts, special offers or conveniences, or applications, requests, registration and reservation of products, services and/or facilities offered by HLD Malls;
  • Designing and optimising the facilities, services and/or products of HLD Malls;
  • Checking and comparing any information relating to you from time to time for the purposes listed in this section;
  • Preventing or detecting any illegal or suspicious activity;

 

  • Complying with any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply; and

 

  • Any other purpose(s) which has been agreed by the user from time to time.

 

 

 

B       Disclosure and Transfer of Personal Data

 

To facilitate the above purposes, we may disclose or transfer the user’s personal data to any of the following parties irrespective of whether such parties are located inside or outside Hong Kong, provided that any disclosure or transfer of the user’s personal data to another person for direct marketing purposes is subject to the “Use and Provision of Personal Data for Direct Marketing” in the next section:

 

(i)        Members and assoicates of the Henderson Land Group;

(ii)       Any agents, contractors and/or third-party service provides providing us with services in relation to administrative, telecommunications, information technology, system management, repair and maintenance and/or other services to support the business operation of us or the Henderson Land Group;

(iii)      Any person who has a duty of confidentiality to us, including our accountants, legal advisers or other professional advisers; and

(iv)      Any regulatory or other authorities to whom we are required to make disclosure under any law binding on us or upon any request, guidelines or codes we are reasonably expected to comply with.

 

 

C       Use and Provision of Personal Data for Direct Marketing

 

We intend to use the personal data of users (mainly the name, contact information, services and product portfolio information and background information) for direct marketing purposes and provide such personal data to the parties referred to in section B(i) above. To use the personal data of users for direct marketing purposes or disclose or transfer users’ personal data to other persons for direct marketing purposes, we must obtain written consent from the users.

 

In terms of direct marketing, we intend to:

 

(a)       Use and analyse the personal data collected, formulated, compiled or held by us from time to time, in order to understand the needs, preferences and usage patterns and habits relating to products, services and facilities;

 

(b)       Promote the following categories of products, services, and matters to the user:

 

  • Real properties inside and outside Hong Kong, including residential, office, and commercial properties and industrial buildings, shops, hotels and serviced apartments, shopping malls, car parks and parking spaces;
  • Catering and travelling, shopping malls, department stores and related activities and matters;
  • Consumer goods and services, including homeware, household services, cooking supplies, kitchen utensils, electrical appliances and furniture, entertainment, electronic products, computers and accessories, audio and video products, stationery and toys, baby goods, apparel, fashion, accessories, leather goods, luggage, footwear, watches and jewellery, healthcare products, hair products, beauty products and cosmetics, leisure goods, pet products and services, environmental protection and health products;
  • Electronic services including online transaction or payment platforms or electronic payment services;
  • Property management, construction, gas stoves and appliances and applications;
  • Insurance, credit financing, finance and financial services;
  • Telecommunications and information technology;
  • Transport infrastructure operations and management, transportation and logistics;
  • Rewards / incentives / promotions, corporate social responsibility activities, charitable and non-profit making related matters.

 

(c)       The above products, services and objects may be provided by us or any person referred to in section B (i) above;

 

(d)       We provide the personal data of user to other persons referred to in section B(i) for marketing purposes for a return on money or other assets.

 

If the user agrees to our use of the user’s personal data for direct marketing purposes in accordance with the above scope and arrangements, or our provision of the user’s personal data to others for direct marketing purposes, please put a tick in the box provided.

 

Users may decide whether or not to accept direct marketing at their own discretion and have the right to change their choice at any time. If users would like to change their choice, please write to the address listed in the “Access to and Correction of Personal Data” section below. If we receive the user’s notification to refuse direct marketing, we shall process it in due course so that the user will not be included in subsequent direct marketing, without charge.

 

 

D       Access to and Correction of Personal Data

 

In accordance with the Ordinance, the user has the right to:

(i)      Inquire whether we hold the user’s personal data in our records, and have access to personal data relating to the user;

(ii)     Correct any inaccurate information of the user’s personal data; and

(iii)    Be informed of our policies and practices regarding personal data

 

Users requiring access to or correction of personal data or making other enquiries are requested to write to the address below and mark your communication “Confidential”. While processing a user’s request or inquiry, we may request the user to provide certain personal information, so as to verify the user’s identity. We shall respond within the time as specified in the Ordinance. We may charge a not more than necessary fee for processing access to information.

 

Personal Data (Privacy) Director (Group Leasing Department)

Henderson Leasing Agency Limited

(marked CONFIDENTIAL)

Address: 73/F, Two ifc, 8 Finance Street, Central, Hong Kong