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Privacy Policy Statement

This statement is made by the Eagle Property Management (CP) Limited (together with Three Garden Road, “we”, “us” or “our”), in accordance with the Hong Kong Personal Data (Privacy) Ordinance and where applicable, the European General Data Protection Regulation ("GDPR"). We are committed to ensuring that all Personal Data (as defined below) are handled in accordance with the Ordinance and where applicable, in accordance with the GDPR. We respect the privacy of every individual whose Personal Data we handle and are committed to protecting your privacy and ensuring security for your Personal Data.


This statement explains the types of Personal Data we collect, how and for what purpose we use that information, who we share it with, and how we protect that information.


For the purposes of applicable data protection law, the data user is Eagle Property Management (CP) Limited.


Why have a PrivacyPolicy Statement?

We will process Personal Data about you in your capacity as an investor and/or a visitor to this website ("Website").


“Personal Data” means any personal information which on its own or combined with other information relates to and identifies (directly or indirectly) a living individual.


We believe it is important that you know what Personal Data we collect, what we use it for and on what basis. It's also important we set out the rights you have in relation to your Personal Data. Where applicable,you have the right to know what information we hold and to request copies ofthat information, as well as object to us holding such information, request that any inaccurate information we may hold about you is rectified, and incertain circumstances request that we delete such information.


This Privacy Policy Statement sets out in detail the reasons why we collect your Personal Data.


What information is covered by this Privacy Policy Statement?

This Privacy Policy Statement governs the processing of Personal Data that you provide to us, that we collect or receive from you or that we receive about you when you visit our Website. It also covers Personal Data processed by us in relation to investors.


Updates and changesto this Privacy Policy Statement

We review our Privacy Policy Statement regularly. If you have any questions about this Privacy Policy Statement you can write to Data Protection Officer, Suites 806-7, ICBC Tower, Three Garden Road, Central, Hong Kong.


What Personal Data wecollect and how

Personal Data we may collect and use including your contact details and identity information (for instance, your name, address, e-mail address, telephone number, fax number, company name, industry and occupation), payment information of products or services of your order (for instance, credit card number and expiry date, account information of other payment services (for instance, online or mobile payment services) and statement information), and information of your Three Garden Road eSTORE membership (for instance, account information, password and transaction records).

How we collect Personal Data

We collect this information when you provide it to us, or we create it ourselves or collect it from other organisations.


Information we receive from you

You may provide information to us when you:


  • ask us to provide you with products, services orinformation relating to our products or services;
  • send us enquiries or requests; and
  • submit comments or other correspondence to usvia the links available on this Website, via telephone call and/or email to us.


Information we collect about you

We may receive information about you that you authorize third parties (such as credit reference agencies, fraud detection agencies, and registration or stockbroking industry exchanges) to provide to us.


We also may obtain information about you from third-party sources (e.g. publically available sources) and service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you.


Additionally, when you visit our Website, we may use cookies and other technologies to automatically collect the following information:


  •   Technical information, including your IP address, your login information, browser type and version, device identifier, location and time zone setting, browser plug-in types and versions, operating system and platform, page response times, and download errors;
  •   Information about your visit, including the websites you visit before and after our Website and products you viewed or searched for;
  •   Length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers) and methods used to browse away from the page; and
  •   Similar information for additional content that can be accessed from website pages, such as opening or printing documents or which videos are played and for how long.


If you do not want to receive a cookie when using our Website, you may set your browser to refuse cookies or to notify you when you receive a cookie, which you may then refuse upon such notice. However, by disabling cookies, you may not be able to take full advantage of the Website.


Sensitive or special category Personal Data

Different rules apply to the processing of data concerning race, ethnic origin, political opinions or beliefs, religious or other beliefs, trade union membership, physical or mental health, sexual life or orientation and any offences committed and sentences or court proceedings relating to actual or potential offences. This is known as sensitive or special categories of data.


During our relationship with you, we should not require any such sensitive or special categories of data. Therefore please do not send us such data.


How we use your Personal Data

We will have a specific purpose to collect, store and use your Personal Data. The Personal Data we collect will depend on our relationship with you.


We process your Personal Data for the following purposes:


  •   To provide our products or services to you;
  •   To verify your identity;
  •   To process your payment instruction;
  •   To contact you when necessary or appropriate;
  •   To provide customer support (including to respond to your comments and questions);
  •   For legal and administrative purposes, including assessing and managing risk;
  •   To safeguard our legal rights and interests; and
  •   To seek and receive advice from our professional advisors, including accountants, lawyers and other consultants.


The processing of your Personal Data is necessary for our legitimate interests when we process your Personal Data to provide our products or services to you; to verify your identity, to process your payment instruction; to contact you when necessary or appropriate, to provide customer support (including to respond to your comments and questions), to safeguard our legal rights and interests, and to seek and receive advice from our professional advisers, including accountants, lawyers and other consultants.


Where necessary to comply with applicable laws, we will seek your consent to process your Personal Data.


In some cases it will be necessary for us to process your Personal Data in order to comply with our legal and regulatory obligations, for example where we process your Personal Data to comply with our regulatory and legal obligations, including assessing and managing risk.


Where we process your Personal Data to provide a product or service, we do so because it is necessary in order for us to provide such product and service.


Refusal to provide your information may make it impossible for us to provide the products, services or information requested.


Access and rectification of Personal Data

You have the right to ascertain whether we hold your Personal Data, to obtain a copy of your Personal Data, and to rectify any Personal Data that is incomplete or inaccurate. You may also request that we inform you of the type of Personal Data held by Eagle Property Management (CP) Limited.


Requests for access and correction or for information regarding policies and practices and kinds of data should be addressed in writing to:

Data Protection Officer, Suites 806-7, ICBC Tower, Three Garden Road, Central, Hong Kong


A reasonable fee may be charged to offset our administrative and actual costs in complying with your access requests.


For individuals in the EU you have additional rights (where applicable) - for further information please see the "Your rights under the GDPR" section below.


In the event of any inconsistency between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.


Disclosure of Personal Data to third parties

We may share your Personal Data with third parties in the following circumstances:


  •   Third parties permitted by law: In certain circumstances, we may be required to disclose or share your Personal Data in order to comply with a legal or regulatory obligation (for example, we may be required to disclose Personal Data to the police, The Stock Exchange of Hong Kong Limited, the Securities and Futures Commission in Hong Kong, other regulators, government agencies or to courts, judicial or administrative authorities). We may also disclose your Personal Data to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.
  •   Third parties connected with business transfers: We may transfer your Personal Data to third parties in connection with are organisation, restructuring, merger, acquisition or transfer of assets,provided that the receiving party agrees to treat your Personal Data in a manner consistent with this Privacy Policy Statement.
  •   Within our group: We may share your Personal Data among our other offices, affiliates and locations to administer our services and products, to send you information about products and services that may be of interest to you and conduct the other activities described in this Privacy Notice.
  •   Our service providers: We use other companies,agents or contractors to perform services on our behalf or to assist us with the provision of our products and services. For example, we may share your Personal Data with the following categories of service provider:
    •   infrastructure and IT service providers (including for email archiving, such as providers of our cloud hosting solutions)
    •   external auditors and professional advisers;
    •   insurance brokers and insurance companies; and
    •   marketing, advertising, analysis, research and communications agencies.


We will only provide our service providers with Personal Data which is necessary for them to perform their services to us, assist us with the provision of our products or services, or respond to your enquiries or complaints, and we require them not to use your Personal Data for any other purpose. We will use reasonable commercial efforts to ensure that all our service providers keep your Personal Data secure.


Transfer of Personal Data outside the European Economic Area

Your Personal Data may be transferred to and processed by us, our affiliates and third parties which may be located in countries outside the European Union and /or the European Economic Area ("EEA").  In particular, Personal Data we collect about you will be stored in Hong Kong. We will take all steps that are reasonably necessary to ensure that your Personal Data is treated securely and in accordance with this Privacy Notice as well as applicable data protection laws,  including, where relevant, by entering into EU standard contractual clauses (or equivalent measures) with the party outside the EEA.


EU customers only: Your rights under the GDPR

For the purposes of applicable data protection law, the data controller is Eagle Property Management (CP) Limited.


If you are in the EU and the processing of your Personal Data is subject to the GDPR, then you have the following rights (if applicable):


  •   Access. You have the right to request a copy of the Personal Data we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
  •   Rectification. You have the right to have incomplete or inaccurate Personal Data that we process about you rectified.
  •   Deletion. You have the right to request that we delete Personal Data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
  •   Restriction. You have the right to restrict our processing of your Personal Data where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
  •   Portability. You have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
  •   Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of alegal claim.
  •   Withdrawing Consent. If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge. This includes cases where you wish to optout from marketing messages that you receive from us.


You can make a request to exercise any of these rights in relation to your Personal Data by sending the request in writing to Data Protection Officer, Suites 806-7, ICBC Tower, Three Garden Road, Central, Hong Kong.


You also have the right to make a complaint at any time with your national data protection authority or other public authority governing the protection of your Personal Data.


How we protect your Personal Data

We have implemented technical and organisational security measures to safeguard the Personal Data in our custody and control. Such measures include, for example, limiting access to Personal Data only to employees and authorised service providers who need to know such information for (a) the purposes described in this Privacy Policy Statement and (b) in order to perform their jobs, such as providing you with information you request, or notifying you of new products and services.


While we endeavour to protect our systems, sites, operations and information against unauthorised access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others, such as hackers.


How long we keep your Personal Data

The period for which we retain Personal Data will vary depending on what purpose it has been collected for, as well as the requirements of any applicable law or regulation. We will only retain your Personal Data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable law. When we no longer need to use Personal Data, we will remove it from our systems and records and/or take steps to anonymise it so that you can no longer be identified from it.


Children's privacy

Only adults over the age of 18 are allowed to place order in Three Garden Road eSTORE or register as a member of Three Garden Road eSTORE. We will not knowingly collect Personal Data from children under the age of 16years. If you are under the age of 18, consent from your parent or guardian is required before you provide us with any personal data.


Contact details

If there are any questions or concerns regarding this Privacy Policy Statement, please write to Data Protection Officer, Suites806-7, ICBC Tower, Three Garden Road, Central, Hong Kong.