PERSONAL INFORMATION COLLECTION STATEMENT
Lee Gardens Club
Personal Information Collection Statement (PICS)
Collection of your personal information
Lee Gardens Club (“Lee Gardens Club”) is a program managed and operated by Hysan Marketing Services Limited. You are seeking to apply to become a member of Lee Gardens Club, and have completed the application form to which this PICS is attached. Please read the following PICS to understand how the Hysan Group handles your personal data and your rights under the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the "Ordinance"). The Hysan Group comprises Hysan Development Company Limited and each of its subsidiaries including Hysan Leasing Company Limited, Hysan Marketing Services Limited, Hysan Property Management Limited, Hysan Corporate Services Limited, Bamboo Grove Recreational Services Limited, as well as their holding companies, branches, representative offices and affiliates (collectively the "Group", "Hysan", "we", "us" or "our").
1. Data Collection
1.1 The types of personal data ("Data") we collect from you may include:
a) your personal information, e.g. your salutation, name, gender, age group, marital status, month and date of birth, spending record, your interest, your geographical location, bank details, photograph, your identification proof, document or numbers;
(b) your contact information, e.g. telephone number, residential address, office address, mailing address, email address, and fax number;
(c) your business and educational information, such as company name, business title and education background;
(d) your membership numbers and relevant log-in information, credit card/debit card/stored value card information, mobile payment and other payment information, vehicle registration number, vehicle/plate photo that you will use to access our products and services or in relation thereto;
(e) your social media account details, e.g. user names or account numbers;
(f) photos of and information regarding your spending and purchase of goods and/or services at the Participating Merchants1 (via the Lee Gardens mobile application (“Lee Gardens App” or “App”);
(g) browsing preferences and behaviours, MAC address and/or IP address (in so far as they may be deemed to amount to personal data). Note that if the WiFi function on your device has been enabled, the MAC address and/or IP address of your device may be collected, even if the device is not connected to our WiFi services; and
(h) other information as may be set out in the relevant form or collection channel.
1.2 We may also collect non-personally identifiable information about you, such as browsing preference of our websites or mobile applications, personal preferences and comments, and responses to promotional offers and surveys.
1.3 In certain situations, we may ask you to provide the Data of other individuals to us, e.g. emergency contacts, information of your family members. By providing us with such Data, you represent to us that you have obtained those individuals' authorisation and/or consent to the use, disclosure and transfer of their Data. We shall not be responsible for any claim whatsoever from any party in the absence of such consent.
1.4 For both iOS version and Android version of the Lee Gardens App (we do not support Windows Phone version or other platforms):
(a) we may request permission to access your “Calendar” on your mobile device via the Lee Gardens App in order to allow you to save any events relating to the Lee Gardens Club being hosted by us or a Participating Merchant ("Event") to your Calendar. If you permit us to access your Calendar for such purpose, please click on our icon on the App confirming that you would like to mark an Event in your Calendar. We will not access your Calendar for any other purpose and will not gain access to or collect any other data stored on your Calendar. You can also elect to switch off this function via the App.
(b) we may request permission to access your “Camera” on your mobile device to take and upload a photo via the Lee Gardens App of your spending receipt for goods or services purchased at a Participating Merchant to enable you to earn reward points as part of the Lee Gardens Club and/or your profile photo. We will not otherwise access your photo album and will not gain access to or collect any other data stored on your photo album. You can also choose to not upload any photo.
(c) we may request permission to access your “Wi-Fi Connection Information” on your device via the Lee Gardens App, as the Lee Gardens App requires internet connection to earn points on-line. You can also elect to use your own mobile data for internet connection.
1.5 In the relevant form or collection channel it may be indicated whether any Data is obligatory or voluntary. If you fail to supply Data that is marked as obligatory, we may not be able to process your Lee Gardens Club membership application, engage with you for the intended purposes or provide the relevant products and services fully or at all.
2. Purposes for which the Data are Collected and Used
2.1 We may use the Data you provide for one or more of the following purposes (or any directly related purpose):
(a) To enable us or the Participating Merchants to provide rewards or benefits or privileges to you in relation to your Lee Gardens Club membership;
(b) For use of the services available at any of our websites, systems, mobile applications and/or through other telecommunication channels, in particular to administer the Lee Gardens App;
(c) For market research and/or data analytics, including to better understand customer behaviour, for customer and tenant relationship management purposes, and to improve the business operations and marketing strategy of Hysan and our Partners;
(d) Subject to your consent, to send you marketing and promotional updates on our and our Partners' activities, products and services from time to time and to customise and tailor such marketing communications for you; "our Partners" include our retail merchants (including the Participating Merchants), office tenants, co-branding partners, and business partners (who may be engaged in businesses such as retail, banking, finance, credit/smart/stored value cards, insurance, charity/not-for-profit causes, entertainment, food & beverage, and other businesses as we may notify you);
(e) To confirm your identity and verify that you are a member of Lee Gardens Club;
(f) To administer your Lee Gardens Club membership, including accumulating and redeeming any reward points earned by you under the membershipand provide you with information regarding your aggregate amount spent at all Participating Merchants;
(g) To allow you to use the services, systems, facilities, functions or features provided by us or third parties through the App;
(h) To communicate with you by post, email, digital media (including through push notification via the App), telephone, SMS or other means regarding your Lee Gardens Club membership or your use of our products, services, mobile applications, systems and/or websites;
(i) To handle your requests for services, membership, redemption or benefits;
(j) To assess your continued eligibility as a member of Lee Gardens Club;
(k) For reservations with or through us;
(l) For daily operation and administration of our business and premises, including the provision of car park services and information;
(m) To enforce our rights under contracts, including to collect or recover any debt owed by you to us;
(n) To comply with legal or regulatory obligations applicable to any Group member;
(o) To connect to our WiFi services and to provide you with automatic personalised location-based services and content, including targeted advertisements, content, features, deals and offers if you have consented to the receipt of direct marketing materials;
(p) For the use of any member of the Group in connection with any of the above purposes and/or any of the services such entities may be offering to you from time to time;
(q) To handle your enquiries or requests, e.g. lost & found;
(r) For any other purposes to which you may from time to time agree; and<
(s) To carry out our obligations to you under the Terms and Conditions for Membership of Lee Gardens Club";
2.2 We will not sell or rent the Data provided to us, or knowingly or intentionally use or share the Data in ways unrelated to the purposes aforementioned.
3. Disclosure and Transfer of Personal Data
3.1 We may disclose and transfer the Data you provide or which are otherwise collected by us to the following parties (whether local or overseas) in connection with the purposes set out above (or any directly related purpose):
(a) any member of the Group (including different divisions within each Group entity);
(b) any of our agents, professional advisers (including lawyers and auditors), contractors, subcontractors or third party service providers who provide administrative, financial, data processing, data storage, telecommunications, computer, payment, system operation, property management, marketing and research, information technology, data analytics or other services in connection with the operation and maintenance of our business, or any persons under a duty of confidentiality to us;
(c) our Partners;
(d) our successors or assigns (whether actual or proposed) under an acquisition, sale or restructuring of the business and/or assets of any member of the Group, or any assignee of our rights;
(e) any person to whom we are under an obligation to make disclosure under the requirements of law or a court order of any jurisdiction or to any government or law enforcement authorities or administrative organs as requested;
(f) any person to whom we believe in good faith that disclosure is otherwise necessary or advisable including to protect our rights or properties or in circumstances which we consider to be related to any of the purposes for which the Data are collected; and
(g) to any person when we have reason to believe that disclosing the Data to such person is necessary to identify, contact or bring or defend legal action against someone, e.g. anyone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
3.2 The Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for the purposes mentioned above, and you explicitly consent to and accept all risks of such transfer. We will try to ensure, as far as possible and practicable, that Data sourced or transferred outside Hong Kong is protected to standards in line with the requirements of the Ordinance, subject to any other requirements and limitations of the particular jurisdiction.
4. Direct Marketing
4.1 We intend to use your Data (and transfer your Data to the parties set out in paragraphs 3.1(a)-(d) above) to send you marketing and promotional materials through post, email, digital media (including through push notification via the App), telephone, SMS and other means, in relation to activities in Hong Kong or overseas such as:
a) Retail Events and Promotions: (i) promotions and events hosted, sponsored or organised by us or any member of the Group or by our Partners; (ii) any rewards or discounts, offers, membership, privileges, advantages or benefits offered by each member of the Group or our Partners;
b) Tenants / Residents Events and Promotions: promotions and events which we or any member of the Group host, sponsor, organise or participate in, e.g. clubhouse activities for residents, privileges and events for tenants.
c) Properties for Sale or Leasing: office, retail and/or residential properties offered for sale or leasing by us or any member of the Group and related services;
d) Charity and Community: solicitations for donations or contributions for charitable, social enterprise or non-profit making purposes, or community / social corporate responsibility events or activities which we or any member of the Group host, sponsor, organise or participate in; and
e) Others: other activities, events, businesses or promotions as may be carried out by the Group and notified to you (as set out in the relevant form or collection channel) from time to time. collectively the "Marketing Activities". We will only use your Data for the purposes of Marketing Activities if you have consented to such use.
4.2 You always have ultimate choice and control over the type of information you would like to receive from us. When you complete and return your membership application or other forms to us or use our online services, you can indicate your consent to us to use your Data for the purposes of the Marketing Activities. You can withdraw your consent for use by us of your Data for the Marketing Activities, at any time, by sending an email to our Data Privacy Officer at firstname.lastname@example.org or as indicated in the relevant materials.
4.3 Please note that surrender of membership does not mean withdrawal of consent to use of your Data for the purposes of Marketing Activities. All withdrawal of consent must be made in accordance with clause 4.2 above.
5. Cookies and Other Tracking Mechanisms
5.1 We may automatically collect information about your computer or device, including where available your IP address, device ID, MAC address, operating system and browser type. This is statistical data which does not reveal your identity. Similarly, cookies may be left on the hard drive of your computer, mobile phone or other devices.
5.3 We use analytics tools to automatically measure how visitors interact with content on our websites, systems and applications, or in relation to your use of our WiFi services. If you log-in to our websites, systems, applications or WiFi services via your social media accounts, we may collect information you have made available on the relevant social media sites and link your interaction with us to such information. Where you have consented to direct marketing, we may also engage social media sites or send you push notifications via the Lee Gardens App to show you advertisements that are customised (which may be automatic) based on analysis of any Data we may retain in relation to you, your interactions with us and/or aggregated and anonymous non-personally identifiable information we collect via analytics technologies.
5.4 We may feature embedded links, “share” buttons or widgets on our websites, systems or applications to enable you to connect to third party sites, including social media sites. These third party sites may set cookies which can identify you as an individual when you are logged in to their services. We do not control these cookies or how these sites collect and handle your Data. You should read the relevant third-party sites for their privacy policies before submitting any Data to these sites. We have no control over and are not responsible or liable for the contents of third party sites or third party posts on our websites, systems, applications or social media accounts.
5.5 We may use analytic technologies to collect non-personally identifiable information about you on an aggregated and anonymous basis, such as information captured by devices in real-time during your visit (e.g. visitor counts and information), and those which are collected via our WiFi services through your WiFi enabled device (even if it is not connected to our WiFi services) (e.g. IP address, MAC address, location data, visitor statistics and preferences, activity patterns and device information). If you do not wish us to collect the aforesaid information via our WiFi services, then you can turn off the WiFi function on your device. We use this data for research and analytics purposes, including helping us to study activity patterns and visitor preferences in order to improve service experience. If you sign in to use our WiFi services through your Lee Gardens Club membership log-in details, such non-personally identifiable information may be linked to any Data we may retain in relation to you, and if you have consented to receive direct marketing, we may provide you with targeted advertisements, content, features, deals and offers through push notifications via the App.
5.6 We may use Push Notification function to provide automatic personalised services and content. If you have enabled this function, we may provide you with targeted advertisements, content, features, deals and offers through push notifications via the App.
6. Data Security and Retention
6.1 The Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes (or a directly related purpose) mentioned above, after which it will be destroyed. We will retain your Data for fifteen (15) months following the termination of your membership, in order to enable us to address any enquires or disputes that arise between us and you concerning your Lee Gardens Club membership. Only anonymised data, where it is not possible to ascertain your identity, is retained for analytical and statistical purposes for more than fifteen (15) months following the termination of your membership.
6.2 In order to ensure the correct use and to maintain the accuracy of the Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Data, we have implemented various physical, electronic and management measures to safeguard and secure the Data we collect.
7. Our Commitment to Children's Privacy
Protecting the privacy of children is our primary concern. If you are under the age of 18, you should obtain consent from your parent or guardian before providing us with your Data.
8. How to Access or Correct Your Data
8.1 You are entitled to access or correct any Data related to you held by us. If you wish to obtain a copy of any of your Data or if you believe that the Data related to you which we collect and maintain is inaccurate, please contact our Data Privacy Officer at email@example.com or at the following address:
Data Privacy Officer
50/F, Lee Garden One
33 Hysan Avenue
8.2 In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.
8.3 You may also contact us at the above details for any other data privacy related matters.
This PICS is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this PICS, the English version shall prevail.
Last Version Date: December 2020
1. "Participating Merchants" means select merchants that are part of the Club program, namely retail merchants located at any Hong Kong premises operated by the Hysan Group, including but not limited to the Lee Gardens area (Hysan Place, Lee Garden One, Lee Garden Two, Lee Garden Three, Lee Garden Five, Lee Garden Six, Leighton Centre, Lee Theatre Plaza, One Hysan Avenue and 25 Lan Fong Road).