General Privacy Notice
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Privacy notice and summary‍
Vanke is committed to respecting and protecting your privacy. This privacy notice sets out how we look after your personal data when you provide your personal data to us (whether on your own behalf or on behalf of an organisation) or we provide you with relevant products or services, including in respect of property transactions (our "Services"); and tells you about your privacy rights and how certain laws may apply to you.Please note that if you have joined the Vanke Club or visited our website(s), you may be given additional privacy notices which are also relevant.If you have any queries about this notice or how we use your personal information, please contact us atIf you have any queries about this notice or how we use your personal information, please contact us at datainquiry@vanke.com.
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Contents
1. About us
2. What personal data do we collect?
3. How and why we collect personal data
4. How we share personal data
5. International transfers
6. Data security
7. How long we keep personal data
8. Your rights
9. Changes to this notice or your data

1. About us
Our Services are provided by Vanke Property (Hong Kong) Company Limited ("Vanke", also referred to in this notice as "we", "us" and "our") and/or our subsidiaries, holding companies and other group companies. Vanke's registered office is at 55/F., Bank of China Tower, 1 Garden Road, Central, Hong Kong.
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2. What personal data do we collect?
'Personal data' means any data which can be associated with you as an individual, either directly or indirectly. We collect different information depending on how you use our Services and how you interact with us.
The personal data we collect via the Services may include:
• Identity information, such as your name, date of birth, sex, the number of people in your household, your educational level, personal identification number, identity card or passport information, your organisation and position, any relevant professional licence or registration you may hold, and your personal interests and hobbies.
• Contact data, such as your address and email and telephone details.
• Preferences you have expressed in relation to an actual or potential property transaction (including but not limited to a sale, purchase, lease and/or licence).Financial information, including your bank account number and bank cashier order numbers.
• Marketing and communications data, including any communications we may receive from you, and your preferences in receiving notifications, marketing and other communications from us and third parties.
If you contact us, we will collect further personal data about you that you choose to provide to us.
Our Services are not intended for collecting or storing 'special categories' of personal data, such as details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, or health information. We do not intentionally collect data about actual or alleged criminal offences via our Services. Our Services are not intended to collect data of children under the age of 18.
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3. How and why we collect personal data?
We only collect the personal information that you give us.
We will only use your information where:
a) We need it to perform a contract or provide a service that you or your organisation has asked forFor example, we will use your identity and contact details to verify who you are and for anti-money laundering purposes, to communicate with you about our Services, to facilitate providing our Services to you, and to respond to any requests, queries, issues or concerns you may have. If you do not provide us with this Information, we may be unable to provide the relevant Services.
b) We have a legitimate interest (reasonable business purpose) for doing soWe will use your information for our legitimate business reasons where our doing so will not unduly affect your rights. For example, we use all data to keep our records up to date, and develop new and improved Services.
We may also use any or all of the information above to administer and manage our business in general. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know.
c) You have given us permission to do soIf you have signed up to our mailing lists and/or given to us relevant consents we will send you marketing materials in respect of our Services or the services or products of our business partners, including newsletters, updates, and information in respect of your membership, including offers and promotions that we feel may be of interest to you. You can unsubscribe from these emails at any time by following the unsubscribe link or instructions provided in any email we send, by writing to us at our registered address, or by emailing us at datainquiry@vankeclub.com.hk.
For information about how we share information with third parties for marketing purposes, please see Section 4 below.
d) We need to comply with a legal or regulatory obligationIn certain circumstances, we may need to retain or use your data to comply with regulations and/or the law.
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4. How we share personal data
Personal information collected is shared with China Vanke, Co. Ltd and Vanke Holdings (UK) Limited and their respective subsidiaries (together, the "Vanke Group").
We may share your information with our trusted service providers, including our technical suppliers (such as our email hosts). When we share your information with our service providers, we will ensure that your data is kept secure and used only in accordance with this notice.
We will also share your information with third parties as necessary to provide you with the Services. This includes (but is not limited to) any vendor(s) from whom you will purchase the property, estate agents, lawyers, and banks.
Where you have consented to our doing so, we will share information with third parties and other business partners to provide you with marketing materials that we think may be of interest to you.
On rare occasions, we may share personal data when we believe it is necessary to comply with the law, regulation or legal request (including a court order or government inquiry); with our professional advisors; to enforce or apply our terms of use or other agreements; in the context of a company sale, investment, reorganisation or restructuring exercise; or to protect the rights, property, or safety of Vanke, our employees, our users, or others.
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5. International transfers
When we transfer your data to a country which the European Commission does not deem to have adequate data privacy laws, we will ensure that such transfer(s) are in accordance with applicable data privacy laws. In respect of transfers within the Vanke Group, we have executed a data transfer agreement giving effect to the Model Clauses pursuant to Commission decision 2004/915/EC.
In respect of transfers outside of Vanke, we either implement the Model Clauses pursuant to Commission decision 2004/915/EC or 2010/87/EU (as appropriate) with the recipient of your personal data; and/or ensure that the recipient of your data is registered with the EU-US Privacy Shield.
You can obtain further information in this respect (including a copy of the Model Clauses) by contacting us.
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6. Data security
The safety of your personal data is important to us, and we use various technical and organisational measures to ensure that your data is secure.
Vanke employs encryption, data security, and intrusion prevention technologies to protect and secure all personal information in our possession. However, the transmission of information via the Internet is not completely secure. Although we take appropriate measures to safeguard against unauthorised disclosures of information, we cannot guarantee the security of your data.
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7. How long we keep personal data
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
To find out more about how long we retain personal data, please contact us at datainquiry@vanke.com.
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8. Your rights
You have certain rights over your personal data. If the GDPR applies, you may:
• require us to rectify the personal data we hold about you, where that data is incorrect;
• require that we restrict the processing of your personal information in certain circumstances;
• request access to the personal data that we hold about you;
• require that, in certain circumstances, we delete the personal information we hold about you;
• require that we provide you with the information that we hold about you in a structured, commonly used and machine-readable format; and/or
• withdraw your consent to our using your data for marketing purposes at any time.If the GDPR applies, you also have the right to lodge a complaint with the appropriate supervisory authority. We would, however, be grateful if you would contact us in the first instance so we can endeavour to deal with your concerns direct.
If you wish to exercise any of these rights or have any queries in relation to them, please contact us at datainquiry@vanke.com, or by writing to our address listed above. To protect your privacy and security, we will take reasonable steps to help verify your identity before granting access or making corrections.
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9. Changes to this notice or your data
We may amend or modify this privacy notice from time to time and will notify you of any changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This privacy notice was last updated on 12 November 2019.
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© 2019 Vanke Holdings (Hong Kong) Company Limited.