Hang Lung Group Limited, Hang Lung Properties Limited, as well as their associated companies, branches, representative offices and other affiliated or related companies from time to time (collectively “our Group”, “we” or “us”) are committed to protecting your personal data privacy in accordance with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of The Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”)) (the “Ordinance”).
We shall take appropriate steps to ensure compliance by our staff of this Privacy Statement. Please read the following carefully to understand our policy on personal data privacy protection.
Collection of Personal Data
Depending on your relationship or interaction with us, we may collect Personal Data from you through our websites, mobile applications, forms, platforms, premises or facilities, or through other online and offline channels. We may also generate and compile information about you. Personal information and particulars provided by you and all information gathered and compiled by us about you from time to time is collectively referred to as “Personal Data”.
All Personal Data collected by us is provided on a voluntary basis, unless we indicate that the provision of certain Personal Data is mandatory for a particular purpose. You are not obliged to provide your Personal Data. However, if you do not provide the Personal Data requested, we may be unable to process the relevant request, application, enquiry or transaction, provide or administer the relevant services, facilities, memberships, programmes or activities, manage the relevant relationship with you, or otherwise carry out the purposes for which the Personal Data is collected.
If we wish to collect your Personal Data directly from you, we will first provide you with a Personal Information Collection Statement, which sets out the purposes for which we will use your Personal Data, the classes of persons to whom your Personal Data may be transferred, and the rights you have to access and correct your Personal Data.
We generally collect Personal Data directly from you. Where appropriate, we may also collect your Personal Data from other sources, including:
• members of our Group;
• corporate tenants, business partners, contractors, service providers and authorised representatives;
• employees, referees, recruitment agencies and background-check providers;
• publicly available business or employment-oriented social networking services and job boards and other public records; and
• other lawful sources.
Personal Data We Collect and How We Use It
The types of Personal Data we collect and the purposes for which we use it depend on your relationship or interaction with us. The categories, examples of Personal Data and purposes described below are provided for illustration only, are not exhaustive, and do not necessarily apply to every individual, interaction or service. We may also use Personal Data for incidental or associated purposes directly related to the purposes described below, or for another purpose to which you have agreed.
Customers, members and users of our facilities and services
Personal Data we may collect:
• your name and contact details;
• membership and account information;
• information required to verify your identity;
• transaction, membership, rewards and participation records, including receipts, points and redemptions;
• booking, reservation and facility-usage information;
• preferences, interests, enquiries, feedback and communication records; and
• website, application and service-usage information.
We may use such Personal Data for one or more of the following purposes, as applicable:
• providing, administering and supporting our products, services, facilities, memberships, accounts, bookings, reservations, customer programmes and related transactions;
• verifying identity and processing payments, transactions, points, privileges, rewards and redemptions;
• communicating with you, responding to enquiries, complaints and requests, and providing customer support;
• operating and administering customer relationship management programmes, membership clubs, loyalty programmes and reward programmes;
• conducting research, surveys, statistical analysis and data analysis to understand trends, preferences, interests, experiences and habits, and to design, evaluate and improve our services, products, facilities, programmes, activities and customer experience;
• administering events, promotions and related activities; and
• direct marketing, including sending you marketing materials and promoting services and products to you, subject to your consent being obtained in accordance with the section “Use and Transfer of Personal Data in Direct Marketing” below.
Purchasers, tenants, licensees and other business contacts
Personal Data we may collect:
• your name, contact details, job title, employer and business contact details;
• identification information and information concerning your authority or representation;
• property enquiries, applications, registrations of interest, correspondence, negotiation and contractual records;
• information required for due diligence, identity verification, compliance checks or credit assessment;
• information relating to property sales, purchases, leases, licences, payments, deposits and other financial administration; and
• complaint, incident, claim and dispute information.
We may use such Personal Data for one or more of the following purposes, as applicable:
• responding to property sales, leasing, licensing, procurement and other business enquiries, applications or registrations of interest;
• conducting identity verification, due diligence, compliance checks and credit assessment;
• negotiating, entering into, administering and enforcing property sale and purchase agreements, leases, licences, contracts and other commercial or operational arrangements, including payment, completion, handover, post-sale matters, defaults, disputes and relationship management; and
• marketing and selling properties, subject to the section “Use and Transfer of Personal Data in Direct Marketing” below.
Owners, residents, occupiers and visitors of our managed properties
Personal Data we may collect:
• your name, address, unit, contact and identification information;
• property, occupancy, access, visitor, parking, facility-usage and other property-management records;
• repair, maintenance, service-request and complaint records;
• correspondence and resident communications;
• CCTV images and video footage; and
• information relating to incidents, accidents, security, emergencies, insurance and claims.
We may use such Personal Data for one or more of the following purposes, as applicable:
• providing and administering property management, resident, facility, access, visitor, parking, maintenance, security and related operational services;
• verifying ownership, occupancy, authorisation or identity, where appropriate;
• responding to repair, maintenance and service requests and communicating with owners, residents, occupiers and visitors;
• administering facilities and enforcing applicable house rules;
• protecting the safety and security of persons and property, including through CCTV monitoring, access control, incident prevention and investigation; and
• investigating and handling complaints, accidents, incidents, emergencies, insurance matters and claims.
Job applicants, employees and other personnel
Personal Data we may collect:
• identification and contact information;
• date of birth, address and employment-related particulars;
• recruitment, employment and personnel-administration information, including qualifications, references, remuneration, payroll, attendance, leave, benefits and training records;
• bank account information for payroll and expense reimbursement;
• travel-document and related information for business travel;
• medical and health-related information provided for leave administration, employees’ compensation, benefits, workplace health and safety or other employment-related purposes;
• workplace access, security, incident and investigation information; and
• information relating to the administration and cessation of employment or engagement.
We may use such Personal Data for one or more of the following purposes, as applicable:
• recruiting and assessing suitability for employment, internship or other engagement;
• administering and managing the employment or work relationship;
• administering payroll, remuneration, expense reimbursement, leave, training, benefits, travel and other personnel matters;
• handling workplace injuries, occupational health and safety matters, employees’ compensation and related claims;
• managing workplace access, security, health, safety and emergency arrangements; and
• responding to employment-related enquiries, complaints, disputes, incidents and investigations.
Individuals whose Personal Data is provided by an employee
We may collect identification, contact, relationship, reference and benefit-related information about individuals whose Personal Data is provided by an employee, including emergency contacts, referees and eligible dependants.
We may use such Personal Data for one or more of the following purposes, as applicable:
• contacting the relevant individual in an emergency or urgent situation;
• obtaining and considering employment references;
• administering voluntary medical-benefit enrolment for eligible spouses and children and verifying eligibility; and
• handling related benefit claims, enquiries and administration.
Other individuals who interact with us or participate in our activities
We may also collect Personal Data concerning the following persons:
• complainants, enquirers, claimants, witnesses and persons involved in accidents or incidents;
• participants, registrants, guests, speakers, performers, interviewees, survey respondents, competition entrants and prize recipients in connection with our events, campaigns, promotions, competitions, surveys, community programmes, educational activities, heritage or archival projects and other activities;
• individuals whose information is provided by a tenant, business partner, contractor, employee or authorised representative; and
• other persons whose Personal Data is received from a lawful source in connection with our operations.
Depending on the relevant activity, the Personal Data we collect may include:
• name, contact details and registration or participation information;
• registration, attendance, participation, entry, submission, response, feedback and survey information;
• information (such as age and age range) required to administer eligibility, judging, prizes, awards or acknowledgements;
• photographs, images, voice, audio or video recordings, interviews, quotations and other contributed content; and
• payment or reimbursement information, where applicable.
We may use such Personal Data for one or more of the following purposes, as applicable:
• handling enquiries, complaints, claims, accidents, incidents, disputes and investigations;
• administering events, campaigns, promotions, competitions, surveys, community programmes and other activities, including registrations, eligibility, communications, participation records, prizes, awards and acknowledgements;
• conducting surveys, research and analysis to evaluate and improve our activities, services and engagement initiatives;
• using photographs, recordings, interviews, quotations and other contributed content to document, report on, promote or preserve records of the relevant activity, as notified to the relevant individual; and
• communicating with the relevant individual and administering the relevant activity or relationship.
General purposes applying across the above categories
We may also use Personal Data collected across the above categories for the following purposes:
1. complying with legal and regulatory requirements, and conducting audits, maintaining records, managing risks and handling disputes;
2. making disclosures required by law, regulation or court order, or requested by a governmental, regulatory, law-enforcement or administrative authority;
3. establishing, exercising or defending legal claims, obtaining legal advice, taking enforcement or legal action, and defending and/or protecting the rights or properties of any member of our Group, including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person could be harmed or property of any other person could be damaged by such interfering activities;
4. detecting, preventing and responding to fraud, misuse, unlawful activities, security threats and breaches of our policies or terms; and
5. any other incidental or associated purposes relating to the above, or any other purpose to which you may from time to time agree.
Disclosure and Transfer of Personal Data
Personal Data held by us will be kept confidential but we may provide or transfer the Personal Data for the purposes mentioned above to:
1. any member of our Group;
2. any agent, contractor or third party who provides administrative, information technology, marketing and research, cloud, data processing, telemarketing, telecommunications, payment, computer or other services to us and/or our Group and who has a duty of confidentiality to the same;
3. other business partners (e.g. loyalty programme operators/other companies involved in providing customer services);
4. credit reference agencies, credit, debit and/or charge card companies and/or banks;
5. recruitment, background check, payroll, benefits, medical, training, travel and other employment-related service providers;
6. any person to whom our Group is under an obligation to make disclosure under the requirements of any law binding on our Group or for the purposes of any guidelines issued by regulatory or other authorities with which our Group is expected to comply;
7. any person under a duty of confidentiality to us (including our accountants, auditors, legal advisors or other professional advisors); and
8. any other person authorised by the relevant data subject or permitted by law.
We may transfer your Personal Data to the above parties outside Hong Kong for the purposes mentioned above.
Use and Transfer of Personal Data in Direct Marketing
From time to time with your consent, we and any of the Permitted Classes of Persons (as defined below), intend to market or promote goods, services, facilities, activities or promotions within the Classes of Marketing Subjects (as defined below) to you. We may not use or provide your Personal Data for direct marketing purposes without obtaining your consent (which we will seek to obtain at Personal Data collection points either in data collection forms or on our website or through the “Hang Lung Malls App (恒隆商場手機應用程式)” and activities incidental to operating and administering the “hello Hang Lung Malls Rewards Program (hello恒隆商場獎賞計劃)”) in accordance with the applicable laws, rules and regulations.
In connection with the above, we intend to:
1. use your name and contact information to market and promote the following categories of goods or services: properties (both residential and commercial), restaurants and dining privileges, hotels, spa facilities and services, sporting equipment/activities and facilities, cinemas, entertainment/cultural activities and facilities, books and stationery, toys and educational goods, clothing, footwear, fashion accessories, food and beverages, florists, eyewear, jewellery, watches, health and beauty products/services, motor vehicles, car parking facilities, banking and financial services, electronic appliances and home appliances/furnishings whether such goods and services are provided by our Group or by tenants of our commercial properties (collectively, the “Classes of Marketing Subjects”); and
2. provide your name and contact details to providers of any of the Classes of Marketing Subjects within and outside our Group (the “Permitted Classes of Persons”) so that they may send you direct marketing.
You may write to our contact at the address below or contact us via the contact information provided in our marketing materials to opt out of direct marketing from us or the Permitted Class of Persons at any time. We will never transfer your Personal Data for gain.
Retention of Personal Data
We will keep your Personal Data for as long as necessary to fulfil the purpose for which the Personal Data was collected. Personal Data which is no longer required will be securely deleted, anonymised or otherwise disposed of in accordance with our applicable retention practices.
Security of Personal Data
We will take appropriate measures to ensure that your Personal Data is properly protected. However, there is no security guarantee for any data transmission over the internet and you transmit all such data at your own risk. Once we receive your transmission, only our authorized employees or contractors will be able to access your Personal Data.
Links
Links on this website may link to websites maintained by other third parties. These third parties may have their own privacy policies and practices which might not be bound by this Privacy Statement. We make no representation or warranty regarding the accuracy, timeliness, suitability or any other aspect of the information and content on such websites. Access to and use of such other websites is at your own risk and subject to the terms and conditions applicable to such websites.
Web Logs/ Cookies
When you visit our website, we shall make a record of your visit only for preparing general statistics on the usage of this website to improve the effectiveness of our marketing and promotional activities. Unless we specifically indicate to you that we intend to collect your Personal Data and require you to check a box to agree to such collection, we do not collect any Personal Data from you during your browsing of this website.
We shall also place a cookie in your browser. A cookie is a small file which contains anonymous information about your preferences and navigation pattern in particular sites, including your IP (internet protocol) address, browser type and the city-level location of your internet service provider, thus enabling website owners to provide more useful features for their users. The data collected by means of “cookies” will not be disclosed to any third parties except to any member within our Group or the agents of our Group, will not be combined with any other information, and will only be used to provide troubleshooting services.
You may disable cookies by changing your browser settings, although this may affect your ability to use certain features of our website.
Access to and Correction of Personal Data
Pursuant to the Ordinance, you have the right to request access to and correction of your Personal Data held by us. Such enquiries or requests should be addressed to:
Data Protection Officer
Hang Lung Properties Limited
Address: 28/F, Standard Chartered Bank Building, 4 Des Voeux Road Central, Hong Kong
Email: privacyofficer@hanglung.com
We may charge a reasonable fee for handling any data access and correction requests.
Miscellaneous
In case of any discrepancy between the different language versions in respect of any part or all of this policy, the English version shall prevail.
We reserve the right to review, edit, vary or change this Privacy Statement at our sole discretion and without prior notice. If any amended version of the Privacy Statement results in any changes to the way we handle your Personal Data that require your consent, we will bring the amended Privacy Statement to your attention.
© 2026 Hang Lung Properties Limited. All rights reserved.
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