Latest update: 31 October 2021

Keppel Hong Xiang Management Consultancy (Shanghai) Co., Ltd. and other Keppel Land China entities related to you (hereinafter referred to as “Keppel Land China” or "we") attaches great importance to the protection of your personal information. The "Privacy Policy" (hereinafter referred to as “the Policy”) is formulated in accordance with relevant Chinese laws, regulations and standards, and aims to explain how we collect, process and protect your personal information and how you can protect your legal rights and interests.

This Policy will help you understand the following:

1. How do we collect and use your personal information
2. How do we use Cookies and other similar technologies
3. How do we store your personal information
4. How do we entrust the processing, share, transfer and publicly disclose your personal information
5. How do we protect your personal information
6. Your rights
7. How do we process children's personal information
8. How this Policy will be updated
9. How to contact us

The Policy applies to our website、mini program hereinafter referred to as the "platforms") and our services. When you use our website、mini program or accept our services, we may collect and use your relevant information. Before you use our platforms and/or services, please read carefully and confirm that you have fully understood the content of the Policy, and make the choices you think are appropriate in accordance with the guidelines of the Policy. We use bold and italicized text to remind you of sensitive information concerning your personal information in the Policy.

Unless otherwise instructed, disagreement to the Policy or its updates (we will notify you of such updates in time) may affect your normal use or continued normal use of our platforms and/or services.

If you have any question or concern about the Policy or related issues, please contact us through the contact information provided in “9. How to contact us”.

1. How do we collect and use your personal information

1.1 The circumstances and types of our collection of your personal information

(1) Account Registration

For the purposes of registering your account for the platform, we will collect your WeChat authorization information (including the nickname of the WeChat account, the profile photo of the WeChat account and other information authorized by you);
If you refuse to provide the aforementioned necessary information, you will not be able to complete the account registration.

(2) Provide you with our services

In order to provide you with our services, we will collect the following personal information from you:

• When you receive membership gifts, you need to provide us with your basic information, including your name, contact address, etc.
• You need to provide us with your mobile phone number and mobile phone verification code when you use the platform's Internet access, consultation and complaint functions.
  If you refuse to provide the aforementioned information, you will not be able to obtain the corresponding services, but your access to our other services will not be affected.

(3) Safety and Management

(4) Provide you with a more comfortable service experience

In order to provide you with a more comfortable service experience, we may collect the following personal information about you:

• Log information: When you use the products or services we provide, we will automatically collect the information related to your detailed usage. For example, your IP address, browser type, telecom operator, language used, date and time of visit, records of pages you browse, abnormal status of applications, and other system activity information;
• Device permission call: In order to provide convenient and high-quality services, we may call some permissions of your device. The following is a list of device permissions that we may call and the corresponding description of the purpose of use. You have the right to close the authorization of the following permissions at any time, but it may affect your normal use of some functions of the platforms.
  (a) Device information: According to the device model and permissions granted during the installation and use of the platforms, we will collect information about the device using the platforms, such as device model, device settings, unique device identifiers, etc.
  (b) Camera: You need to authorize us to use the camera permission for taking pictures of relevant files (for example, taking pictures of the corporate certification materials) and facial photos.

(5) Customer Service

When you contact our customer service, in order to protect the security of your account, we need you to provide the necessary personal information to verify your identity. In order to facilitate contact with you and help you solve the problem as soon as possible or record the solution and results of related problems, we may save your communication/call records and related content (account information, other information you provide to prove relevant facts, or the phone number, email address and other contact information you left).

(6) Other additional services

In order to improve and enhance our services, we may learn your opinions or intentions from you through questionnaires, opinion solicitation or other marketing survey activities. If you choose to participate, you may be required to provide your name, gender, age, preferences, and enjoyment and other personal information.

(7) We obtain your personal information from third parties

We may obtain your personal information indirectly from third parties, but this happens only when we confirm that these third parties have obtained your consent for sharing relevant data with us, or the third parties are legally permitted or required to disclose your personal information to us.

We will require the third party to make a commitment to the legality and compliance of the source of personal information. If the third party violates the commitment, we will explicitly require such third party to bear the corresponding legal responsibility.

We will understand the scope of consent for the processing of personal information that the third party has obtained, including the purpose of use, whether the personal information subjects agree to transfer, share, publicly disclose, delete their personal information.

The personal information obtained from third parties will be used to provide services to you, and to ensure the accuracy of your related records in our possession. If our processing of such personal information exceeds the scope of consent that the third party has obtained, we will obtain your express consent directly or through the third party that has provided the information within a reasonable period of time upon we obtain such personal information or before we process such personal information.

To avoid ambiguity, the personal information collected in one of the above situations may also be collected in the other situations mentioned above. The types of personal information listed in each situation are not exhausted.

1.2 Our purpose to use your personal information

We will use the above personal information and other similar information generally for the following purposes:

(1) Providing you with relevant services (including the performance of our obligations under such service contracts with you);

(2) Setting up, operating, maintaining, managing or improving our services, related business functions (including the development of new services or business functions) or any account you have in our system, and provide related support services (such as processing orders and other service applications);

(3) Maintainting, testing or operating the systems (including those of our service providers) required for the provision of any of our services, or in connection with the web site(s) or mobile application;

(4) Facilitating interconnection and inter-operability between service providers in connection with providing services to you;

(5) Responding to and dealing with enquiries, complaints and other customer-care activities;

(6) Evaluating, processing, responding to or otherwise processing your inquiries, requests, feedbacks, questions, instructions, complaints or other customer-care related activities;

(7) Verifying your identity and processing orders and applications for services;

(8) Carrying out credit checks, for the preparation of credit reports and/or for the evaluation of creditworthiness;

(9) Marketing, promotion (including offer to sell you any other products or services), improve and/or further the provision of services to you by us, or by our affiliates, partners, contractors or third-party service providers;

(10) Sharing relevant information with our affiliates and partners to carry out market research, planning, customer surveys, trend analysis and/or other forms of data analysis in order to better tailor offers, promotions and/or other direct marketing to you;

(11) Providing supplementary or value-added services;

(12) Providing and manage customer loyalty benefits, reward benefits, promotional benefits, contests, lucky draws and other related benefits;

(13) Conducting market research, planning, customer surveys, trend analysis and/or other relevant forms of data analysis;

(14) Keeping you informed of our products and services as well as those of our affiliates and partners;

(15) Conducting training and/or improving our service quality and/or marketing and advertising strategies;

(16) Improving your user experience and/or the products and services delivery to you;

(17) Establishing, enhancing and/or further improving payment systems, including their interfaces or interactions with the systems of other financial institutions, merchants and/or payment institutions;

(18) Seeking professional advice, including legal advice, or enforce your obligations or enforce our rights, including, without limitation, collection of amounts owed by you or by any other person, or defending our rights, the rights of any related corporations, partners, contractors and/or third party service providers;

(19) Conducting investigations or taking action in relation to bad debts, crime and fraud prevention, detection of prosecution, risk management, violation of our terms and conditions for services, or to prevent any individual from harm, illegal or unlawful activities;

(20) For internal/external audit or compliance purposes;

(21) Complying with regulatory, compliance or legal or regulatory requirements and/or relevant obligations;

(22) As permitted or required by applicable laws and regulations, industry codes or market rules;

(23) Any other purpose necessary, ancillary or consequential to the above specific purposes.

When we intend to use personal information for other purposes not specified in this Policy, we will ask for your consent in advance.

When we intend to use personal information collected for a specific purpose for other purposes, we will ask for your consent in advance.

1.3 Exceptional circumstances

To the extent permitted by law, we can collect and use your personal information in the following circumstances without your authorized consent, and we may not respond to your request for correcting/modifying, deleting, cancelling information, withdrawing consent or demanding information:

(1) The processing is necessary for the conclusion or performance of a contract to which you are a contracting party, or for conducting human resource management under the labor rules and regulations developed in accordance with the law and a collective contract signed in accordance with the law;

(2) The processing is necessary to fulfill statutory functions or statutory obligations;

(3) The processing is necessary to respond to public health emergencies or protect the life, health or property safety of natural persons under emergency circumstances;

(4) Personal information is processed within a reasonable scope to conduct news reporting, public opinion-based supervision, or other activities in the public interest;

(5) The processing of the personal information that has been disclosed by the individuals themselves or other personal information that has been legally disclosed is within a reasonable scope in accordance with Personal Information Protection Law, except that it has a major impact on the individual’s rights and interests; or

(6) Under any other circumstance as provided by any law or administrative regulation.

2. How do we use Cookies and other similar technologies

To let you get a better visit experience and to recommend content that you may be interested in, we will use cookies and similar technologies such as pixel tags/beacons and scripts (hereinafter collectively referred to as "Cookies"). With the help of Cookies, we can store information about visits and visitors, and provide you with better and more services through analysis of such information. If you click "agree" when the Cookies notification is displayed, it means that you agree that we use Cookies to provide services to you.

You can modify your acceptance of Cookies or reject our Cookies, but rejecting Cookies may cause you to be unable to use some of the service functions that rely on Cookies in some cases.

3. How do we store your personal information

All your personal information is stored on locally secure servers in the People's Republic of China (for the purposes of this Policy, excluding Hong Kong, Macao and Taiwan) and protected in controlled facilities. We will classify your data according to importance and sensitivity, and ensure that your personal information is in the necessary security level. Employees who access this information to provide services to you will undertake strict obligations of confidentiality. Similarly, we will take special access control measures for data storage to prevent unauthorized access and use.

During your use of our services, we will continue to save your personal information in principal for a period not exceeding the period necessary to provide you with services. After you terminate your use of our services, we will delete or anonymize your information, unless otherwise stipulated by laws and regulations for the retention period of specific information, or to protect our rights in the court (e.g. for the sake of limitation of action). If we stop operating the platforms, we will delete or anonymize your personal information in accordance with applicable laws within a reasonable period of time. If such measures cannot be taken (for example, because your information has been stored in the backup archive), we will safely store your personal information and avoid further processing until such information can be deleted as prescribed by law.

4. How do we entrust the processing, share, transfer and publicly disclose your personal information

4.1 Entrustment of processing

Some functions of our system may be provided by external service providers. For example, we may engage a professional data processing service organization to provide technical support in data analysis.

For companies, organizations and individuals that we entrust to process personal information, we will sign strict confidentiality agreements with them, require them to process personal information in accordance with our requirements, this Policy and any other relevant confidentiality and security measures.

4.2 Sharing

We usually do not share your personal information with any other companies, organizations or individuals, except in the following circumstances:

(1) We may share your information with our affiliated companies. We will only share necessary information and are bound by the stated purpose in the Policy. If the affiliated companies intend to change the purpose or the method of information processing, we will ask for your consent again.

(2) We may share your information with our authorized partners, such as our service providers (including companies that assist in system processing, the operation management teams of relevant properties, property management teams, logistics companies, etc.) to ensure the provision of our products and/or services, and for the purposes listed in “1. How do we collect and use your personal information”. However, we will share your personal information only for legal, legitimate, necessary, specific and clear purposes, and will only share the information necessary to achieve the above-mentioned purposes. Our partners have no right to use the shared information for any other purpose.

(3) We may share your personal information in accordance with laws and regulations, needs of litigation dispute resolution, or mandatory requirements of administrative and judicial organs. If such circumstances are involved, we will inform you of such information sharing, except otherwise provided by laws or administrative regulations.

If we need to share your information with companies, organizations and individuals other than those listed above, we will ask for your consent separately.

For companies, organizations and individuals whom we share personal information with, we will sign strict confidentiality agreements with them, ask them to process personal information in accordance with our instructions, the Policy and any other relevant confidentiality and security measures.

4.3 Transfer

We will not transfer your personal information to any company, organization or individual, except in the following circumstances:

(1) After obtaining your explicit consent, we will transfer your personal information to other parties;

(2) In the case of mergers, acquisitions, dissolution or bankruptcy liquidation, if the transfer of personal information is involved, we will inform you of such transfer, and will require new companies and organizations that hold your personal information to continue to be bound by the Policy, otherwise we will ask the company or organization to ask for your consent again.

4.4 Public disclosure

We will publicly disclose your personal information only under the following circumstances:

(1) After obtaining your explicit consent;

(2) Disclosure based on law: we may publicly disclose your personal information according to the compulsory requirements of laws and regulations, legal procedures, litigation, or government authorities.

5.How do we protect your personal information

We attach great importance to the security of your personal information. For example, we use encryption, desensitization and other technologies to improve the security of personal information; we use trusted protection mechanisms to prevent malicious attacks on personal information; we deploy access control mechanisms to prevent unauthorized access; we organize security and privacy protection training courses. The measures we take are designed to provide you with a level of security protection that matches the risks arising from the processing of your personal information.

We will take reasonable and feasible measures and try our best to avoid collecting unnecessary personal information.

Although there is no 100% secure network transmission or electronic storage method, which prevents us from guaranteeing the absolute security of personal information, we will take appropriate technical and organizational safeguard measures to protect your information from being stolen, lost, misused and from any unauthorized access, reproduction, collection, use, disclosure, alteration or destruction.

In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions on what you can do to independently prevent and reduce risks, and remedies for you, etc. We will promptly inform you of the incident by email, letter, telephone, push notifications, etc. At the same time, we will also proactively report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities.

6. Your rights

6.1 Access your personal information

Except as otherwise provided by laws and regulations, you have the right to log into your account at any time to access your personal information on your own.

You can also contact us through the contact information provided in “9. How to contact us” to exercise this right.

6.2 Correct and supplement your personal information

When you find that your personal information that we are processing is inaccurate or incomplete, you have the right to ask us to correct or supplement it. You can log into your account to correct or supplement your personal information by yourself.

You can also contact us through the contact information provided in “9. How to contact us” to exercise this right.

6.3 Delete your personal information

In the following circumstances, you can request us to delete personal information through the contact information provided in "9. How to contact us":

(1) If our processing of personal information violates laws and regulations;

(2) If we collect and use your personal information without your consent;

(3) If you withdraw your consent after you have consented to our collection and use of your personal information;

(4) If our processing of personal information violates the agreement with you;

(5) If you no longer use our products or services, or you have cancelled your account;

(6) If we no longer provide you with products or services;

(7) If the purpose of processing your personal information has been achieved, cannot be achieved, or it is no longer necessary to achieve the purpose of processing;

(8) If the retention period of your personal information has expired.

If we decide to respond to your request to delete your personal information, we will also notify the entities that have obtained your personal information from us and require them to delete your personal information in a timely manner, unless laws and regulations provide otherwise, or these entities have obtained your independent authorization.

When you delete information from our platforms, we may not delete the corresponding information in the backup system immediately, but we will delete the information when the backup system is updated.

6.4 Change the scope of your authorization or withdraw your authorization

Within the scope of your authorization to collect and process your personal information, you can change the scope of your authorization to process your information or withdraw your authorization by changing the settings or contact us.

For example, we will use algorithms to push commercial promotion and service information to your intelligent terminal device, but you have the right to unsubscribe at any time. You can unsubscribe by changing the settings in your smart terminal device. You can also contact us through the contact information provided in "9. How to contact us" to exercise this right.

Please understand that each business function requires some necessary information to be completed. After you withdraw your consent or authorization, we will no longer be able to provide you with the functions corresponding to the consent or authorization that you have withdrew, and will no longer process your corresponding information. However, your decision to withdraw your consent or authorization will not affect the information processing carried out previously based on your authorization.

6.5 Cancel your account

You can log in to your account and cancel it by yourself.

You can also contact us through the contact information provided in “9. How to contact us” to exercise this right.

6.6 Obtain a copy of personal information

You can log in to your account and obtain a copy of your personal information by yourself.

Provided that it is technically feasible and meets the conditions set forth by the National Internet Information Department, we may also transfer a copy of your personal information directly to a third party designated by you at your request.

You can also contact us through the contact information provided in “9. How to contact us” to exercise this right.

6.7 Obtain the Explanation of this Policy

You may request an explanation of this Policy by contacting us through the contact information provided in "9. How to contact us".

6.8 Restrict automated decision-making by information system

In some business functions, we may make decisions only based on non-manual automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legitimate rights and interests, you have the right to ask for an explanation from us, and have the right to reject our decisions made solely through automated decision-making, and we will also provide appeal methods without infringing on our trade secrets, other users’ rights, and social public interests.

6.9 Respond to your above request

To ensure safety, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request.

We will respond to your request within thirty (30) days. If you are not satisfied or have any question, you can contact us through the contact information provided in “9. How to contact us”.

For your reasonable request, we do not charge fees in principle, but for the requests that are repeated or exceed reasonable limits, we will charge a certain cost depending on the circumstances. We may reject your requests if they are technically difficult to fulfill, or they are not required to be responded to in accordance with laws and administrative regulations, or responding to your requests would violate laws and administrative regulations. We will give you an explanation when we reject your requests.

7. How do we process children’s personal information

Our platforms, products and/or services are mainly adult oriented. Without the consent of their parents or guardians, children are not allowed to create their own accounts.

We will not proactively collect personal information from children directly. For the collection of children's personal information with the consent of the guardians, we will use or publicly disclose this information only when it is permitted by laws, with the consent of the guardians, or is necessary to protect the children.

We consider anyone under the age of 14 as a child.

If we find that we have collected children’s personal information without prior verifiable parental consent, we will try to delete the relevant data as soon as possible.

8. How the Policy will be updated

We may update the Policy in due course to adapt to the development of law, technology or business. However, without your explicit consent, we will not reduce your rights under the Policy.

We will publish the latest version of the Policy on this page. You can check the latest update time of the Policy at the “latest update” at the top of the Policy. If we make major changes to the Policy, we will notify you in an appropriate manner. If you continue to use our services after the Policy is changed, it means that you have fully read, understood and are willing to be bound by the revised Privacy Policy. Such changes in the Privacy Policy will be applicable from the effective date specified in the notification. If you do not agree with the updated Privacy Policy, you should stop visiting or using our platforms.

The major changes referred to in the Policy include but are not limited to:

(1) Major changes in our service mode, e.g. the purpose of processing personal information, the type of processed personal information, and how personal information is used;

(2) Major changes in our ownership structure, organizational structure, e.g. the change of owners due to business adjustments, a(n) bankruptcy, merger and acquisition.

(3) Changes of the main objects which the personal information is shared, transferred or publicly disclosed to;

(4) Major changes of the rights that you participate in processing of personal information and the way to exercise such rights;

(5) The changes of our responsible department, contact information and complaint channels for personal information security;

(6) When a personal information security impact assessment report indicates high risks.

9. How to contact us

We have set up the personal information protection officer and you can contact him/her through the following ways: dpo@keppellandchina.com

We will review the issue as soon as possible and respond within thirty (30) days after verifying your identity.

If you are not satisfied with our reply, or if you think that our personal information processing method hurts your legitimate rights and interests, you can negotiate with us to resolve it. If the negotiation fails, you can and agree to submit relevant disputes to the people's court with jurisdiction where we are located and apply the laws of the People's Republic of China (excluding Hong Kong, Macau and Taiwan) for legal settlement.