Privacy Statement

Privacy Statement

Introduction

Shui On Group (means Shui On Land Limited and all of its related subsidiaries and its affiliates, referred to as "Shui On Group", the "Group", "we", "us" and "our") takes individuals' privacy seriously. This Statement explains our policies and practices and applies to information collection and use. Shui On Group is a data controller and/or a data user which controls the collection, holding, processing or use of your personal data.

In order to provide better service to you, we may, in the course of and in relation to provision of our services or products, collect and process the following information about you while you are visiting and using any Online Services, such as our websites (the “Site”), online store, membership system, operation system, our application software (APP), our official accounts in Wechat, or providing us with your personal data via other means (including via our physical stores or telephone enquiries number, your application for or use of our services, such as our Privilege Cards or Private Sales, your consultation or purchase of residential properties from us or via your employment inquiry etc.).

We do not knowingly solicit any personal data or other information from any persons under the age of 18. If you are under 18, by visiting our Site you agree that you have informed your parents and guardians about the Privacy Policy Statement prior to such registration or use, and they have approved of such registration or use by you on the terms of the Privacy Policy. If it is proved that your guardians have not agreed for us to provide the relevant services and products to you and to collect relevant personal data, we may be required by the law to delete your data and stop providing the relevant products or services to you. If you are a child from an EU Member State, we need get your guardians’ express consent to allow your registration or use.

The provision of personal data by you is necessary in order for us to provide you with the requested services and for us to perform our contractual obligations (if any) to you. If you do not supply such data, we may be unable to provide the requested service. Certain personal data, such as data about your fingerprints, race or ethnic origin, religious or philosophical views or face information, is characterised as “sensitive” and is subject to stricter regulation than other personal data. Please note that content and information that you input to our services, may reveal your sensitive personal data. We urge you to consider whether it is appropriate to communicate sensitive personal data within our services.

Your personal data is stored securely in the Group’s system and the Group will take all practicable steps to ensure that personal data is not kept longer than is necessary for the fulfillment of the purpose (including any directly related purpose) for which the data is or is to be used.

In addition, when you browse the Site or use the application, we will collect the basic technical information that your browser sends to the Site such as your browser type and language, access times, the address of the site from which you came to the Site, your IP address, your device type or click stream data within our website or the application (i.e. the actions taken in connection with the Site) etc. We collect such technical information during your visit to the Site or use the application through our automatic data collection tools, which may include cookies and other commonly used technologies. We collect such data for the purpose of improving the functionality of the Site or the application. Further information on cookies is set out below. 

We use the personal data you provide to us for the following purposes (and any purposes directly related to these purposes) (collectively, the “Purposes”) in and outside China:

(a) Identifying and verifying your identity;

(b) Communicating with you in respect of your use of our services, products, mobile application(s) and/or website(s) (as the case may be);

(c) Information management and database administration;

(d) To provide our services to you (including assessing any application for and administration of such services);

(e) Matching your personal data with information you provided to us via other means; 

(f) Monitoring and analysing usage of our services, products, mobile application(s) and/or website(s) (as the case maybe) to help the further development and improvement of its services, products, mobile application(s) and/or website(s);

(g) Complying with laws, regulations or codes of practice in or outside China;

(h) Legal proceedings, including collecting overdue amounts;

(i) Prevention or detection of crime, and protection of the security and safety of our services and products;

(j) For the purposes of software verification or administering software upgrades;

(k) Other purposes directly relating to the activities identified above;

(l) We may conduct direct marketing, notification and delivery of related events, services and products of Shui On Group (and/or its partners and institutes) via fax, email, direct mail, telephone and other means of communication whether now or hereafter known, or send e-newsletters to you. You may choose not to receive aforementioned materials, by simply telling us , and we will cease to do so, without charge.

3.

Disclosure

We do not rent, sell, or share with third parties the Personal data we collect from you except (i) to provide information or services that you have requested;(ii) with your permission; or (iii) under the following circumstances:

A.  

For specific purpose, we may share your personal data within our group of companies and with joint venture partners and third party service providers, contractors and agents. In addition, we may allow such third parties to collect your Personal data across our services. In each case, we permit such sharing and/or collection for the purposes of:  

- providing our services to you;

- assisting us in carrying out the purposes set out under the “use of information” section above;

- carrying out our obligations and enforcing our rights under the this Privacy Policy Statement; and/or

- our business, including helping us better understand and improve our services.

These third parties may be located, and use and store your Personal data, outside of your jurisdiction for these purposes.

[Where we permit any third parties to collect and use your personal data in accordance with the above paragraph, we will use reasonable efforts to ensure that such third parties only use your personal data: (i) in compliance with this Privacy Policy Statement; and (ii) subject to any other instructions we give them, including any appropriate confidentiality and security measures that we implement.]  

B.

Even if you do not send us any Personal data, we will collect information regarding how you use our site (referred to as "Non-Personal data"). Non-Personal data cannot be used to identify your personally. Similar to many other sites, we obtain Non-Personal data such as IP addresses, browser types, the name of your ISP (internet service provider), information about where a user comes from before arriving at our Site, what pages a user visits, the order of those pages, and the amount of time spent on each. A vendor performs this service for us by sending a cookie to gather this information, compile it, and report to us. We use Non-Personal data to customize the content you see, improve our services, conduct research, and provide anonymous aggregated reporting for internal audits and third-parties.

A cookie is a small data file, usually including an anonymous unique identifier, which is sent from a web site's computer and stored on your computer's hard drive. Use of cookies is common on the Internet. A web site can send its own cookie to your browser if your browser's preferences allow it, but (to protect your privacy) your browser permits a web site to access only the cookies it has already sent to you, not the cookies sent to you by other sites. You can configure your browser to accept all cookies or reject all cookies, or notify you when a cookie is sent to you. (Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.) You can reset your browser to refuse all cookies or indicate when a cookie is sent to you. But if you refuse cookies, some parts of the Site will not function properly and may not provide services or information you have requested.

Personal data stored electronically are password-protected. Encryption technology is used on our secured web areas. Our computer systems are placed in restricted areas. We only permit authorized employees to access personal data. These employees are trained on our privacy policies.

The Site and other Online Services may, from time to time, contain links to external sites operated by third parties for your convenience. We have no control of and are not responsible for these third party sites or the content thereof. Once you leave the Site, we cannot be responsible for the protection and privacy of any information which you provide to these third party sites. You should exercise caution and look at the privacy statement for the website you visit.

We regularly review this Privacy Policy and may from time to time revise it by updating this page. By continuing to use our services after any amendments to this Privacy Policy, you are agreeing to this Privacy Policy as revised, so please do visit this page periodically for updates.

We will generally hold your data on our servers hosted in China. However, we may transfer it to our overseas offices elsewhere in the world for the purpose of processing into our database. If you are located in the European Economic Area (“EEA”) your personal data may be transferred to countries located outside the EEA which do not provide a similar or adequate level of protection to that provided by countries in the EEA. Such transfers will only be made in accordance with applicable laws including where necessary for us to comply with our contractual obligations with you. We will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Statement.

By using our service, making an application or visiting our Site and other Online Services, you acknowledge the collection and use of your personal data by us as outlined in this Statement. If you do not agree with the use of your personal data as set out in this Statement, or the Terms of Use, please do not use this Site or use our services.

You have the right:

•to check whether we hold personal data about you and to access such data

•to require us to correct inaccurate data or withdraw authorization

(After modification or withdrawal of the authorization for personal data collection and use, we will not collect, process or use personal data beyond of the modified authorization or withdrawal, but this modification or withdrawal will not affect the processing of personal data based on the prior authorization. Meanwhile, the modification or withdrawal of authorization for collection, processing and use of certain personal data, may result in the failure to provide the product or service normally)

•to ascertain our policies and practices in relation to personal data and the kind of personal data held by us.

If you are from an EU Member State, subject to certain limitations and/or restrictions, you have the right under the data protection laws in the EU:

•to request access to and rectification or erasure of your personal data;

•to obtain restriction of processing or to object to processing of your personal data; and

•to the right to data portability.

Individuals from the EU also have the right to lodge a complaint about the processing of their personal data with their local data protection authority.

If you wish to exercise one of the above mentioned rights, cease marketing communications, and/or raise questions or complaints please click Contact Us.

Where permitted by law to do so, we may charge a reasonable fee for processing a data access request.

If there is any conflict between the Chinese and English versions of this Statement, the English version prevails.