Private Policy

POLICY ON PERSONAL DATA

1. 218 Apartment value all personal information provided by their customers, and this note sets out 218 Apartment's policy and practices in relation to personal data and the Personal Data (Privacy) Ordinance (the "Ordinance").

2. The Ordinance protects the privacy of individuals by controlling the manner in which personal data may be collected, held, processed and used. Any personal information collected and recorded by 218 Apartment in relation to a customer, from which the identity of the customer can be ascertained, will be subject to regulation by the Ordinance.

3. From time to time, it will be necessary for customers to supply 218 Apartment with certain personal data in connection with the commencement or continuation of leasing, development, selling, buying, management or other related services (the "Services").

4. Failure to supply such personal data may result in the delay or inability of 218 Apartment to, or to continue to, carry out the Services.

5. Personal data will be used by 218 Apartment in connection with its provision or termination of the Services, in particular: -
(a) daily operation and performance of the Services;
(b) making credit analysis decisions;
(c) conducting credit checks to ensure customers' creditworthiness;
(d) recovery of any monies owed or liabilities incurred by a customer in relation to the Services;
(e) tracing debtors;
(f) any verification or exchange of information;
(g) in connection with matching for whatever purpose (whether or not with a view to taking any adverse action against a customer) any such personal data in 218 Apartment's possession with other personal data
concerning the customer;
(h) in connection with any system or facility for payment by electronic means or via communication media in which 218 Apartment participates;
(i) in connection with promoting, improving or furthering the provision of the Services by 218 Apartment to customers generally;
(j) in connection with the marketing or advertising of products and services to customers and/or solicitation of donations or contributions for charitable or other purposes;
(k) in connection with complying, or checking compliance, with any laws or regulations relating to the Services;
(l) any other incidental or associated purposes relating to the above and any other purpose which a customer may from time to time agree;
and/or
(m) statistical research and analysis.

6. 218 Apartment may make such enquiries as they consider necessary to confirm the accuracy of the personal data of the customers and 218 Apartment may transfer (whether within or outside Hong Kong), disclose and/or exchange personal data of the customers to and/or with all such entities as 218 Apartment may consider necessary, including the following entities:-
(a) any subsidiary, affiliate or business partner of 218 Apartment;
(b) any branch or office of 218 Apartment;
(c) any actual or proposed assignee, participant or transferee of 218 Apartment's right in relation to a customer;
(d) any agent, dealer, contractor, sub-contractor or third party service provider appointed or engaged by 218 Apartment;
(e) any bank or financial institution;
(f) any professional body;
(g) any credit card company;
(h) any credit reference bureau or agency or other information exchange system;
(i) any law enforcement agency or related entity;
(j) any debt collection agency or related entity;
(k) any direct marketing agency or related entity; and/or
(l) any charity.

7. Any of the entities referred to above may utilise the personal data in the course of any business or performance of any duty or function carried on by such entity.

8. A customer is entitled to request 218 Apartment to cease to use his or her personal data for the purpose specified in 5(j) above and on receipt of such a request 218 Apartment shall cease to use such personal data for such purpose.

9. In accordance with the terms of the Ordinance and subject to exemptions specified in the Ordinance, any customer:-
(a) has the right to check whether 218 Apartment hold personal data about him or her and has a right to receive copies of such data;
(b) has the right to require 218 Apartment to correct any personal data relating to him or her which is inaccurate; and
(c) has the right to ascertain 218 Apartment's policy and practices in relation to personal data and to be informed of the kind of personal data held by
218 Apartment.

10. In accordance with the terms of the Ordinance, 218 Apartment have the right to charge a reasonable fee for processing a data access request.

11. Requests for access to personal data, correction of personal data and information relating to the kind of personal data held, may be made in writing by post to:-

The Privacy Compliance Officer
218 Apartment
218 Hennessy Road, Wan Chai, Hong Kong
Hong Kong