This policy statement provides information on the obligations and policies of Portman Ventures, under the Hong Kong SAR Personal Data (Privacy) Ordinance Cap.486 (the “Ordinance”). Portman Ventures is committed to protecting the personal data of individuals and therefore it is the Company policy to ensure its policies and practices in relation to the collection, use, transfer, storage and access of personal data comply with the requirements of the Ordinance.  Where the Company’s operations are subject to privacy legislation other than that of Hong Kong SAR, then this policy shall be applied so far as practicable and consistent with such local legislation. Throughout this policy, the meaning of the term “personal data” is as defined in the Ordinance
 
TYPES OF PERSONAL DATA COLLECTED

For the purpose of complying with the laws of the Hong Kong Special Administrative Region (including the Estate Agents Ordinance and the prevention of money laundering) and verification of the identity of both the vendor/landlord and the purchaser/tenant, and in order to market properties and provide services, and administrative function of the Company, customer may be required to provide his/her:

•    Name
•    Phone number
•    Address
•    Contact details
•    Identity card number
•    Passport
•    Payment details
•    Bank statement
•    Credit cards
•    Utilities bills
 
COLLECTION OF PERSONAL DATA

Customer’s personal data will be collected upon:

•    Signing the estate agency agreement to appoint us as customer’s estate agent for properties beyond HKSAR governing territories
•    Signing the provisional sale and purchase agreement/tenancy agreement or memorandum of the like
•    Purchasing the first hand property
•    Contacting us for the enquiry or complaint
•    Participating in our marketing and promotional activities or competitions
•    Using or visiting our website
 
USE OF PERSONAL DATA

The personal data provided by the customer may be used by the Company for the purpose of:
•    Provision of real estate services for properties beyond HKSAR governing territories
•    Promotion and marketing of the services; products and/or events of the Company
•    Introducing to the customer with his/her consent the following services and products relating thereto (the Company may or may not receive remuneration as a result of any such introduction)
•    Legal services
•    Mortgage referral
•    Banking
•    Financial
•    Wealth management; and/or
•    Insurance
•    Compliance with the applicable laws, rules and regulations as well as the guidelines practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company
•    Collection of outstanding sums from customer; and/or
•    Legal proceedings and/or enforcement of judgements and/or orders.
 
DISCLOSURE OF PERSONAL DATA

All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:
•    Co-operative estate agents
•    Law firms
•    Financial institutions
•    Insurers
•    Mortgage referral services providers or
•    Wealth management services providers
•    Government agencies, regulatory bodies and/or other lawful authorities as required or authorized by law
•    Courts, tribunals and/or parties to the legal proceedings
Personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right/authority to access such information. In addition, personal data may be disclosed under any of the circumstances described in Part VIII of the Ordinance in which the concerned personal data are exempt from the provisions of Data Protection Principle 3 of the Ordinance.
 
ACCURACY OF PERSONAL DATA

The Company has certain procedures in place to maintain personal data at a reasonable level of accuracy, completeness and relevancy for the purpose for which the personal data is to be used. The Company aims to keep personal data accurate and up-to-date. However, the Company relies on the customer to disclose all material information to the Company and to inform the Company of any errors or changes in such information.
 
The Company fully complies with the “Rights of Access and Correction” obligations of the Ordinance. Please refer to the section titled “Access and Correction of Personal Data” below for details on how customer can obtain and correct any customer’s personal data that the Company may hold.
 
RETENTION OF PERSONAL DATA

Personal data of customer will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations, or such longer period as prescribed by applicable laws, rules and regulations as well as guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company.
 
DIRECT MARKETING

In accordance with the requirements of the Ordinance, the Company will honor a customer’s request not to use his or her personal data for the purpose of direct marketing.  Upon customer’s consent, the Company may deliver to customer, through various communication, channels by using email address correspondence, address, mobile phone number telephone number, service number and service account number, various promotion material relating to real estate services.
 
Customer can at any time send written request to our Data Protection Officer at Portman Ventures to stop receiving the promotion materials aforesaid or to start receiving the same (if customer has unsubscribed from receiving such materials before).
 
ACCESS TO AND CORRECTION OF PERSONAL DATA

Under the Ordinance, customer has the right to access and/or correct his/her personal data. In accordance with the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
 
ENQUIRES

All enquiries about this statement or personal data shall be addressed in writing to the Data Protection Officer of Portman Ventures.  The Company reserves the right to amend this statement and/or any part thereof.