Privacy Policy

Privacy Policy

Sanston is committed to ensuring that your privacy is protected and our use of your personal information is governed by this Privacy Notice. On this site, “Sanston”, “our” and “we” each mean all the HK SAR companies in the Sanston group (including but not limited to their respective subsidiaries) which collect and use your information in the manner set out in this Privacy Notice. Any reference to “you” or “your” refers to anyone whose personal information we process.

 

1. Introduction

Our use of your personal data will be governed by this Privacy Notice.

Sanston is a controller for the personal information that it collects and uses about you. We will treat your personal information as confidential and in accordance with applicable data protection legislation and your personal information will only be shared with others in accordance with this Privacy Notice.

This Privacy Notice explains;

  • What personal information is

  • How we collect your personal information

  • The types of personal information we collect

  • How we use your personal information

  • The legal basis for processing your personal information

  • How we share your personal information

  • How long we keep your personal information

  • How we keep your personal information secure

  • Overseas transfers of your personal information

  • Your rights in relation to your personal information

  • How to make complaints and how to contact us


If there are any changes to the way in which your personal information is used, this Privacy Notice will be updated.

 

 

2. What is personal information

Personal information is any information that tells us something about you. This could include information such as name, contact details, date of birth, bank account details or any information about your needs or circumstances which would allow us to identify you.

Some personal information is classified as "special" data under data protection legislation. This includes information relating to health, racial or ethnic origin, religious beliefs or political opinions and sexual orientation. This information is more sensitive and we need to have further justifications for collecting, storing and using this type of personal information. There are also additional restrictions on the circumstances in which we are permitted to collect and use criminal conviction data.

Any references to personal information in this privacy notice will include personal data, and where relevant, special categories of personal data under the Hong Kong SAR Personal Data (Privacy) Ordinance- Cap.486 (the “Ordinance”). 

 

 

3. What personal information do we collect?

We will collect your full name and contact details (such as phone number, email address and postal address) from you whenever you engage with us.

In addition, if we are providing a service to you, or on your behalf, where we are required to do so by law, we will collect information relating to your identity, which will be at least one form of photographic identification (such as a passport, a driving licence or an identification card) and one form of documentation with proof of your place of residence (such as a recent utility bill).

We will also confirm whether you have any relatives or close connections working at Sanston so that we can consider potential conflict of interests and if identified how to manage these , in accordance with our statutory and regulatory obligations.

Depending on the service that we provide to you (or on your behalf) we may also collect additional personal information as detailed below

Buy, Sell, Let, Rent

If you are selling or letting a property through us;

  • We will collect a contact telephone number to get in touch with you about organising viewings and updating you on any offers received or rental applications for your property.

  • Where you are not the legal owner of the property we will request details from you as to your ability to sell or let the property such as a Power of Attorney, Guardianship Order or Grant of Probate.

  • We will collect your bank account details to arrange onward payment of rent due to you


If you wish to rent a property we are listing;

  • Specific access requirements so that we can find a property that is suitable for your needs

  • Your bank / building / similar account details to allow us to manage an approved tenancy deposit account for you and to set up your rental payments.

  • If you are a tenant renting under the 'Right to Rent' scheme we will collect details of your Biometric residence card, your immigration status document and/or your birth certificate to carry out our required checks under this scheme


If you wish to purchase a property we are listing for sale where you have specifically provided us with these, we will collect personal information relating to any specific access requirements you may have in relation to a property so that we can find a property that is suitable for your needs. We will also collect personal information required to source a property for you and, where required, negotiate the purchase of a property on your behalf.

Property Management

Where we engage with you to manage property on your behalf we will ask for additional emergency contact information in case we need to get in touch with you outside of working hours or in the event there is a matter requiring your urgent attention. Where you engage us for portfolio management services we will share your personal information with third party lenders as is necessary to allow us to fulfil our obligations to you and to properly manage and advise you on your property investments.

Other

If you subscribe to receive research, news or other market updates from us, then in addition to the above we will collect details about the sector in which you work and the type of content that you would like to receive.

 

4. How we use your personal information

What is the legal basis of our data processing?

Under data protection legislation we are only permitted to use your personal information if we have a legal basis for doing so. We rely on the following legal bases to use your information;

  • For employment-related purposes

  • Where we need information to perform the contract we have entered into with you

  • Where we need to comply with a legal obligation

  • Where the processing is necessary for us to carry out activities for which it is in Sanston' legitimate interests (or those of a third party) to do so and provided that your interests and fundamental rights do not override those interests, including:

    • Processing that is necessary for us to promote our business, brands and products and measure the reach and effectiveness of our campaigns. – this will include sending you marketing information from time to time after you have engaged us to provide services or received services from us either which may be similar and of interest to you or where you have expressly indicated that you would like to receive such information. You have the right to opt out of receiving this information at any time.

    • Processing that is necessary to improve our knowledge of the real estate sector – this will include undertaking market analysis and research so that we better understand trends in the property sector and provide better knowledge along with more tailored and relevant services for our customers in the future.

    • Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively – this will include: verifying the accuracy of information that we hold about you and create a better understanding of you as a customer; processing for administrative efficiency purposes such as where we outsource certain administrative functions to third parties who are specialise in such services; processing for network and information security purposes i.e. in order for us to take steps to protect your information against loss, damage, theft or unauthorised access or to comply with a request from you in connection with the exercise of any of your rights outlined below.


In more limited circumstances we may also rely on the following legal bases:

  • Where we need to protect your interests (or someone else's interests); and/or

  • Where it is needed in the public interest or for official purposes


We may process special categories of personal information and criminal conviction information in the following limited circumstances:

  • With your explicit consent, in which case we will explain the purpose for which the information will be used at the point where we ask for your consent.

How we use your personal information

For specific information on how your personal information will be used for the services you have requested from us, please select from any of the options below;

Buy, Sell, Let, Rent

  • We use your personal information for the purposes of fulfilling our obligations to you to let or sell your property or, if you are a buyer or tenant, for the purposes of arranging a contract for sale or a lease for you.

  • If you are purchasing a property we are acting as agents for the sale of or selling a property through us we will share your personal information with your appointed solicitors and the solicitors acting for the other side of the deal as is necessary to facilitate the sale or purchase.

  • If you are renting a property we are acting as letting agents of, we will share your personal data with third party referencing agencies for the purposes of the prevention and detection of crime, fraud and/or money laundering and checking your suitability to rent that property

Property Management

  • Where we are managing property on your behalf we may need to pass your personal information from time to time on to third party contractors whom we have engaged to carry out maintenance on your properties.

Other uses of your personal information

  • If we sell any part of our business and/or integrate it with another organisation your details may be disclosed to our advisers and to prospective purchasers or joint venture partners and their advisers. If this occurs the new owners of the business will only be permitted to use your information in the same or similar way as set out in this privacy notice.

  • We will share personal information with our regulators, governmental or quasi-governmental organisations, law enforcement authorities and with courts, tribunals and arbitrators as may be required from time to time in order to comply with our regulatory and legal obligations;

  • Where we use third party services providers who process personal information on our behalf in order to provide services to us. This includes IT systems providers and IT contractors as well as third party referencing or screening agencies for the purposes of the prevention and detection of crime.

  • We may share your personal information with any person working within the Sanston Group on a need to know basis to ensure we are able to perform our obligations to you.

  • We will hold your personal information on our client management systems and use this to provide you with marketing information about similar services offered by Sanston to those which you have engaged us to provide which we feel you might find useful from time to time. You have the opportunity to opt out of receiving this information at any time.

What happens if you do not provide information that we request?

We need some of your personal information to perform the services you have requested from us. For example:

  • where we are selling a property on your behalf we need to know your contact information so that we can update you with information on viewings, offers and the progress of the sale;

  • where you have asked us to find you a property which meets certain access requirements, we may need to know some further details about your particular circumstances so that we can find you a suitable property;

We also need some information so that we can comply with our legal obligations. For example, we may need identity documents from you to meet our obligations to prevent fraud and money laundering.

If you do not provide the information required for these purposes, we will not be able to perform our contract with you and may not be able to provide services to you or continue to provide certain services to you. We will explain when this is the case at the point where we collect information from you.

 

 

5. How we keep your information secure

The security of information is very important to us and we have measures in place which are designed to prevent unauthorised access to your personal information including but not limited to:

  • Our client files are stored on our secure client management systems. Access is restricted on our client systems to those within the business who are required to have access to your information for legitimate business purposes.

  • Hard copy documentation is stored in locked cabinets.

 

All data is hosted in datacentres which have systems and protections in place to protect against both unauthorised access, and other external factors that could cause damage to, your personal data. There are strict access requirements in place and access is restricted to those absolutely necessary.

We ensure access to personal information is restricted to Sanston employees and workers or other persons working within the Sanston Group on a need to know basis. Training is provided to any of those Sanston employees and workers who need access to personal information.

 

6. For how long do we keep your personal information

The period for which we will keep your personal information will depend on the type of service you have requested from us. The retention period may be longer than the period for which we are providing services to you where we have statutory or regulatory obligations to retain personal information for a longer period, or where we may need to retain the information in case of a legal claim.

 

7. Overseas transfers of your personal information

We may transfer, store, or process your personal information in locations outside the HK SAR. Where the countries to which your personal information is transferred do not offer an equivalent level of protection for personal information to the laws of the HK SAR, we will ensure that appropriate safeguards are put in place.

We’ll use the safeguards:

  • Transfer it to a place outside HK with privacy laws that give the same protection as the HK. Learn more on the Hong Kong Legislation website for section 33 of Personal Data (Privacy) Ordinance (Cap. 486)

 

 

8. Your rights in relation to your personal information

  • You have a number of rights in relation to your personal information, these include the right to:

  • Be informed about how we use your personal information

  • Obtain access to your personal information that we hold

  • Request that your personal information is corrected if you believe it is incorrect, incomplete or inaccurate

  • Request that we erase your personal information in the following circumstances: 

    • If Sanston is continuing to process personal information beyond the period when it is necessary to do so for the purpose for which it was originally collected

    • If Sanston is relying on consent as the legal basis for processing and you withdraw consent

    • If Sanston is relying on legitimate interests as the legal basis for processing and you object to this processing and there is no overriding compelling ground which enables us continue with the processing

    • If the personal information has been processed unlawfully (i.e. in breach of the requirements of the data protection legislation)

    • If it is necessary to delete the personal information to comply with a legal obligation

  • Ask us to restrict our data processing activities where you consider that: 

    • personal information is inaccurate

    • our processing of your personal information is unlawful

    • where we no longer need the personal information but you require us to keep it to enable you to establish, exercise or defend a legal claim

    • where you have raised an objection to our use of your personal information

  • Request a copy of certain personal information that you have provided to us in a commonly used electronic format. This right relates to personal information that you have provided to us that we need in order to perform our agreement with you and personal information where we are relying on consent to process your personal information

  • Object to our processing of your personal information where we are relying on legitimate interests or exercise of a public interest task to make the processing lawful. If you raise an objection we will carry out an assessment to determine whether we have an overriding legitimate ground which entitles us to continue to process your personal information; and

  • Not be subject to wholly automated decisions which produce legal effects or which could have a similarly significant effect on you.

If you wish to obtain a copy of any of your personal data or if you believe that the personal data relating to you which the company collects and maintains is inaccurate, you may write a request to the Data Protection Officer at the address below:

Sanston Property Limited at 17/F, The L. Place, No. 139 Queen’s Road Central, Central, Hong Kong.

In accordance with the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.

 

 

9. Complaints and Contact Details

Complaints

If you have any complaints about the way we use your personal information please contact the Data Protection Officer at 17/F, The L. Place, No. 139 Queen’s Road Central, Central, Hong Kong.

Contact details

If you have any questions, comments or requests regarding any aspect of this Privacy Policy, please do not hesitate to contact us by writing to the Compliance Team at 17/F, The L. Place, No. 139 Queen’s Road Central, Central, Hong Kong.

 

10. The use of cookies by Sanston

What is a cookie?

A cookie is a small text file that is downloaded onto your computer when you visit certain websites and allows a website to recognise a user's computer. Cookies are used to help users navigate websites more efficiently and to perform certain functions, as well as to provide information to the owners of the website.

What cookies do Sanston use?

The table below lists the cookies used by this website and provides a description of how each cookie works, clicking the '+' symbol will expand the box to give further explanation on each cookie. Where further information about a cookie exists on an external website a link has been provided under 'More information'

私隱條款

在此私隱政策聲明中:
(1) Sanston是指Sanston Property Limited。
(2) 本公司是指Sanston Property Limited。

概覽

此政策聲明是根據香港特別行政區法例第486章《個人資料(私隱)條例》 (下稱 “該條例”)為Sanston就其責任及政策提供資訊。Sanston致力於保障個別人士的個人資料。因此,本公司的政策是為確保其就有關個人資料的收集、運用、轉移、儲存及取用的政策和操作符合該條例的要求。

當本公司的業務受香港以外地方的私隱法例所規限時,則此政策須在切實可行及符合當地法律的情況下實施。

在本政策聲明中,“個人資料”是指在該條例定義的個人資料。

 

收集個人資料的種類

為遵守香港特別行政區法例 (包括《地產代理條例》及防止清洗黑錢) 及核實賣家/業主及買家/租客雙方的身份,及為本公司能向客戶提供銷售物業代理服務及公司行政管理的需要,客戶可能需要提供其:

  • 姓名

  • 電話號碼;

  • 地址;

  • 聯絡詳情;

  • 付款詳情;

  • 身份證號碼;

  • 護照;

  • 銀行結單;

  • 信用卡;及

  • 公用設施的賬單。

 

個人資料的收集

本公司會在以下情況收集客戶的個人資料:

  • 簽署地產代理協議委託本公司為客戶的地產代理時;

  • 簽署臨時買賣合約/租約或類似的備忘錄時;

  • 購買一手物業時;

  • 聯絡本公司作出查詢或投訴時;

  • 參加本公司各項銷售及推廣活動或比賽時;

  • 使用或瀏覽本公司之網站時

 

個人資料的使用

本公司可以為以下目的使用客戶提供的個人資料:

  • 提供物業服務;

  • 本公司進行推廣及銷售本公司的服務、產品及/或活動;

  • 在客戶同意的情況下向客戶介紹以下服務及產品及其相關的事項 (本公司或會因此而收取報酬):

    • 法律服務;

    • 按揭轉介;

    • 銀行服務;

    • 金融服務;

    • 財富管理;及/或

    • 保險服務。

  • 遵守適用的法律、規則及規例以及由監管部門發出及適用於本公司的指引、執業通告、專業守則及執業指引;

  • 向客戶收取未付的款項;及/或

  • 法律程序及/或執行判決及/或命令。

 

個人資料的披露

本公司將會對持有的一切個人資料予以保密,但本公司可在有需要披露此等資料以達到收集此等資料的目的或直接與其相關的目的時,向以下各方提供此等資料:

  • 合作的地產代理;

  • 律師事務所;

  • 銀行或金融機構;

  • 保險公司;

  • 按揭轉介服務提供者;

  • 財富管理服務提供者;

  • 政府部門、監管團體及/或其他法律要求或授權的合法機構;

  • 法院、審裁處及/或法律程序的各方。

個人資料也可根據任何法定或合約的義務或法院要求披露予任何人士,惟此等人士需能夠證明其取用資料的權利/權限。此外,個人資料也可根據該條例第VIII部份所載的情況下披露,其中有關個人資料獲豁免而不受第3 條保障資料原則所管限。

 

個人資料的準確性

本公司有一定的程序將個人資料的準確性、完整性及相關性保持在一個合理的水平,以配合個人資料的用途。本公司致力於保持個人資料準確及個人資料更新。但本公司依賴客戶向本公司披露所有重要的資料及通知本公司此等資料的任何錯誤或變更。

本公司完全遵守該條例的 “查閱及更正的權利”下的責任。詳情請參閱下列 “個人資料的查閱及更正” 有關客戶如何查閱及更正任何本公司可能持有客戶的個人資料的章節。

 

個人資料的保存

被收集的客戶個人資料只會保存至達到與收集資料之原有目的或直接有關的目的爲止,除非該個人資料亦為滿足任何適用的法定或合約責任、或適用的法律、規則及規例以及由監管機構發出及適用於本公司的指引、執業通告、專業守則、及執業指引所需要而保留較長的時間。

 

直接促銷

按照該條例的要求,本公司會依照客戶的要求不使用他或她的個人資料用作直接促銷。

在獲得客戶的同意後,本公司可通過使用電子郵件、通訊地址、流動電話號碼、電話號碼、服務號碼及服務賬戶號碼等不同聯絡方式,向客戶傳遞有關物業服務的不同推廣材料。

客戶在任何時間可致函香港中環皇后大道中139 號L Place 十七樓Sanston Property Limited的保護個人資料主任,要求停止接收或開始接收 (如客戶在之前已要求停止接收) 上述的推廣材料。

 

個人資料的查閱及更正

根據該條例的規定,客戶有權查閱及/或更正他/她的個人資料。據此,客戶可致函香港中環皇后大道中139 號L Place 十七樓Sanston Property Limited的保護個人資料主任提出要求。按照該條例的規定,本公司有權為處理任何查閱個人資料的要求而收取合理的費用。

 

個人資料的查閱及更正

有關此政策聲明或個人資料的所有查詢,請致函本公司的保護個人資料主任,地址是香港中環皇后大道中139 號L Place 十七樓Sanston Property Limited。

本公司保留修訂此政策聲明及/或其任何部份的權利。

 
 

TO CONTACT A REPRESENTATIVE

PLEASE CALL OR EMAIL US:

ALTERNATIVELY YOU CAN FILL

IN THE FOLLOWING CONTACT FORM:

SANSTONPROPERTY

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+852 9855 2586 | +852 26260510

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The L Place 17/F

139 Queens Road Central,
Central, Hong Kong

Co License : C-079471

Sanston Property Limited (License No. C-079471 All content © copyright 2019 Sanston Property Ltd. All rights reserved.