Privacy Policy Statement

It is the policy of the Data User (Lan Kwai Fong Group) to comply with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR ("Ordinance"). In doing so, we will ensure compliance by our staff with the strictest standards of security and confidentiality.

The Lan Kwai Fong Group (“Group”, “we”, or “our”) adopts the following Privacy Policy Statement (“Privacy Policy”) in regard to the use of [www.californiatower.com], and related webpages and services (the “Website”), but specifically excluding affiliated websites covered by independent privacy policies. This Privacy Policy applies to information collected through the Website and otherwise (for example, if you contact us directly). However, it does not cover any information — personal or not — that may be collected through other websites (including those of our affiliates) or in other venues. Your use of the Website and our services is subject to this Privacy Policy, which may be updated periodically to reflect changes in how we collect, use, and/or share information and also changes as required to comply with changes in applicable law or regulatory requirements. Our Privacy Policy will reflect the date it was last updated. We therefore encourage you to review this Privacy Policy periodically to stay informed of how we use your personal information.

Our Group safeguards all information provided by our Customers and Website users ("Users"). We do not collect any personally identifiable information (“PII”) from Users during their browsing of our Website. When Users visit our Website we record their visit only as a 'hit' and do not collect any PII from them. We will however make a record of the visit that shows only the domain name server (DNS) address, part of their e-mail address, and of the pages visited. We use such information only for preparing general statistics on the usage of our web sites.

If PII are collected in the process of making enquires or submitting applications for services provided by different operations within our Group, Users will be informed via the Personal Information Collection Statement of our websites of such purposes and uses, including the extent of their transfer and disclosure; and the right of access to and correction of the collected PII.

In order to provide users with more information and services, we use third-party content providers and service providers, and provide links to other web sites. These third-parties may collect Users' PII when Users make use of their services. These third parties adhere to their own privacy policies and practices and our Privacy Policy Statement does not cover such third-party practices.

Should Users have any queries about our privacy policy and practice, please write via e-mail to our Data Protection Team at [email protected] or via mail to 20/f On Hing Building No. 1 On Hing Terrace Central Hong Kong

We set out our general policy and practices in respect of our collection and use of your data.

The Data User, in complying with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the laws of the Hong Kong SAR, is committed to safeguarding your privacy on-line, and notify you of certain matters when collecting information from you. This statement may change from time to time, so please check back periodically. By subscription to our newsletter and every time you visit this Website or to use our services, you agree to be bound by this statement at that time in force.

Collection

At the time of subscription to our newsletter and at other times when using the Website, you may be asked to provide us with personally identifiable information, such as your name and e-mail address. It is necessary for us to collect your information for providing you with the various services and activities offered on this Website. You are not obliged to provide the information but if you fail to provide the requested information, we will not be able to provide you with the services and activities available on this Website. Certain non-personally identifiable information which does not identify you, may also be collected when you use this Website, including the type of browser and operating system you use, your IP address, other navigational clickstream data, etc

We do not knowingly collect or use data relating to children below the age of 16, unless parental consent is provided for any collection and processing of PII in relation to children aged 16 or below. If you sign up for our newsletter on the Website, you confirm that you have reached the age of majority in your country of residence.

We may use cookies to enhance your experience on the Website and personalize services you may receive from us. For more information on cookies collection, please refer to our Cookie Policy. From time to time, we may also get data about you from third parties, which you agree to share with us on social networks (such as Facebook, Instagram, Google, etc.).

Purpose and Use of Data

We use and process the PII we collected through this Website with lawful justifications, including legal basis such as your prior explicit consent, to comply with a legal obligation, for performance of a contract, or in our legitimate interests as a business (such as in connection with the conducting and developing of our business and marketing activities), but only where such are not overridden by your interests and fundamental rights.

We describe below how we plan to use your PII, and upon which of the legal basis we rely to do so. Where appropriate, we also identify our legitimate interests as a business.

Purpose/Activity	Lawful basis for processing including basis of legitimate interest
To respond to your inquiry for more information through email to us and to share with you our newsletters, news, updates and reports in response to your inquiries	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to address enquiry from visitors of our Website and to develop our business)
To collect data for identity verification and records and to maintain contact lists for correspondence	(a) Performance of a contract with you (b) Necessary for our legitimate interests (to address enquiry from visitors of our Website) (c) Your prior explicit consent
To compile aggregate statistics about our users and to analyze site usage	(a) Necessary for our legitimate interests (to keep our records updated and to study the performance of our Website and topics of interest to visitors)
To operate internal control, resolve disputes, troubleshoot problems and enforce our terms of use	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security) (b) Necessary to comply with a legal obligation
To deliver information to you that we believe you may have interest in, such as targeted banners, new services and products and other promotions and marketing materials	(a) Necessary for our legitimate interests (to study how visitors use our Website, to grow our business and to customize experiences and preference viewing of the Websites)
To contact you regarding administrative notices and communications relevant to your use of this web site and to respond to your reques	(a) Performance of a contract with you (b) Our legitimate interest in keeping our members updated about our services

We may from time to time send direct marketing materials promoting products and services to Users. Suitable opt-out facilities will be provided during the direct marketing process.

If we add new features or services that might require the sharing of your personal information with an additional advertiser or sponsor, we will provide you with notice and the opportunity to opt-out to receive these offers. We will also get your explicit opt-in consent before we share your personal information with any third-party for marketing purposes.

With your explicit consent, we will send you updates via email about all the latest news and / or offers on our Website. You can unsubscribe at any time by clicking the link provided in any email. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you. You can also contact us directly.

Transfer of Data

1. If we use third-party suppliers or service providers to facilitate our services, we will have to provide your information to these suppliers or service providers offering such services where you choose to use these services.
2. We may disclose or access account information when we believe in good faith that the law requires it.
3. We may also disclose or access account information for administrative and other purposes that we deem necessary to maintain, service, and improve our services.

In addition, your information will be accessed by, disclosed or transferred to any person or bodies corporate or division within our Group for legitimate interests to our business for purposes set out above.

As the parties mentioned above may have places of business outside Hong Kong, your information may be transferred out of Hong Kong. By subscribing to our Website, you agree to us transferring your information to these parties outside Hong Kong. These parties adhere to their own privacy customs and policies and your information will be subject to said customs and policies.

Your Legal rights

You have the following rights with respect to your personal information: right of access, rectification and erasure (right to be forgotten) of your personal information we hold about you, right to object and restrict of processing of personal information, right to withdraw consent and right to data portability, which includes requesting for migration of your personal information in a structured electronic format to a third-party of choice. You may directly contact us if you wish to exercise these rights.

Retention Period

PII collected will be maintained securely in our system. We will only retain such data for as long as it is required to fulfill the purposes for which it was collected. Only authorized staff will be permitted access to such PII, and we shall not release such PII to any external parties except those parties set out in our Personal Information Collection Statement without User's prior explicit consent.

Cookies

In order for us to provide Users with customizable and personalized services, we use cookies to store and sometimes track information about Users. The information collected by means of cookies includes a User’s navigation pattern. This is done without Users being aware that it is occurring. Generally, we use cookies to estimate our audience size; to track Users' progress and number of entries in our promotional activities; and to measure Users' traffic patterns. PII collected by means of cookies will not be disclosed to any third parties except to those parties within our Group.

We only obtain this information when you provide explicit prior consent to the Website. For more information regarding Cookies, please refer to our Cookie Policy.

Disclosure

We will not sell, share, or rent your information to others except to our staff and to trusted third parties and affiliates when we need to share the information to provide a product or service you have requested. We may also share your information to enable a trusted third party or affiliate to provide services to us, and then only to provide those services. We limit as commercially reasonable their access and use of your PII to that which is necessary to provide these services to us. Without limiting the above, we will share your PII with third parties only in the ways that are described in this Privacy Policy.

We may also be required by law to disclose your PII in response to a subpoena, court order, or a request for cooperation from law enforcement or other governmental agency globally. Your PII may also be shared when we believe disclosure is necessary in connection with efforts to investigate, prevent, or take other action regarding actual or suspected illegal activity or other wrongdoing, to protect and defend the rights, property or safety of LKF, our users, or others. We will use commercially reasonable efforts to make you aware of the disclosure of your PII contrary to the terms set forth in this Privacy Policy (e.g., in the event of any material security breach).

Third Party Links and Policies

The Website may contain links to other websites owned and operated by third-parties and/or affiliates. These third-parties and affiliates may collect information from you. These affiliates and third-parties and their computer servers may be located in Hong Kong, the People’s Republic of China, the United States, or in other countries. We do not control, and are not responsible for, the privacy and security practices of any third parties or affiliates. We strongly recommend that you review the privacy and security policies of all third parties and affiliates to determine how they handle information they may collect about you. To the extent their privacy policies conflict with this Privacy Policy, their privacy policies shall prevail.

Last update: 30 July, 2018