Privacy Policy Statement
Midland Realty International Limited (the "Company")

1. General

   The Company is committed to protecting the personal data of individuals and therefore it is the Company’s policy to ensure its policies and practices in relation to the collection, use, transfer, retention and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance, Cap.486 (the “Ordinance”).

2. Types of Personal Data Collected

   For the purpose of provision of real estate agency services by the Company, customers may be requested to provide personal data including but not limited to the name, contact details (including but not limited to telephone number, fax number, email and/or correspondence address), identification document number and copy of any document which may contain the personal data of the customers, such as identity card, passport, bank statements and utility bills. Provision of personal data is on a voluntary basis. Failure to supply such personal data may result in the Company being unable to provide real estate agency services.

3. Use of Personal Data

   The personal data provided by the customers may be used by the Company for the purpose of:
   
   1. provision of real estate agency services (including provision of estate agency works in relation to property(ies) owned directly or indirectly currently or in the future by you or your related person* or company(ies) in which you or your connected person is a director or holds any direct or indirect interest(including to conduct land search and company search (If applicable));
   2. direct marketing of the real estate agency services of the Company;
   3. direct marketing of the services, reward and/or promotional programmes and/or events provided by the institutions or individuals listed in paragraph 6 below (the “Third Parties”) in relation to the classes of marketing subjects specified in paragraph 5 below (the “Services”);
   4. 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;
   5. collection of outstanding debts from customers; and/or
   6. legal proceedings and/or enforcement of judgments and/or orders.
   *related person includes spouse, parent, child, brother or sister
   

4. Use of Personal Data for Direct Marketing

   The Company intends to use the name and contact details (including telephone number, fax number, email and/or correspondence address) of the customers for direct marketing of the real estate agency services provided by the Company.

5. Transfer of Personal Data for Direct Marketing

   The Company intends to transfer the name and contact details (including telephone number, fax number, email and/or correspondence address) of the customers to the Third Parties for use in direct marketing of the following Services and the Company may derive gain as such:
   1. real estate agency;
   2. financial planning;
   3. wealth management;
   4. insurance;
   5. property valuation;
   6. mortgage referral;
   7. immigration consultancy;
   8. banking;
   9. legal services; and/or;
   10. reward and/or promotional programmes and/or events.

6. Transfer of Personal Data

   Personal data of customers held by the Company may be transferred to the following parties:
   1. co-operative estate agents;
   2. service providers of the Company offering rewards and/or promotions;
   3. law firms, banks, financial institutions, insurers, service providers for mortgage referral, financial planning, property valuation, immigration consultancy and/or wealth management;
   4. government agencies, regulatory bodies and/or other lawful authorities;
   5. courts, tribunals and/or parties to the legal proceedings; and/or
   6. debt collection agencies.

7. Request to Cease the Use of Personal Data for Direct Marketing

   Even if customers have given consent to the Company on the use and/or transfer to the Third Parties of their personal data for direct marketing, customers may still have the right, at any time without charge, to request the Company to cease to use and/or transfer their personal data to the Third Parties for direct marketing. Customer may write to the Data Protection Officer of the Company at dpo@midland.com.hk or Rooms 2505-8, 25/F, World-Wide House, 19 Des Voeux Road Central, Hong Kong for making such request. The Company will cease using their personal data for such purpose.

8. Web Logs

   The Company uses cookies to learn how you interact with our content and to improve your experience when visiting the Company’s website. The Company does not use, and has no intention to use the visitor data to personally identify anyone. Most web browsers are initially set up to accept cookies. You have a choice not to accept the cookies and continue to browse the Company’s website, but if you do, certain functionality may not be available. For further details on how the Company uses cookies, please see our separate Cookie Policy.

9. Security and Retention of Personal Data

   The Company has implemented internal control measures to ensure the security of personal data and to prevent unauthorized or accidental access, process, erasure, loss or use of personal data. Personal data provided by you are retained until the completion of the purposes for which such data were collected and will not exceed 7 years in general, 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.

10. Access to and Correction of Personal Data

    Under the Ordinance, customers have the right to access and/or correct their personal data. Accordingly, customers may at any time write to the Data Protection Officer of the Company at dpo@midland.com.hk or Rooms 2505-8, 25/F, World-Wide House, 19 Des Voeux Road 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.

11. Enquiries

    All enquiries about this statement or personal data shall be addressed in writing to the Data Protection Officer of the Company at dpo@midland.com.hk or Rooms 2505-8, 25/F, World-Wide House, 19 Des Voeux Road Central, Hong Kong.

    The Company reserves the right to change this Statement and/or any part thereof.