PRIVACY

1. Introduction 

• Goodman Asia Limited, Goodman Management Consulting (Shanghai) Co. Ltd., Goodman Management Consulting (Beijing) Co. Ltd. and their controlled, associated or related entities, including any funds managed by them (each, being “Goodman”, Goodman Group”, “we”, “us”, “our”) recognize the importance of protecting the privacy and rights of individuals in relation to their personal data.
• This document is our privacy policy and it tells you how we collect and manage the personal data of the parties with whom we deal, including but not limited to our customers, contractors, agents and other third parties. We respect rights to privacy, including as required under all relevant laws and regulations such as Personal Data (Privacy) Ordinance of Hong Kong (“PDPO”) and the relevant regulations and policies of the People’s Republic of China (“PRC”) regarding protection of personal information and under all applicable privacy and similar legislation in the jurisdictions in which we operate.

2. What is your personal data? 

• In general terms, personal data is any data that can be used to personally identify you. This may include your name, address, telephone number, email address and profession or occupation. If the data we collect personally identifies you, or you are reasonably identifiable from it, that data will be considered personal data.
• The term may be given a specific definition under privacy legislation which may apply in jurisdictions in which we operate. If this is the case, Goodman will treat in that jurisdiction that information or data as personal information or data for the purpose of the privacy legislation applying in that jurisdiction. 

3. What personal data do we collect and hold

We may collect personal data from you in the course of our business, through your use of our website, when you contact or request information from us, or as a result of your relationship with Goodman. We may collect the following types of personal data:

• general identification and contact information, such as your name, the company you work for, your title, position, your postal address, email address and phone numbers;

• identification and background information, which may include your full name, photographic identification such as a passport or identification card and gender;

• financial information, such as bank account;

• information you provide to us for the purposes of attending meetings and Goodman events, for example your contact details and business information disclosed to Goodman through the exchange of business cards;

• personal information provided to us by or on behalf of our customers, suppliers, investors and other stakeholders or generated in the course of our relationship with them;

• personnel records of employees and applicants for any type of role or employment with Goodman;

• details of services you have enquired about, together with any additional information necessary to deliver those services and to respond to your enquiries;

• any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives or otherwise; and

• information you provide to us through our representatives or customer surveys from time to time.

4. How do we collect your personal data?

We will collect your personal data directly from you unless it is unreasonable or impracticable to do so. When collecting personal data from you, we may also collect it in ways including:

• through your access and use of our website;

• through an intermediate entity that represents you;

• during conversations between you and our representatives; or

• when you make an enquiry, complete an application or enter into some form of contractual or other arrangement with us.

We may also collect personal data from third parties including from third party companies such as credit reporting or due diligence agencies and other government entities, but may only use this data in a manner consistent with the purposes described below.

5. Cookies

When you access our website, we may send a “cookie” (which is a small summary file containing a unique ID number) to your computer. This enables us to recognise your computer and greet you each time you visit our website with any relevant preferences. We may also use cookies to measure traffic patterns, to determine which areas of our website have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits so that we can improve our website.

Our cookies do not collect personal data and we have no intention to use the visitor data to personally identify anyone. If you do not wish to receive cookies, you can set your browser so that your computer does not accept them, but if you do, certain functionality may not be available.

We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyses trends, administer the website, track users movements and gather broad demographic information.

6. What happens if we cannot collect your personal data?

If you do not provide us with the personal data described above, some or all of the following may happen:

• we may not be able to provide the requested services to you, either to the same standard or at all;

• we may not be able to provide you with information or data about our products and services that you may want; or

• we may be unable to tailor the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

7. For what purposes do we collect, hold, use and disclose your personal data?    

We may collect and hold personal data about you so that we can perform our business activities and functions and provide the best possible quality customer service.

Subject to any restrictions under the applicable legislation in the jurisdiction in which the information or data was collected, we may use and disclose your personal data for the following purposes:

• to inform you of updates concerning relevant members of the Goodman Group;

• to provide services to you and to send communication or information requested by you;

• to provide you with access to certain areas of our website;

• to conduct business processing functions including providing personal data to our controlled, associated or related entities, contractors, service providers or other third parties;

• for the administrative, marketing (including direct marketing), planning, product or service development, quality control or research purposes of the Goodman Group;

• to provide your updated personal data to our related bodies corporate, contractors or service providers for the purposes of our business or our relationship with you;

• to update our records and keep your contact details up to date; to process and respond to any complaint made by you; and

• to comply with any law, rule, regulation (including applicable know your customer, anti-money laundering and counter-terrorism financing regulations and requirements), lawful and binding determination, decision or direction of a regulator or other authority.

Your personal data will not be shared, rented or disclosed other than as described in this Privacy Policy.

8. How long do we keep your personal data? 

• Whenever we collect or process your personal data, we will only keep it for as long as is necessary for the purpose for which it was collected, subject to satisfying any legal, accounting or other regulatory requirements. 

• At the end of any retention period, your data will either be deleted completely or anonymised (for example, by aggregation with other data so that it can be used in a non-identifiable way for statistical analysis or business planning).

• In some circumstances, you can ask us to delete your data.

9. To whom may we disclose your personal data?

Subject to any restrictions under the applicable legislation in the jurisdiction in which the information or data was collected, we may disclose personal information or data to:

• our employees, controlled, associated or related entities, contractors or service providers for the purposes of the operation of our website or our business, fulfilling requests by you and to otherwise provide services to you including, without limitation, share registry providers, custodians, web hosting providers, IT systems administrators, accounting and fund administrators, mailing houses, couriers, payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, solicitors, business advisors, real estate agents and consultants;

• suppliers and other third parties with whom we have commercial relationships for business, marketing and related purposes; and

• any governmental organisation for any authorised purpose or as required under or in connection with any law.

We may combine or share any personal data that we collect from you with personal data collected by any of our controlled, associated or related entities, subject to any applicable restrictions on the disclosure of information in any jurisdiction to entities outside that jurisdiction. Personal data may also be disclosed to any person or persons pursuant to any statutory obligations or as required by law.

10. Direct marketing materials

Subject to any restrictions under any legislation in the jurisdiction in which the information was collected, we may send you direct marketing communications and information about our services that we consider may be of interest to you. These communications may be sent in various forms, including mail, SMS, WeChat and other messaging services and email, in accordance with applicable laws and regulations.

If you indicate a preference for a method of communication, we will endeavour to use that method whenever practical to do so. In addition, at any time you may opt-out of receiving marketing materials from us by contacting us (see the details below) or by using opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list.

We do not provide your personal data to other organizations for the purposes of direct marketing by them. 

11. How can you access and correct your personal data?

You are entitled to access or correct any personal data we hold about you at any time by contacting us (see the details below). Where we hold data that you are entitled to access, we will try to provide you with a suitable means of accessing it (for example, by mailing or emailing it to you) within the time limits prescribed under applicable laws and regulations.

There may be instances where we cannot grant you access to the personal data we hold. For example, we may need to refuse access if granting access would interfere with the privacy of others or it would result in a breach of confidentiality. If that happens, we will give you written reasons for the refusal. 

12. What is the process for complaining about a breach of privacy?

Goodman prefers that complaints about breaches of privacy be made in writing, so we can be sure about the details of the complaint. Goodman’s Privacy Officers will normally deal with privacy complaints. Otherwise, the complaint will be dealt with by someone who was not involved in the conduct that your complaint is about. Goodman will attempt to confirm as appropriate and necessary with your understanding of the conduct relevant to the complaint and what you expect as an outcome. Goodman will, within the time limits prescribed under applicable laws and regulations, inform you whether Goodman will conduct an investigation, the name, title, and contact details of the investigating officer and the estimated completion date for the investigation process.

After Goodman has completed its enquiries, we will contact you, usually in writing, to advise the outcome and invite a response to our conclusions about the complaint. If we receive a response from you, Goodman will assess it and advise if Goodman has changed its view. If you are unsatisfied with the outcome, Goodman will advise further options including, if appropriate, review by the relevant Government departments and agencies. 

13. Do we disclose your personal data overseas?

Subject to any restrictions under any legislation in the jurisdiction in which the information was collected, we may disclose personal data to our controlled, associated or related entities and third party suppliers and service providers located overseas for some of the purposes listed above. We will take reasonable steps to ensure that the personal data sourced or transferred outside Hong Kong or China (as applicable) is protected to standards in line with the requirements.

We take reasonable steps to ensure that the overseas recipients of your personal information or data do not breach the privacy obligations relating to your personal information or data.

14. Security

We take reasonable steps to ensure your personal data is protected from misuse and loss from unauthorised access, modification or disclosure. We may hold your information in either electronic or hard copy form. Personal data is destroyed or de-identified when no longer needed.

We limit access to your personal data to those employees, agents, contractors and other third parties on a “need to know” basis.

We cannot provide any assurance regarding the security of transmission of data you communicate to us online. We also cannot guarantee that the data you supply will not be intercepted while be transmitted over the internet. Accordingly, any personal data or other information which you transmit to us online is transmitted at your own risk.

15. Links

Our website may contain links to other websites operated by third parties. We make no representations or warranties in relation to the privacy policies of any third party website and we are not responsible for the privacy policies or the content of any third party website. Third party websites are responsible for informing you about their own privacy practices.

16. Contacting us

We hope this privacy policy has been helpful in setting out the way we handle your personal data and your rights to control it.

If you have any questions about this privacy policy, any concerns or a complaint regarding the treatment of your privacy or a possible breach of your privacy, please use the contact link on our website or contact our Privacy Officer using the details set out below.

Goodman Privacy Officer in Hong Kong:
Suite 901, Three Pacific Place,
1 Queen’s Road East, Hong Kong, or call on +852 2249 3100.
Email: [email protected]

Goodman Privacy Officer in China:
Unit 1001-1004,
10/F, Tower 2,
1539 Nanjing Road West,
Jing An District, Shanghai, China, or call on +86 21 6133 2000.
Email: [email protected]

17. Changes to our privacy policy

We may change this privacy policy from time to time. Any updated versions of this privacy policy will be posted on our website.

This privacy policy is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this policy, the English version shall prevail.

This privacy policy was last updated on 5 December 2019.

 

 

It is important that the personal data that we hold about you is accurate and current. Please keep us informed if any of the personal data you have provided us with changes during your relationship with us.