Privacy Statement | Swire Pacific Limited

Privacy Notice

This privacy notice ("Notice") sets out how Swire Pacific Limited ("Swire Pacific", "we", "our" or "us") collect, use, store and handle personal data ("Personal Data") from you or that you may provide to us.

1. Commitment to Personal Data protection

We are committed to protecting the privacy of the Personal Data we hold. To ensure that you can make informed decisions and feel confident about providing your Personal Data to us, we outline in this Notice our practices and the rights you have concerning the collection and use of your Personal Data.

2. Personal Data we collect

The types of Personal Data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of Personal Data may include (without limitation) the following:

your personal information (e.g., your name, gender and date of birth);
your contact information (e.g., telephone numbers, mailing addresses, email addresses and fax numbers);
your business information (e.g., company name, business title and associated contact information);
your interests, personal preferences or comments;
your likeness, voice, image or biometric information as may be captured by any CCTV monitoring or security system used at the premises of any member of the Swire Pacific Group; and
information when you use our website (www.swirepacific.com) (“Website”) or other services or products (e.g., behavioural information, location information, browser details, IP addresses).

Certain Personal Data (e.g., relating to your personal information and contact information) are required for specific services and if you fail to supply such Personal Data, we may not be able to provide you with the services or products. By providing your Personal Data to us, you acknowledge that such provision is fair and reasonable in the circumstances.

3. Purposes for which your Personal Data are collected and used

The purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:

for the supply of any services, products, facilities and/or other subjects (together, the "Services") which we or any of our subsidiaries (together, "Swire Pacific Group") may offer to you, or you may require from us, from time to time;
for use of the online services available at any of the websites of any member of the Swire Pacific Group and/or through other telecommunication or media channels;
where you have applied for a position with us, to review and process your job application;
with your consent, for marketing or promoting any Services of any member of the Swire Pacific Group (e.g., sending you updates on our latest offers and promotions in relation to any of our Services from time to time);
with your consent, for promoting and soliciting donations or contributions for charitable or non-profit making causes;
for sale or purchase of any Services of any member of the Swire Pacific Group and/or other related services;
for identification and verification purposes in connection with any of the Services that may be supplied to you;
where you attend any premises of the Swire Pacific Group companies which implement CCTV monitoring, for health and safety purposes, including for preventing vandalism;
for communicating with you by email, mail, fax, phone or other means, including contacting you regarding your enquiries;
for compliance with (including the making of appropriate disclosures when required by) any applicable law, regulation or court order of any jurisdiction, stock exchange rules or relevant industry codes or guidelines and/or as requested or responding to enquiries (including participation in any investigation) by any government, regulatory or law enforcement authority or administrative organisation, or stock exchange, which may be within or outside the Hong Kong Special Administrative Region of the People’s Republic of China ("Hong Kong");
for establishing legal claims or defences, obtaining legal advice, and/or exercising, defending and/or protecting the rights or properties of any member of Swire Pacific Group, including identifying, contacting or bringing legal action against any person who may be causing interference with such rights or properties (whether intentionally or otherwise) or where any other person (including the property of such person) may be harmed or damaged by such interference;
to evaluate any potential business opportunity or transaction with you;
for conducting investigations of any incidents involving any member of Swire Pacific Group;
for use by any member of Swire Pacific Group in connection with any of the above purposes and/or any of the Services that any member of Swire Pacific Group may offer or provide to you from time to time; and/or
for any other incidental or associated purposes relating to the above, or any other purposes as specified in a personal information collection statement when your Personal Data is being collected, or any other purposes which you may from time to time consent.

We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes without your prior consent.

Further uses of your Personal Data may also be specified in a personal information collection statement that we provide to you when we collect Personal Data from you.

4. Disclosure and transfer of Personal Data

To facilitate the purposes mentioned under section 3 of this Notice, we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Hong Kong, and your Personal Data may be transferred within or outside Hong Kong. These third parties may include the following:

any member of Swire Pacific Group;
any agent, contractor or third-party service provider who may from time to time provide administrative, consulting, advisory, communications, distribution, data processing, IT-related, cybersecurity, security, payment, payment processing, data analytics, marketing or other services to or support the operation of Swire Pacific Group’s business (including direct marketing activities);
medical professionals, clinics, hospitals, insurers and/or loss adjustors;
in the event of default, debt collectors or recovery agents;
any credit or rating agency;
any person, government or law enforcement authority or administrative organisation as required or permitted by law;
any industry association or complaint handling body;
any person under a duty of confidentiality to any member of Swire Pacific Group (including accountants, legal advisers or other professional advisers);
any actual or proposed assignee, purchaser or beneficiary of all or any part of the business and/or assets of any member of the Swire Pacific Group; and/or
charitable or non-profit making organisations including Swire Trust.

The Personal Data you provide to us may also be sourced from or transferred to other jurisdictions outside Hong Kong for any of the purposes mentioned above.

5. Direct Marketing and right to opt out

If we intend to use your Personal Data (including your name and contact details) for direct marketing purposes (e.g., to send you marketing communications about news, offers or promotions in relation to the Services or activities of any member of the Swire Pacific Group), we will first obtain your consent (or an indication of no objection) before doing so.

If we intend to provide your Personal Data (including your name and contact details) collected from you to third parties for their use in direct marketing, we will first obtain your consent (or an indication of no objection) before doing so.

You have the right to opt-out from receiving marketing communications from us at any time, free of charge by:

following the opt-out instructions contained in the communications, or
email or write to us at the address listed in section 11 below.

6. Our commitment to Children's Privacy

Protecting the privacy of children is our primary concern. Hence, we will not knowingly collect or maintain Personal Data in our database from persons who are under 16 years of age without prior consent from a parent or guardian. If you believe we may have mistakenly or unintentionally collected any information from or about a child, please contact our data protection officer (see contact details at section 11 below).

7. Use of Cookies

Please refer to our Cookie Policy for more information.

8. Data retention

Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above, after which it will be destroyed or deleted.

9. Data security

All Personal Data we collect about you is stored on our or our subcontractors’ secure servers. We may also transfer your Personal Data outside the country in which you are located, including to countries with a different level of data protection than in the country in which you are located.

While no data transmission over the Internet, a website, mobile application or via email or other message service can be guaranteed to be secure from intrusion, we maintain contractual and commercially reasonable physical, electronic and procedural safeguards to protect your Personal Data in accordance with the requirements of relevant data protection legislation. We also comply with our security policies and standards when accessing or using your Personal Data and restrict access to your Personal Data to those persons who need to use it for the purpose(s) for which it was collected. You are responsible for keeping any information that we send to you confidential and for complying with any other security procedures that we notify you of. In particular, where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website or mobile applications, we ask you to regularly update your password and not to share the password with anyone.

10. Links to other websites

Our Website may contain links to third party sites that are operated under different privacy practices.

All such websites are independent from our Website. We have no control over the contents of such other websites or their privacy policies or compliance with applicable laws and regulations. You should therefore be fully aware that the provision of such links does not constitute an endorsement of, or approval from, or any form of association by or with Swire Pacific Group. We have no control over Personal Data that is submitted to these other websites. You should remain alert when you leave our Website and read the privacy notices of other websites.

11. How to access or correct your personal data or contact us

You are entitled to access or correct any Personal Data relating to you held by us. 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 we collect and maintain is inaccurate, please write to us at the address below.

A request for access to Personal Data, correction of Personal Data, or for information regarding policies and practices and kinds of Personal Data held by us may be sent to us at group.dpo@swirepac.com or the following mailing address:

Data Protection Officer
Swire Pacific Limited
33/F One Pacific Place
88 Queensway
Hong Kong

In accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong), we have the right to charge a reasonable fee for the processing of any data access request.

You may also contact us at the contact details above if you have a complaint about our processing of your Personal Data. We will do our best to resolve your complaint, but if you are not satisfied with our response, you may contact the Privacy Commissioner for Personal Data (www.pcpd.org.hk).

12. Jurisdiction-specific information

If you are located in a jurisdiction with a data protection law which applies to our processing of your Personal Data, you may have additional rights under that law, for example, you may have a right to request erasure or deletion of your Personal Data, to opt out or restrict processing of your Personal Data in certain circumstances, or request that your Personal Data be transferred to another provider, or obtain a copy of your Personal Data in a portable and readily usable format, or request an explanation of any automated decision-making. To exercise those rights where applicable, please contact us at the contact details set out in section 11 above.

13. Changes to this Privacy Notice

This Notice may be amended from time to time. We therefore encourage you to review this Notice when you visit our Website to stay informed of how we are using your Personal Data.

This Notice was last updated on 17 January 2024.

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