Goodman Asia Limited, Goodman Management Consulting (Shanghai) Co. Ltd. and any of their controlled, associated or related entities, includng any funds managed by any of them (“Goodman”, Goodman Group”, “we”, “us”, “our”) recognise the importance of protecting the privacy and rights of individuals in relation to their 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.
We may collect the following types of personal data:-
We may also collect some information that is not personal data because it does not identify you or anyone else. For example we may collect anonymous answers to surveys or aggregated information about how users use our website.
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 collect it in ways including:
We may also collect personal data from third parties including from third party companies such as credit reporting agencies and other government entities, but may only use this data in a manner consistent with the purposes described below.
We may log IP addresses (that is, the electronic addresses of computers connected to the internet) to analyse trends, administer the website, track users movements and gather broad demographic information.
If you do not provide us with the personal data described above, some or all of the following may happen:
We may collect and hold personal data about you so that we can perform our business activities and functions and provide 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:-
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:
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.
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, fax and email, in accordance with the 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 organisations for the purposes of direct marketing by them.
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 in the PDPO or other 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.
In accordance with the terms of the PDPO or other applicable laws and regulations, we have the right to charge a reasonable fee for the processing of any data access request.
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 in the PDPO or other 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.
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.
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 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.
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.
Goodman Privacy Officer in Hong Kong:
Suite 901, Three Pacific Place,
1 Queen’s Road East, Hong Kong, or call on +852 2249 3100.
Goodman Privacy Officer in China:
10/F, Tower 2,
1539 Nanjing Road West,
Jing An District, Shanghai, China, or call on+862161332000.