ASIA PACIFIC LAND PRIVACY POLICY

Asia Pacific Land, Ltd. and its affiliates1 (collectively, the “Company,” “we,” or “us”) want you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect:

  • Through websites operated by us from which you are accessing this Privacy Policy (the “Websites”),
  • through HTML-formatted email messages that we send to you that link to this Privacy Policy.

Collectively, we refer to the Websites and our HTML-formatted email messages, as the “Services”.

PERSONAL INFORMATION

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Services collect Personal Information, including:

  • Name
  • Postal address
  • Telephone number
  • Email address

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

  • Through the Services
    We collect Personal Information through the Services, for example, when you contact us through the Services.
  • Offline
    We collect Personal Information from you offline, e.g., when you visit our offices or contact us by phone.
  • From Other Sources
    We receive your Personal Information from other sources, for example:

    • publically available databases
    • joint marketing partners, when they share the information with us

We need to collect Personal Information in order to provide the requested Services to you. If you do not provide the information requested, we may not be able to provide the Services.

Use of Personal Information

We and our service providers use Personal Information for legitimate business purposes including:

  • Providing the functionality of the Services and fulfilling your requests.
    • To provide the Services’ functionality to you
    • To send administrative information to you, such as changes to our terms, conditions and policies.

    We may engage in these activities to manage a contractual relationship with you and/or to comply with a legal obligation.

  • Aggregating and/or anonymizing Personal Information.
    • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose.
  • Accomplishing our business purposes.
    • For data analysis, for example, to improve the efficiency of our Services;
    • For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements;
    • For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft; For developing new products and services;
    • For enhancing, improving, or modifying our current products and services;
    • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
    • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests;

    We may engage in these activities to manage a contractual relationship with you, to comply with a legal obligation, and/or based on our legitimate interest.

Disclosure of Personal Information

We disclose Personal Information:

  • To our affiliates2 for the purposes described in this Privacy Policy.
  • To our third party service providers, to facilitate services they provide to us.
    • These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services.

Other Uses and Disclosures

We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so:

  • To comply with applicable law and regulations.
    • This can include laws outside your country of residence.
  • To cooperate public and government authorities.
    • To respond to a request or to provide information we believe is important
    • These can include authorities outside your country of residence.
  • To cooperate with law enforcement.
    • For example, when we respond to law enforcement requests and orders or provide information we believe is important.
  • For other legal reasons.
    • To enforce our terms and conditions; and
    • To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
  • In connection with a sale or business transaction.
    • We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.

OTHER INFORMATION

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual

  • Browser and device information
  • Demographic information and other information provided by you that does not reveal your specific identity
  • Information that has been aggregated in a manner such that it no longer reveals your specific identity

Collection of Other Information

We and our service providers may collect Other Information in a variety of ways, including:

  • Through your browser or device:
    • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services you are using. We use this information to ensure that the Services function properly.
  • IP Address
    • Your IP address is automatically assigned to your computer by your Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a user accesses the Services, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Services. We may also derive your approximate location from your IP address.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.

CHOICES AND ACCESS

How you can access, change or delete your Personal Information

If you would like to request to access, correct, update, suppress, restrict, or delete Personal Information, object to or opt out of the processing of Personal Information, or if you would like to request to receive a copy of your Personal Information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us in accordance with the “Contacting Us” section below. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed or whether you would like to have your Personal Information suppressed from our database. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we may need to retain certain information for recordkeeping purposes.

If you are under 18, you may ask us to remove content or information that you have posted to the Services by writing to Asia Pacific Land Ltd., Suite 2102, Nine Queen’s Road, Central, Hong Kong. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you keep using the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

USE OF SERVICES BY MINORS

The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.

SENSITIVE INFORMATION

Unless we request it, we ask that you not send us, and you not disclose, any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.

UPDATES TO THIS PRIVACY POLICY

The “LAST UPDATED” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy on the Services. Your use of the Services following these changes means that you accept the revised Privacy Policy.

CONTACTING US

Asia Pacific Land, Ltd. located at Suite 2102, Nine Queens Road, Central, Hong Kong, is the company responsible for collection, use and disclosure of your Personal Information under this Privacy Policy.
If you have any questions about this Privacy Policy, please contact our Group Corporate Secretary at +852 3656 8000, or:

Asia Pacific Land, Ltd.
Suite 2402, Nine Queens Road
Central, Hong Kong

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.

ADDITIONAL INFORMATION REGARDING THE EEA

You may also lodge a complaint with an EU/EEA data protection authority for your country or region where you have your habitual residence or place of work or where an alleged infringement of applicable data protection law occurs. A list of data protection authorities is available here.

1 Affiliates include Asia Pacific Land (Japan), Ltd.; Asia Pacific Land (Taiwan), Ltd.; APL Europe GmbH; and APL America Investments, Ltd; APL (New York) Corporation; APL Europe (Luxembourg) S.à r.l.

2 Affiliates include Asia Pacific Land (Japan), Ltd.; Asia Pacific Land (Taiwan), Ltd.; APL Europe GmbH; and APL America Investments, Ltd; APL (New York) Corporation; APL Europe (Luxembourg) S.à r.l.