Privacy Policy (Effective date: 17 July 2018)
- Pledge
The Mills Limited (“The Mills”) pledges to comply with the applicable laws and regulations and, in particular, the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region and the General Data Protection Regulation of the EU.
- Log Files
You may visit The Mills’s website without specifying any personal data. When you visit The Mills’s website, the servers of The Mills will only collect non-personal data relating to your visits (including your IP address, browser type, access time and your visited pages or similar information) and do not collect your personal data.
- Use of Cookies
When you browse The Mills’s website, cookies will be stored in your computers, mobile phones, tablets or other devices for internal navigation and programming only. You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functions of The Mills’s website.
- Collection of Information
If you wish to use specific services offered by The Mills (e.g. e-newsletters, online transactions), you may be invited to provide your personal data to The Mills on a voluntary basis for purposes as stated in the relevant Personal Information Collection Statement provided at the time of such personal data is required. If you do not provide or update accurate information as requested for a specific service, The Mills may not be able to provide such service to you.
- Kinds of Information Collected
You may be required to provide to The Mills your personal data, which may, if so necessarily required by the relevant purposes, include your name, e-mail address, address, phone number, business information (company, title, contact information) website, age group, interests, personal preferences, comments and such other information.
- Main Purposes and Uses of Information Collected
The Mills will use your personal data for purposes relating to its [daily operation, administration of accounts and records, research and development, communicating news and information, identification and verification, processing transactions, information and database administration, public relations, disclosure when required by applicable laws or regulations, or orders or requests made by the competent authorities, of the applicable jurisdictions] and all other purposes in connection with or incidental to the aforesaid. When The Mills intends to use your personal data for certain specified purposes, such specified purposes will be set out in the relevant Personal Information Collection Statement at the time of such personal data is required.
- Direct Marketing
If The Mills intends to use your personal data (including your name and contact details) collected from you for direct marketing purposes (e.g. to send you marketing communications about news, offers or promotions), The Mills will first obtain your consent (or an indication of no objection) before doing so. You may opt-out from receiving marketing communications from The Mills at any time, free of charge by:
- following the opt-out instructions contained in the communications; or
- write to the Personal Data Privacy Officer of The Mills at the address listed in “Enquiries” below.
- Retention of Information
The Mills will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which The Mills has collected it and, if applicable, as long as required by the applicable laws or regulations of the applicable jurisdictions. If such purposes no longer apply, or if the retention period required expire, your personal data will be deleted.
- Disclosure of Information
The Mills may share your personal data with or transfer the same to: –
- The Mills’s holding companies, subsidiaries, associated companies, fellow subsidiaries and any company in which any of the above has any interest (collectively, the “Group”);
- the business associates, partners, agents, contractors, sub-contractors, data processors, suppliers and providers of the Group (collectively, the “Service Providers”) for the prescribed purposes;
- the competent authorities of the applicable jurisdictions where overriding legal requirements exist; and
- actual or proposed assignee of The Mills or the Group or participant or sub-participant or transferee of The Mills’s or the Group’s rights.
- Transfer
Within the scope of the purposes set out above, your personal data may be transferred to third countries (including countries outside the EU and Hong Kong) due to the Group’s and/or the Service Providers’ server locations and in compliance with the requirement of the application laws.
- Service Providers
The Mills may provide your personal data to the Service Providers. Such Service Providers are or will be required to handle your personal data consistent with the agreements The Mills enters into with them as well as this Privacy Policy.
- Third Party Websites and plug-ins
The website of The Mills may from time to time contain linkages to other websites. The Mills has no control over your personal data submitted by you, if any, to other websites. This Privacy Policy only applies to the website of The Mills. You should read the respective privacy policies of other websites before you submit any personal data to the third parties.
- Security
The Group has implemented appropriate technical and organizational measures to protect your personal data as far as possible. However, no data transaction over the internet can be guaranteed to be fully secured. Accordingly, despite The Mills’s effort to protect your personal data, The Mills cannot guarantee or warrant the security of any information you transmit to The Mills. You transmit all such information at your own risk.
- Automated decision making
The Mills does not use your personal data for automated decision making which produces legal effects concerning you or similarly significantly affects you.
- Your rights
You have the right to, in accordance with the applicable laws or regulations of the applicable jurisdictions:
- request confirmation from The Mills as to whether The Mills processes persona data relating to you;
- access your personal data held by The Mills (if any);
- require The Mills to correct your personal data that is incorrect, incomplete or inaccurate (if any);
- obtain free-of-charge information from The Mills on your personal data;
- receive a copy of this information, including but not limited to the purposes of the processing, the categories of personal data that are processed, the recipients to whom the personal data has been disclosed or is still be disclosed, the planned retention period (if possible) or the criteria for determining such period;
- ascertain The Mills’s policies and practices in relation to data and to be informed of the kind of personal data held by The Mills;
- revoke your consent given to the processing of personal data at any time;
- require The Mills to erase your personal data on such grounds as prescribed under the applicable laws or regulations of the applicable jurisdictions;
- restrict the processing of the personal data by The Mills;
- object to the processing of the personal data by The Mills;
- complain to the competent authorities of the applicable jurisdictions;
- require The Mills to provide information of the origin of your personal data if you have not provided such personal data to The Mills;
- require The Mills to provide information as to transfer of your personal data to a third-party country or to an international organization;
- require The Mills to send to you or where technically feasible, another data controller, your personal data in a structured, commonly used and machine-readable format.
Nothing in this Privacy Policy shall limit your rights under the applicable laws or regulations of the applicable jurisdictions.
- Change to Privacy Policy
This Privacy Policy may from time to time be updated, revised and changed. Any change, update or modification will be effective immediately upon being posted on The Mills’s website. You agree to be bound by such amended Privacy Policy if you continue to use The Mills’s website. Please visit this page periodically to review the most update Privacy Policy.
- Details of Data Controller
The data controller as specified in the General Data Protection Regulation is , which, alone or jointly with others, determines the purposes and means of the processing of personal data.
- Enquiries
If you have any questions or wish to exercise any rights relating to your personal data held by The Mills,
please contact the Personal Data Privacy Officer of The Mills in writing at the following address or by email to communications@themills.com.hk:
Attn.: Personal Data Privacy Officer
(Marked Confidential)
- English Version
If there is any inconsistency or conflict between the English and Chinese version of this Privacy Policy, the English version shall prevail.