Version 1.0

Last Updated Date: [18] May 2023

Click here to see our Personal Information Collection Statement (PICS)

1.We care about your privacy

We are committed to protecting and respecting your privacy. In order to provide you with the best experience, we need to collect various types of information about you in order to help us serve you better.  This Privacy Policy will help you understand the purposes for which we will use your personal data, who we share your personal data with, and the choices you have in relation to how your personal data is collected and used by us.

If you download, install or use our mobile application (Manulife Place) (“App”), then this Privacy Policy will apply to you.

Sometimes, we may provide additional privacy notices to explain how we may use your personal data in specific situations and you may have the choice to opt out of such uses.

2.Who are we?

Sunstone KB (HKSAR) Limited  is a company incorporated in Hong Kong ("us", "we" or "our"). By installing and using our App, you acknowledge and agree to the collection, use and transfer of your personal data in accordance with this Privacy Policy.

3.How do we collect data?

When you use our App, personal data will either be provided by you or collected automatically by our App. We will indicate if the collection and provision of certain categories of personal data is mandatory. We may not be able to provide you with the services on our App if you do not provide us the  information marked mandatory. All other personal data can be provided by you on a voluntary basis.

4.Are you over 18?

Our App is only intended for use by people over the age of 18.  If you are under the age of 18, please do not use our App. We do not knowingly collect any personal data from persons under the age of 18.

5.What information do we collect about you?

The personal data we may collect about you includes:

-your full name;

-email address;

-mobile phone number;

-your location data;

-your company information (company name, position etc.);

-your transaction history and payment details when you purchase anything using our App (including the product or service purchased, the date of purchase, payment preferences, the cardholder's name, credit card number, expiry date and billing information;

-your user account status and account activities; and

-personal data collected whenever we communications with you (e.g. email content, contact information, etc.) or when you complete any voluntary surveys and questionnaires we may send you from time to time (e.g. your demographic information and feedback).

We may also use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:

·your visits to our App, such as your browsing history, how long you stay on our App, and how often you visit; and

·your location information as provided by your mobile or other device when you use our App, including your IP address and general geographic location; and the device on which the App is installed (e.g. your device ID, operating system, type of device, device version, mobile application crashes or other system activity).

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Online tracking technology.

6.How do we use your information?

We will only use your personal data for the purposes set out below:

(a)Account administration

To help administer and maintain your user account, including:

·creating and updating your user account;

·verifying your identity;

·providing you with a log-in ID for your user account to access our App;

·maintaining, updating, administering and processing a record of your activities on our App, including any purchases or orders made by you through our App for any products or services and any points, vouchers or rewards in relation to any rewards programme;

·completing transactions, including processing or facilitating payments and restaurant table booking requests;

·enabling booking of building facilities; and

·facilitating building access.

(b)Customer support

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

(c)Direct marketing

To provide you with marketing and promotional materials (“Marketing Communications”), if you choose to receive them.  Please see the section on Direct marketingbelow for more information.

(d)Personalisation

To provide you with the best possible customer experience in relation to our App. We may also use data analytics tools to determine whether our offers, advertisements and promotions are effective, as well as to determine whether you may be interested in new products or services, or to customise the content and types of offers, products, services and rewards that we present to you.

(e)Optimisation and improvements

We may use your personal data to understand and improve our App or our operations, through various means, such as the use of analytics tools, research, surveys and feedback forms.  This will enable us to enhance services or products, develop new features and benefits, and assess and amend business, marketing and strategic operations and plans.

(f)Legal and administrative purposes

We may use your personal data  to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.

7.Who do we share your information with?

(a)Affiliated Companies

Your personal data may be disclosed or transferred to our, subsidiaries, affiliates and/or branch offices (each an “Affiliate”) in order to fulfil any of the purposes we have set out above. However we will not provide your personal data to any of our Affiliates in order for them to send you marketing materials regarding their own products and services, unless we obtain your prior consent.

(b)Service providers

Your personal data may be disclosed or transferred to our service providers (including agents,  contractors and property services manager(s)) who process personal data on our behalf to help us administer, maintain and operate the App, provide back-end, storage, administrative or IT services to us, provide any services to you, conduct data analytics, or carry out any of the purposes set out above. For example, IT vendors, back-office and front-end service providers, call centre operators and marketing agencies.

(c)Professional advisors (including our lawyers and auditors)

(d)Any government or regulatory authorities or third parties in accordance with any legal or regulatory requirements or any court order applicable to us

(e)Our tenants

Your personal data may be disclosed or transferred to our tenants in order to fulfil any of the purposes we have set out above, including providing you with access to the building and facilitating purchases made on the App.

8.Direct marketing

Subject to your consent, we may:

(a)use your personal data to send you Marketing Communications via email, push notifications on our App, banner advertisements on the App, telephone”, SMS, through your online user account, etc., in connection with the latest news, events, updates, offers, contests and promotions relating to goods and services, such as food and beverage, retail, fitness and other amenities provided by the tenants/merchants at Manulife Place;

(b)transfer your personal data to our Affiliates, tenants, business partners and service providers in order for them to send you Marketing Communications in connection with the the latest news, events, updates, offers, contests and promotions relating to their goods and services; and

(c)analyse your preferences and transactional history in order to gain insights, so that we can customise the content and types of offers, products and services that we present to you via our App or our Marketing Communications.

Before providing you with Marketing Communications, we will ask for your consent.  You can choose at any time not to receive any Marketing Communications from us. See the section on Your rights below.

9.How do we keep your information secure?

We take the security of your information seriously. We take all practicable steps, including the implementation of technical and physical security measures, to ensure that all personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification.

10.How long do we keep your data for?

We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required under law. We will either irreversibly anonymise or securely destroy your personal data once we no longer need it.

11.Your rights

(a)Access and correction

You have the right to access and correct any of your personal data held by us.  You can submit any requests for access to or correction of your personal data at any time to our property services manager at admin@manulifeplace-hk.com.

In order to ensure that your personal data is kept as accurate as possible, please update your user account information on the App.

(b)Opt-out of direct marketing

At any time, you can ask us to stop using your personal data to send you Marketing Communications or can customise how you would like to receive Marketing Communications from us. You can exercise such rights by either:

·emailing our property services manager at admin@manulifeplace-hk.com;

·changing your settings on your online user account using the App; or

·following the unsubscribe instructions in the Marketing Communications we send to you.

We will stop providing you with Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your user account.

12.Online tracking technology

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements. We may use cookies and other similar identification technologies such as web beacons and pixel tags for various purposes (“OTTs”), including verifying users; remembering user preferences and settings to enhance your experience when you return to using our App; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our App; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our App. We utilise Google Analytics for Firebase (“Firebase”) in order to process the above-mentioned OTTs – more details on Firebase may be found at Google Analytics for Firebase Use Policy.

If we use cookies, you can exercise your right to choose whether or not to accept cookies by adjusting your App or browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.

13.Links to other sites

Our App may contain links to other third party websites and applications, including those of our Affiliates (“Third Party Sites”).  We do not own or control, and are not responsible for the privacy practices of those Third Party Sites. We encourage you to remain alert if you follow any links to leave our App, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.

14.How do we manage updates to this policy?

From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary. We will notify you of any updates in accordance with your preference settings and, where required by law, obtain your consent. We will inform you by emailing you at the email address you provided us, and/or by posting a notice of these changes on our App.

15.How to contact us

If you have any questions or comments concerning this Privacy Policy, you can contact our property services manager at admin@manulifeplace-hk.com.