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PRIVACY NOTICE

PRIVACY NOTICE

From time to time, just like many other companies, we collect or process personal data about you. In this privacy notice, we explain:
●what kind of information we process
●how we are collecting it, and
●what we are using it for.

Importantly, we also tell you what your rights are in relation to the personal data we hold and what you can do to enforce them.

1.INTRODUCTION
2.THE PERSONAL DATA WE COLLECT AND HOW WE COLLECT
3.PURPOSES YOUR PERSONAL DATA IS COLLECTED FOR
4.YOUR CONSENT
5.WHO HAS ACCESS TO YOUR PERSONAL DATA
6.HOW WE PROTECT YOUR PERSONAL DATA
7.PERSONAL DATA TRANSFER
8.WHAT RIGHTS DO YOU HAVE
9.DIRECT MARKETING
10.AUTOMATED DECISION-MAKING’ AND ‘PROFILING’
11.HOW LONG WE WILL KEEP YOUR PERSONAL DATA FOR?
12.PROTECTION OF MINORS’ INFORMATION
13.CONTACT US
14.UPDATES TO THIS NOTICE

If this privacy notice does not answer your questions, then get in touch with us by email or post and we’ll be happy to help.
Email: DPO@countrygarden.com.cn
Address: Country Garden Center, Beijiao Town, Shunde District, Foshan City, Guangdong Province

1.INTRODUCTION

Country Garden Holdings Co., Ltd, its subsidiary companies and affiliated companies. (“we”, “us”, “Country Garden”) are committed to protecting your privacy.
This privacy notice explains what personal data we collect about you when you use of our products, service or websites, or when you interact with us and how we use that personal data. It also explains the rights you have in relation to that personal data.
Some of our products and services have specific privacy policies applicable to their functions. Such as Phoenix universal、Phoenix Selection。This Privacy Policy does not apply to such services. Please check to see if the specific service you are using has its own service privacy policy and refer to htat for how we process your personal data and your rights. If a service does not have a specific privacy policy, this Privacy Policy shall apply.

2.THE PERSONAL DATA WE COLLECT AND HOW WE COLLECT

“Personal data”refers to any information relating to an identified natural person or an identifiable natural person. An identifiable natural person means a natural person that may be identified directly or indirectly through. For example, his/her name, ID card number, location data, and network identifier as well as his/her economic, cultural and social identify.
Your personal data will be collected directly or indirectly by your use of our products, service or websites, or when you interact with us, such as calling our hotline, creating a website account, participatin in our brand activities, through which your personal is directly provided to us.
We collect the following types of personal data from you :
Contact details: information that allows us to contact you such as your name, email address, telephone number and addresses associated with your customer record.
On-line account information: information that you provide to set up an on-line account with our website, app and etc. such as your name, contact details, username, password, and property preferences.
Payment information: credit/debit card details and bank account details you provide to make payment, for example for reservation fees.
Purchase and account history: records relating to activities such as purchases, viewing, and reservations of our properties.
Mobile data: when you access our website via your mobile, we collect information that includes your mobile device ID and Ad Manager identifiers.
Location information: your smartphone or computer's IP address may tell us an approximate location but this will be no more precise than the city, state or country you are using your device in.

3.PURPOSE YOUR PERSONAL DATA IS COLLECTED FOR

In the below table, we describe:
●the purposes we collect your personal data for; and
●the categories of personal data we process for that purpose.

Purpose of processing Categories of data processed
To contact you.
If you have indicated an interest in our services, including in a property or development, you have requested a viewing or you have submitted a call-back request or response.
If you have indicated an interest in attending one of our exhibitions, open-days or launches.
Name and contact details provided e.g. email address, telephone number, social media account address etc.
To respond to any queries you send through to us. If you have sent us a query or question by letter, e-mail, via telephone, social media or a similar online platform. Name and contact details provided e.g. email address, telephone number, social media account address etc. A record of the information you provide as part of your query and a copy of the response we provide to you.
To register you as a new customer. If you have indicated an interest in buying, selling, renting, viewing or reserving a property with us. Name and contact details provided e.g. email address, telephone number etc. Your account log-in details and password.
To provide our direct services to you. If you have reserved and/or purchased a property and to meet our post sale agreement with you. Name and contact details. Your gender, nationality, occupation. Your client type and status. Financial information including your credit card details. Transaction information. Information about the contract/agreement we have entered into with you. Your signature. Details of communications we have with you. Information we need to respond to any request or query you make to us.
To facilitate our third party contractors or suppliers to provide agreed services to you e.g. mortgage advisors, our lawyers, lettings advisors, furnishing providers etc. Where we use a third party and/or contractors to provide services on our behalf when you are viewing, reserving, selling or buying a property from us and, to deliver our post sale agreements with you. Name and contact details e.g. postal and home address, email address, telephone number etc. Your client reference number. Your gender, nationality and occupation. Your client type and client status e.g. the point you have reached as a client in our sales process. Details of services and orders you have requested from a third party contractor or supplier. Details of communications we have with you.
To take payment for our products and services. Transaction and payment information, including credit card details.
To verify your identity and, to undertake necessary checks prior to you purchasing a property from us. Contact Name and contact details e.g. postal and home address, email address, telephone number etc. Payment information. Photographic ID and other relevant information that allows us to undertake our anti money laundering (or similar) checks in accordance with our legal requirements when you purchase a property from us.
To enable us to market our products and services to you. If you have expressed an interest in our products and services, or, if you have subscribed to any of our publications, we will send you relevant marketing material from time to time. You can opt out of receiving this information at any time. Your name and contact details you provide to us. e.g. email address, phone number. Your computer IP address. Your product and marketing preferences. Your customer profile. The log-in and password details for your on-line account. Details of any communications you have with us in relation to our direct marketing activities. Information about how you use our and selected third party’s websites. Cookie information . Mobile device ID and Ad Manager identifiers. Approximate location data.
If you have entered a competition, promotion or completed a survey we have sent to you. Name and contact details provided e.g. email address, telephone number, social media account address etc. Any additional information you have provided as part of a survey response or competition e.g. your property preferences, areas you would like to live in etc.
To enable us to offer you tailored advertising and services on our website. You can opt out of receiving this information and servcie at any time. Your name and contact details you provide to us. e.g. email address, phone number. Your computer IP address and log-in data. Your browser type and version, time zone setting, location data, device cookie and identification, browser plug-in types and versions, operating system and platform and other identifying information required for your device to communicate with our websites. Your product and marketing preferences. Your customer profile. Information about how you use our and selected third party’s websites. Cookie information. Mobile device ID and Ad Manager identifiers. Approximate location data.
To permit selected third parties:
a) to provide you with marketing information about properties or services which we feel may interest you.
b) to assist us in the improvement and optimisation of advertising, marketing material and the content of our services and website.
c) You can opt out of receiving this information and servcie at any time.
Your name and contact details e.g. email address, phone number. Your computer IP address. Your product and marketing preferences. Your customer profile. Details of any communications you have with agreed third parties in relation to direct marketing activities. Information about how you browse our and relevant third party websites. Cookie information –. Data that we collect from third party websites such as Zoopla and Rightmove based within the EU. 
To administer and protect our business and websites. To undertake troubleshooting, data analysis, testing and reporting to ensure our website is protected and working effectively. To ensure our website is functioning correctly and to make improvements to the functionality of our website. Your name and contact details you provide to us. e.g. email address, phone number. Your computer IP address. Your browser type and version, time zone setting, location data, device cookie and identification, browser plug-in types and versions, operating system and platform and other identifying information required for your device to communicate with our websites. Your customer profile. The log-in and password details for your on-line account. Payment information, purchase and account history. Information about how you use and browse our website.
To comply with requirements imposed by law or court orders. Identity and contact details. Your computer IP address. Information we hold about our service agreements or contract with you. Payment information, purchase and account history. How you have used our websites or services.

We will only use your personal data when the law allows us to. Most commonly, we will rely on the lawful grounds listed below when we use your personal data.
Consent: if you have consented to the collection and use of your personal data.
Contract: if we need to use your personal data to perform a contract between us. For example, where we enter into a contract with you to purchase a property from us, to provide you with agreed post-sale services, or to provide you with hotel services.
Legal obligation: if we need to comply with a legal obligation. For example, where we have a legal obligation to undertake anti money laundering checks or to process financial information for reporting purposes.
Legitimate interest: if our use of your personal data is for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes carefully considered and specific purposes that enable us to enhance the services we provide, but which we believe also benefit our customers and wider consumers.
Where the processing of personal data is based on a requirement to comply with our contractual obligations to you, or, to enter into a contract with you, failure to provide the personal data required may prevent us from carrying out our contractual agreement with you.

4.YOUR CONSENT

Where the legal basis for us processing your personal data is that you have provided your consent, you may withdraw your consent at any time. To the extent you have given us consent to collect and process your personal data, you may withdraw that consent to process your personal by deleting information, turning off device functions, changing privacy settings on our website. You can also withdraw your consent granted to us by deregistration so that we cannot continue collecting your personal data.
Please understand that each business function requires some basic personal data. Once you withdraw your consent or authorization, we cannot continue providing you with the services for which you withdraw consent or authorization, and will not process your corresponding personal data.
You will not suffer any detriment for withdrawing your consent. If you withdraw your consent, this will not make processing which we undertook before your withdraw your consent unlawful.
You can withdraw your consent by contacting us on:
Email: DPO@countrygarden.com.cn
Address: Country Garden Center, Beijiao Town, Shunde District, Foshan City, Guangdong Province

5.WHO HAS ACCESS TO YOUR PERSONAL DATA

We will not transfer your personal data to any other third party for thier processing for any purpose other than as permitted under this Privacy Policy, other Privacy of our products, service, or as otherwise consented to you. We share personal data with the following entities::
●Our staff – your personal data will be accessed by our staff and contractors but only where this is necessary for their job role. :
●Companies in the same group of companies as us - for the purpose of providing an agreed service to you and for internal administration and reporting purposes. :
For the purpose of providing you with information about properties or services that we feel may be of interest to you where you have agreed to this. :
●Sales Agents – your personal data will be shared with our sales agents when you have expressed an interest in or, are entering into an agreement with us to purchase a property.:
●Estate Management Company – your personal data will be shared with our approved estate management company to provide you with our agreed post-sale services. :
●Contractors we use to provide post sale services to you – for example to fix any defects you may report to us once you have purchased our property. :
●Third party service providers where you have agreed to additional post sales services – for example, where you have agreed to additional services such as mortgage broker advice, furniture packages, decorating services etc.:
●Organisations that undertake checks on our behalf – such as companies that undertake anti-money laundering checks.:
●Our service providers and advisors – we employ other companies and individuals to perform certain functions on our behalf. Examples include companies that support our IT systems, help us analyse the data we hold, process payments, send communications to our customers and provide us with legal support and financial advice. These third-party service providers have access to personal data needed to perform their functions, but may not use it for other purposes. Further, they must process the personal data in accordance with this Privacy Notice and as permitted by applicable data protection laws.:
●Utility companies – who are registered to provide services to a property that you have purchased. :
●Disclosure requested by competent authorities and law enforcement - We will make available your personal data to the public or specified audience only under the following conditions to the extent that security measures generally accepted in the industry have been taken:

At your request, and limited to the personal data you designate in the manner you have requested;

As required by applicable laws and regulations, mandatory administrative enforcement or judicial orders, we may disclose your personal data of the required type in the manner requested. Subject to laws and regulations, when we are requested to disclose, we will require the corresponding legal documents, such as summons or investigation letters. We believe that the information required to be provided by us shall be as transparent as possible to the extent permitted by laws. All requests will be carefully reviewed to ensure that they are legal and we will only disclose the data that the law enforcement agencies have legal right to obtain for specific purposes.

For companies, organizations and individuals with whom we share personal data, we will sign strict confidentiality agreements with them, requesting them to process personal data by taking relevant confidentiality and security measures in accordance with our instructions and this Privacy Notice. In the use of personal sensitive data, we require third parties to adopt data desensitization and encryption technologies to better protect your data.
We may also provide other third parties with statistical information and analytics but we will make sure that the information is aggregated and that no one can be identified from this information before we disclose it.

6.HOW WE PROTECT YOUR PERSONAL DATA

We value personal data security and will take all reasonable and practical measures to protect your personal data. That said, the Internet is not absolutely secure. We recommend that you use complex passwords when using such tools, and take care to protect your personal data.
We promise to use the safety protaction measure which meets the industry standard to protect your personal data. By strengthening the physical, administrative and technical sareguards( such as the acess control system, monitoring system, encryption, anonumizatioon, pseudonymizaton, and security training on employess) of personal data. we will endeavor to protect your personal data from unauthorized access, use, disclosure, modification, damage, loss and any other forms of unlawful processing. With a specialized business continuity plan, we are able to guarantee continuous service for our customers. We will formulate our information security policy and procedure in strict compliance with international standards, and will review and update such policy and procedure from time to time.
We attach great importance to infomation security and build Data Protection Office. We also take a high priority to ensure the security of your personal data by taking proper measures of management, techonology and physical secufiry. A normalized Information Security Protection System has been established either.
In the case of a personal data breach, we will without undue delay, and notify the personal data breach to the supervisory authority competent in accordance with GDPR, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.
When the personal data breach is likely to result in a high risk to your rights and freedoms, we will communicate the personal data breach to you without undue delay.

7.PERSONAL DATA TRANSFER

We are a multinational corporation. Generally, we will process your personal data in the country/region where you use our products or services. However, we may transfer your personal data to other country/region that may have different laws for the protection of personal data. Wherever we transfer your personal data, we will inform you the destination, recipient and related information and take efficient measures to comply with this Policy and applicable local laws. For instance, to transfer your personal data, we will seek your prior consent or sign a necessary data transfer contract with you.

8.WHAT RIGHTS DO YOU HAVE

Under certain circumstances you have the right to:
Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it, you withdraw your consent, we are unlawfully holding your personal data or we should erase your personal data to comply with applicable Chineselaw. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as a legal basis for our processing and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
Request the restriction of processing of your data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or stop us deleting personal data which you need for a legal claim.
Request that we transfer personal data that you have provided to us to you or another party.
You can exercise your rights by contacting us using the contact details at the end of this notice.
We will always aim to help you when you wish to exercise your rights but in some instances we may have lawful grounds to reject your request.
We will investigate any request you make without undue delay and in any event within one month of receipt of your request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
In the event that we decide to not take action on the request, we will inform you of the reasons for not taking action.
Lodging a complaint with the supervisory authority – if you do not agree with a decision we make in relation to a rights request or believe that we are in breach of applicable data protection laws then you can lodge a complaint with a competent data protection supervisory authority.

9.AUTOMATED DECISION-MAKING’ AND ‘PROFILING’

Automated decision making is when a company uses software to make decisions based on information that has been programmed into the software. With automated decision-making, there is usually no human involvement in the decision making process.
Profiling is where algorithms and software are used to analyse personal characteristics to identify trends in the behaviour or choices of individuals.
We undertake profiling for direct marketing purposes. This allows us to understand the effectiveness of any advertising we show you by measuring what adverts are clicked or viewed, and to provide you with more useful and relevant adverts. You can opt out of receiving this information and servcie at any time.

10.HOW LONG WE WILL KEEP YOUR PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, whether we can achieve those purposes through other means and the applicable legal requirements.
Unless otherwise specified by laws and regulations, we will remove or anonymize your personal data within one month from the date when your account is cancelled. If the foregoing period expires, we will remove or anonymize your personal data.
In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

11.PROTECTION OF MINORS’ INFORMATION

Country Garden attaches great importance to the protection of minors' personal data. If you are a minor under the age of 16, you must obtain prior written consent from your parent or legal guardian before using our products and/or services. We protect personal data of minors in accordance with applicable privacy laws and regulations. For the personal data of minors collected with the consent of parents or legal guardians, we will only use or disclose when permitted by laws, explicitly consented by the parent or guardian or required for protecting the child. If we find ourselves collecting personal data of a minor without the prior consent of a verifiable parent or legal guardian, we will delete it as soon as possible.

12.CONTACT US

If you have any questions about how we process your personal data, you can contact us using the details below.
Email:DPO@countrygarden.com.cn
Address: Country Garden Center, Beijiao Town, Shunde District, Foshan City, Guangdong Province

13.UPDATES TO THIS NOTICE

We may update this notice from time to time to reflect changes in the way we process personal data (e.g., if we implement new systems or processes that involve the new uses of personal data) or to clarify information we have provided in the notice. Our changes will be in accordance with applicable data protection laws.
We recommend that you check for updates to this notice from time to time but we will notify you directly about changes to this notice or the way we use your personal data when we are legally required to do so.