This policy statement provides information on the obligations and policies of SAVILLS PROPERTY SERVICES (SHANGHAI) CO., LTD., the “Company”), under the Laws and Regulations on the protection of personal data including but not limited to the Constitution, the General Principles of Civil Law, the Criminal Law, the Tort Law, the Cybersecurity Law (hereinafter collectively the “Privacy Legislation”). Savills is committed to protecting the personal data of individuals and therefore it is the Company policy to ensure its policies and practices in relation to the collection, use, transfer, storage and access of personal data comply with the requirements of the Privacy Legislation.

Throughout this policy, the meaning of the term “personal data” is as defined in the Notice of the Supreme People's Court, the Supreme People's Procuratorate, and the Ministry of Public Security on Legally Punishing Criminal Activities Infringing upon the Personal Information of Citizens, and in the new Cybersecurity Law scheduled to take effect since June 1, 2017.



For the purpose of complying with the laws of the People's Republic of China (including the Laws and Regulations on the real estate services and the prevention of money laundering) and verification of the identity of both the vendor/landlord and the purchaser/tenant, and in order to market properties and provide services, and administrative function of the Company, customer may be required to provide his/her:-

1. name;

2. telephone number;

3. address;

4. contact details;

5. payment details;

6. identity card number;

7. passport;

8. bank statements;

9. credit card; and

10. utilities bills.



Customer’s personal data will be collected upon:

1. signing the estate agency agreement to appoint us as customer’s estate agent;

2. signing the provisional sale and purchase agreement/tenancy agreement or memorandum of the like;

3. purchasing first hand property;

4. contacting us for enquiry or complaint;

5. participating in our marketing and promotional activities or competitions;

6. using or visiting our website.



The personal data provided by the customer may be used by the Company for the purpose of:-

1. provision of real estate services;

2. promotion and marketing of the services, products and/or events of the Company;

3. introducing to the customer with his/her consent the following services and products relating thereto (the Company may or may not receive remuneration as a result of any such introduction) :-

   a. legal services;

   b. mortgage referral;

   c. banking;

   d. financial;

   e. wealth management; and/or

   f. insurance;

4. compliance with the applicable laws, rules and regulations as well as the guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company;

5. collection of outstanding sums from customer; and/or

6. legal proceedings and/or enforcement of judgments and/or orders.



All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:

1. co-operative estate agents;

2. law firms;

3. banks or financial institutions;

4. insurers;

5. mortgage referral services providers or;

6. wealth management services providers;

7. government agencies, regulatory bodies and/or other lawful authorities as required or authorised by law;

8. courts, tribunals and/or parties to the legal proceedings.

Personal data may also be disclosed to any person or persons pursuant to any statutory or contractual obligations or as required by court of law, provided such person or persons are able to prove the required right/authority to access such information. In addition, personal data may be disclosed under any of the circumstances described in Article 42 of the Cybersecurity Law in which the concerned personal data are exempt from the provision of the Privacy Legislation.



The Company has certain procedures in place to maintain personal data at a reasonable level of accuracy, completeness and relevancy for the purpose for which the personal data is to be used. The Company aims to keep personal data accurate and up-to-date. However, the Company relies on the customer to disclose all material information to the Company and to inform the Company of any errors or changes in such information.

The Company fully complies with the rights of access and correction obligations of the Privacy Legislation. The customer is entitled to require the Company to make corrections if he or she founds errors in such information held by the Company. The Company will take measures to delete the information or correct the error.



Personal data of customer will only be retained for as long as is necessary to fulfill the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations, or such longer period as prescribed by applicable laws, rules and regulations as well as guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to the Company.



In accordance with the requirements of the Privacy Legislation, the Company will honor a customer’s request not to use his or her personal data for the purpose of direct marketing.

Upon customer’s consent, the Company may deliver to customer, through various communication channels by using email address correspondence, address, mobile phone number, telephone number, service number and service account number, various promotion material relating to real estate services.

Customer can at any time send written request to our Data Protection Officer at SAVILLS PROPERTY SERVICES (SHANGHAI) CO., LTD., 25/F, Two ICC, 288 Shaanxi Road, Shanghai, 200031, China, to stop receiving the promotion materials aforesaid or to start receiving the same (if customer has unsubscribed from receiving such materials before).



Under the Privacy Legislation, customer has the right to access and/or correct his/her personal data. Accordingly, customer may write to the Data Protection Officer of the Company at SAVILLS PROPERTY SERVICES (SHANGHAI) CO., LTD., 25/F, Two ICC, 288 Shaanxi Road, Shanghai, 200031, China. In accordance with the Privacy Legislation, the Company has the right to charge a reasonable fee for the processing of any data access request.



All enquiries about this statement or personal data shall be addressed in writing to the Data Protection Officer of the Company at SAVILLS PROPERTY SERVICES (SHANGHAI) CO., LTD., 25/F, Two ICC, 288 Shaanxi Road, Shanghai, 200031, China.

The Company reserves the right to amend this statement and/or any part thereof.


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