1.Your Privacy

HART Collective Limited (“HART”) ( “we” or “us”) respects your legal rights of privacy when collecting, storing, using and transmitting personal data and this Privacy Policy and Personal Information Collection Statement (the “Statement” ) explains our privacy practices. It is our policy to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “Ordinance” ) of the Laws of the Hong Kong Special Administrative Region of the People’s Republic of China ( “Hong Kong” ). Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by us is accurate. We will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.

Please read the following carefully to understand our policy and practices regarding how your personal data will be treated. This Statement applies to users of the Slot Game to be launched from 25/3/2019 to 31/3/2019 and held at Ground Floor of H Queen’s, 80 Queen’s Road Central, Hong Kong and our website (the “Website” ) and may from time to time be revised or otherwise changed where we deem necessary.

If there is any inconsistency between the English and Chinese version of this Statement, the English version shall prevail.

Throughout this Statement, the meaning of the term “personal data” is defined in the Ordinance.

2. Data Collection and Use

We may collect your personal data including but not limited to your name, gender, occupation, telephone number, address and email address (“Personal Data”) in order to provide you with information of our events, promotions, products and/or services. You are not obliged to supply the data, but if you do not, we may not be able to provide you with our products or services.

The purposes for which we may use your personal data are as follows:-

(i)   offering, providing and marketing to you our products/services, our products/services jointly provided with our business partners, and/or products/services of Henderson Development Agency Limited (“Henderson”), our parent company (see “Use and provision of personal data in direct marketing” at paragraph 4 below), and administering, maintaining, managing and operating such products/services;

(ii)  collecting data for identity verification and record and maintaining contact lists for correspondence;

(iii) processing and evaluating any applications or requests made by you for products/services offered by us, and that of Henderson;

(iv) designing, providing and marketing to users our facilities, services and/or products, and that of Henderson;

(v)  promoting, improving and/or further the provision of our facilities, services and/or products, and that of Henderson;

(vi) conducting market research for statistical purposes;

(vii)       delivering information that users may have interest in, such as targeted banners, new services and products and other promotions and marketing materials;

(viii)      communicating with our investors and/or potential investors, and that of Henderson;

(ix) matching any data held which relates to you from time to time for any of the purposes listed herein;

(x)  complying with any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply; and

(xi) any other purpose(s) which has been agreed by or notified to you.

If you are under the age of 13, you must ask your parent or guardian before providing any personal data to us.


We will take all practicable steps to keep your personal data confidential but for any one or more purpose(s) named in paragraph 2 above, we may transfer/assign your personal data to or exchange such data with any of the following parties irrespective of whether such parties are located inside or outside Hong Kong:

(i)        any agent, contractor or third party service provider who provides administrative, telecommunications, computer and other services to us with respect to the operation of our business;

(ii)        Henderson;

(iii)       our business partners assisting us in providing our products/services; or

(iv)       any person to whom we are under an obligation to make disclosure under the requirement of any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are reasonably expected to comply.

Unless expressly stated in this statement or with prior consent, personal data collected from you will not be disclosed to any third party other than the above-named parties.

 4.Use and provision of personal data in direct marketing

We intend to:

(i)   use the Personal Data held by us from time to time for direct marketing;

(ii)  conduct direct marketing in relation to the following classes of products and services that we may offer and/or Henderson: any new and/or existing services, products, facilities, activities, contests, lucky draws and/or other events, such as using our websites or mobile applications, following or using our social media accounts e.g. Instagram Official Account, receiving emails or text messages from us or sending us emails or text messages, using our telephone customer service, etc. relating to us and/or Henderson or our or their portfolios of properties or tenants in such portfolios of properties.  If you do not provide the relevant Personal Data, you may not be able to register as our user, enjoy our services, or, even if we continue to provide you with certain services, the quality of such services may not be optimal;

(iii)  the above products and services may be provided by us and/or:

a) Henderson;

b) our business partners, agents and/or contractors; and/or

c) third parties;

(iv) in addition to marketing the above products and services, we also intend to provide the Personal Data to all or any of the persons described in sub-paragraph (iii) above for use by them in marketing those products and services, and we require your written consent (which includes an indication of no objection) for that purpose;

Before using your personal data for the purposes and providing to the transferees set out above, we must obtain your written consent, and only after having obtained such written consent, may use and provide your personal data for any promotional or marketing purposes.

You may in future withdraw your consent to the use and provision of your personal data for direct marketing.

If you wish to withdraw your consent, please inform us in writing to the address in the paragraph 10 below. We shall, without charge to you, ensure that you are not included in future direct marketing activities.

5.Links to Other Websites

This Statement only applies to the Website. If you click on any advertisement or hyperlink linking to other website(s), you will leave this Website for another location. At any other website, the protection of your privacy, personal data and your exposure to cookies are not our responsibility and you are advised to refer to the privacy policy of that other location (if any).

 6.Web Logs

When a user visits the home page of the Website, the visit will be counted and included in the total number of visits to the Website for statistical purpose. This information does not identify you as an individual. No personal data will be collected.


Except as mentioned in paragraph 3 above, your personal data, however stored, will be accessed only by our employees or contractors who are authorized to do so and owe a duty of confidentiality to us. Such authorized personnel or contractors designated to handle personal data will be instructed to do so only in accordance with this Statement.

 8.Use of Personal Data in Legal Proceedings

If it becomes necessary that we have to take action against you for any reason whatsoever including but not limited to recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and take legal action against you.

9.Your Right to Access and Retention

You may at any time request access to and correct personal data relating to you in any of our records. To exercise any of your rights, contact us at the address below marking your communication “Confidential”. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the data refers. We are required to respond to your requests within 40 days and we will endeavor to do so wherever possible, but we may charge you a reasonable fee for doing so.

10.Personal Data Privacy Officer

The person to whom (1) requests (a) for access to data or correction of data; (b) for general information regarding our policies and practices with respect to personal data; and (c) about the kinds of personal data that we hold and (2) general questions and complaints should be addressed is as follows:-

HART Collective Limited
Personal Data Privacy Officer (HART)
(Marked Confidential)
Address:71/F, Two International Finance Centre, 8 Finance Street, Central, Hong Kong

11.Retention of Data

We will only keep your personal data for as long as necessary to fulfill the purpose for which the data was collected unless the personal data is also retained to satisfy any applicable statutory or contractual obligations. Personal data which no longer required will be destroyed.