Mason Swaine & Co (“Mason Swaine”, “the Company”, “we”, “us” or “our”) is a licensed estate agency company operating in Hong Kong (Estate Agents Authority company licence no. E-297373-A000). We are committed to protecting the privacy and personal data of our clients, landlords, tenants, buyers, sellers, website visitors and other individuals we deal with, in accordance with the Personal Data (Privacy) Ordinance, Cap. 486 (“PDPO”) and any codes of practice issued by the Office of the Privacy Commissioner for Personal Data (“PCPD”).

This Privacy Policy Statement (“Policy”) explains what personal data we collect, why and how we collect it, how we use, store, disclose and protect it, and the rights available to you. It applies to personal data collected through our offices, by telephone or email, through property viewings and transactions, and through our website and any related digital channels.

1. What Personal Data We Collect

Depending on your dealings with us, the personal data we may collect includes:

• Identification data: name, Hong Kong Identity Card number or passport number, date of birth, and photographs taken during identity verification;
• Contact data: residential or correspondence address, telephone number(s) and email address;
• Property and transaction data: details of properties owned, leased, bought or sold, preferences, budget, viewing history, offers made, and terms of tenancy or sale and purchase agreements;
• Financial data: proof of funds, mortgage or loan information, bank account details and payment records, where relevant to a transaction, deposit or commission arrangement;
• Due diligence data: information collected to satisfy anti-money laundering and counter-terrorist financing obligations applicable to estate agency practice, including source-of-funds declarations;
• Communications: records of correspondence, enquiries, instructions and complaints made to us by phone, email, in person or through our website;
• Website and technical data: IP address, browser type, device information, and information collected through cookies and similar technologies (see Section 7).

We only collect personal data that is adequate and relevant, and not excessive, for the purposes described in this Policy.

2. How We Collect Personal Data

We generally collect personal data directly from you, for example when you:

• Engage us to help you buy, sell, let or rent a property, or instruct us as landlord, tenant, vendor or purchaser;
• Attend a property viewing, open house, or meeting with one of our agents;
• Submit an enquiry form, contact us by telephone or email, or subscribe to property alerts or newsletters on our website;
• Provide identity documents or financial information for due diligence, agreement preparation or commission arrangements;
• Interact with our website, including through cookies and analytics tools (see Section 7).

We may also receive personal data from third parties in the course of a transaction, such as the other party's solicitors, financial institutions, co-agents, developers, property management companies, or government departments (for example, the Land Registry), where reasonably necessary to complete a property transaction.

3. Purposes for Which We Use Personal Data

We may use your personal data for the following purposes:

• Providing estate agency services, including arranging viewings, negotiating and concluding tenancy or sale and purchase transactions;
• Verifying identity and conducting due diligence, including anti-money laundering checks required of licensed estate agents;
• Preparing and administering agreements, invoices, commission statements and related documentation;
• Communicating with you about properties, appointments, transactions and account matters;
• Complying with our obligations under the Estate Agents Ordinance (Cap. 511), the Estate Agents Authority's Code of Ethics and Practice Circulars, and other applicable laws and regulations;
• Direct marketing of property listings and related services, subject to Section 5 below;
• Improving our services, training staff, and maintaining internal records; and
• Handling enquiries, complaints and, where necessary, legal proceedings or dispute resolution.

4. Direct Marketing

We may wish to use your name and contact details to send you information about property listings, market updates and related services that may be of interest to you (“direct marketing”). In compliance with Part 6A of the PDPO:

• We will not use your personal data for direct marketing unless we have first notified you of our intention to do so and of the kinds of personal data and classes of marketing subjects to be used, and have obtained your consent or an indication of no objection;
• You may withhold or withdraw your consent to receiving direct marketing at any time, free of charge, by using the opt-out or “unsubscribe” mechanism provided, or by contacting us using the details in Section 9;
• If you ask us to stop using your personal data for direct marketing, we will cease to do so without charge.

5. Disclosure and Transfer of Personal Data

We may disclose or transfer your personal data to the following classes of recipients, where reasonably necessary for the purposes set out in this Policy:

• The other party to a transaction and their agents, solicitors or financial institutions;
• Co-agents, developers, landlords, tenants, vendors and purchasers involved in the same transaction;
• Government and regulatory bodies, including the Estate Agents Authority, the Land Registry and law enforcement agencies, where required by law;
• Our professional advisers, including lawyers, accountants and auditors;
• Service providers who assist us with IT, data storage, marketing or administrative support, and who are bound by confidentiality and data protection obligations; and
• Any successor to our business in the event of a merger, acquisition or transfer of business assets.

We require third parties who process personal data on our behalf to protect that data to a standard consistent with this Policy and the PDPO. Where personal data is transferred outside Hong Kong, we take reasonable steps to ensure it continues to receive a comparable standard of protection.

We do not sell your personal data to third parties.

6. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, anti-money laundering or reporting requirements applicable to licensed estate agents. Transaction records are generally retained for the period required under the Estate Agents Ordinance and related regulatory guidance. When personal data is no longer needed, we securely destroy or anonymise it.

7. Cookies and Website Data

Our website may use cookies and similar technologies to operate effectively, remember your preferences, and understand how visitors use our site, including through analytics tools. Cookies may collect information such as your IP address, browser type, pages viewed and time spent on our website.

• Essential cookies are necessary for the website to function and cannot be switched off;
• Analytics cookies help us understand website usage so we can improve our content and services;
• Functional cookies remember choices you make, such as saved property searches;
• You can control or disable cookies through your browser settings; disabling certain cookies may affect the functionality of our website.

If you submit an enquiry, register for property alerts, or subscribe to our newsletter through our website, the personal data you provide will be handled in accordance with this Policy.

8. Data Security

We implement appropriate administrative, technical and physical safeguards designed to protect personal data against unauthorised or accidental access, processing, erasure, loss or use. These measures include restricted access to personal data on a need-to-know basis, secure storage of physical and electronic records, and staff training on data protection obligations. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Your Rights — Access and Correction

Under the PDPO, you have the right to:

• Check whether we hold any of your personal data and obtain a copy of it (a data access request);
• Request correction of any personal data we hold about you that is inaccurate;
• Be informed of the types of personal data we hold and the general policies and practices we apply.

Data access and correction requests should be made in writing to our Data Protection Contact using the details in Section 11. We will respond to a valid data access request within 40 days as required by the PDPO. We may charge a reasonable fee, limited to the direct cost of complying with the request, for a data access request.

10. Complaints

If you have any concerns about how we handle your personal data, please contact us first using the details in Section 11 so that we can investigate and address your concerns. If you remain dissatisfied, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD), whose contact details are publicly available at www.pcpd.org.hk.

11. Contact Us

If you have any questions about this Policy, or wish to make a data access, correction, or direct marketing opt-out request, please contact:

Data Protection Contact, Mason Swaine

Address: Level 16, The Hong Kong Club Building, 3A Chater Road, Central, Hong Kong

Email: masonswaine@me.com

Telephone: +852 6628 7582

12. Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices, our services, or legal and regulatory requirements. The updated Policy will be posted on our website with a revised effective date. We encourage you to review this Policy periodically.

© 2026 Mason Swaine & Co. All rights reserved.