Privacy Policy

I. General

This Privacy Policy (“this Policy”) is made by Link Real Estate (Shanghai) Co., Ltd. and its affiliated companies (“Link” or “we/us”, having its address at Room 919, Floor 9, No. 222 Hubin Road, Huangpu District, Shanghai) in accordance with Personal Information Protection Law of the People’s Republic of China (“Personal Information Protection Law”) and other applicable laws and regulations. In order to provide qualified services and products to you, and to establish/maintain better cooperative and employment relationships with you, we undertake to process your personal information in accordance with the provisions of Personal Information Protection Law and applicable laws and regulations.

Link attaches much importance to the protection of your personal information, so before accepting our products and services or establishing cooperative or employment relationships with us, you are kindly requested to carefully read this Policy, which describes, in detail, our purposes and methods of collecting, storing, using and sharing your personal information. Additionally, this Policy clarifies your rights to personal information, and how you may contact and communicate with us or relevant regulatory authorities when you make any complaints.

1. We will process your personal information in a lawful, legitimate and essential way and in good faith, only for the particular purposes relating to our businesses and activities.
2. We will take all reasonable and practicable measures to ensure that the personal information collected or retained is essential and accurate for the purpose of use.
3. We will take all reasonable and practicable measures to ensure that personal information is retained no longer than the minimum time period necessary for the purpose of use.
4. We will use any personal information collected by us only for the purpose of use at the time of collection or other directly related purposes, unless you expressly consent to the change of purpose, or such purpose is permitted under relevant laws and regulations.
5. We will take all reasonable and practicable measures to ensure protection of personal information and prevent personal information from any unauthorized or accidental consulting, handling, deletion or other illegal uses.
6. We will take all reasonable and practicable measures to ensure that you are informed of the type of personal information held by us and the intended purpose of such information.
7. You have the right to request to consult and/or correct your personal information held by us. Your above request will be dealt with in accordance with relevant laws and regulations.
8. All of our employees must abide by our obligations of security and confidentiality in relation to the collected personal information.

II. How We Collect and Use Your Personal Information

In any scenario where we collect your personal information, we will provide you with relevant notices such as privacy policy applicable to this scenario, so that you may fully understand the purpose, method and scope of our collection and use of your personal information, your rights to your personal information and the protective measures taken by us for ensuring information security. You are kindly requested to carefully read the said notices, and after you have been fully aware of and accurately understood the provisions and relevant legal consequences thereunder, you may accept relevant notices by clicking the “agree” button. 

You understand that, in particular scenarios, we may be unable to directly inform you of the handling rules of personal information in writing and obtain your prior consent. In such cases, we will, orally or through public announcement, notify you of the particulars of how we deal with the personal information, and seek for your consent or provide you with the specific method to withdraw from our personal information processing activities. You may refer to the contents specified in this Policy, in respect of your rights to your personal information, the channel to exercise such rights, and the protective measures taken by us for ensuring information security. In particular, you understand, that we may process your personal information without your consent, in any of the following scenarios:

1. where it is necessary for the conclusion or performance of a contract to which the individual concerned is a party, or for the implementation of human resources management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract concluded in accordance with the law；
2. where it is necessary for the performance of statutory duties or statutory obligations;
3. where it is necessary for the response to a public health emergency or for the protection of the life, health and property safety of a natural person in an emergency;
4. where the personal information is processed within a reasonable scope to conduct news reporting, supervision by public opinions and other activities in the public interest;
5. where the personal information disclosed by the individual concerned or other legally disclosed personal information is processed within a reasonable scope in accordance with applicable laws and regulations.

We hereby list certain scenarios in which we may collect your personal information and the contents of personal information to be collected. Please understand that we may not be able to list all personal information collected by us herein due to the diversity of services provided by us and businesses operated by us. However, when providing you with certain products and services or in order to establish/maintain better cooperative or employment relationships with you, we will perform the obligation of notification and/or obtaining consent for the processing of your personal information in compliance with appliable laws and regulations.

1. WeChat Official Account(s) or Mini Program(s) of Link’s Mall(s)

• Member Registration in Mini Program(s). To register as a member, you must authorize us to use WeChat platform account for registration. Based on your authorization, we will obtain your account information from WeChat platform, including your WeChat nickname, profile photo, mobile phone number bound to WeChat account and your unique user ID on WeChat Mini Program platform. You may choose to fill in new nickname, change profile photo or bind new mobile phone number to your membership account. If you refuse to register as our member, you may continue to view the contents in the Mini Programs, but you cannot use the member services, including but not limited to earning membership points, redeeming membership points for gifts or discounts on parking fees.
• Follow WeChat Official Account(s). When you follow relevant WeChat official account of Link, we will, through WeChat platform, obtain your unique user ID, WeChat nickname and profile photo on WeChat official account platform, and will bind them to your unique user ID on WeChat Mini Program platform, so as to forward information to you.
• Mall Parking. To facilitate your use of the parking services at Link’s malls, you may, through providing the plate number of your vehicle, check parking information and estimated parking fees on a real-time basis. If the plate number you provide is not of your own vehicle, you are obliged to obtain separate consent from the relevant owner before the provision.
• Membership Points. After you purchase any products from a merchant operating in any of our malls, to timely earn your membership points, you may, through authorization, permit taking photo or access to photo album and thereby upload the shopping receipt or scan the QR code on the receipt, so as to provide us with relevant transaction and consumption records and information, such as the name of merchant, the purchase price, date and time of the consumption and the purchase order number. If you refuse to provide the said personal information, you may continue to shop at the merchants, but you will not be able to earn membership points or enjoy other benefits and services exclusive for members. Additionally, we’d like to draw your attention that the Mini Program “Link Central Walk” has opened the payment function in WeChat trading area; if you make payment through WeChat at our cooperative merchant, without your further authorization, we will, through WeChat, automatically obtain relevant transaction and consumption records and information, such as the name of the merchant, purchase price, date and time of the consumption and purchase order number.
• When you use our services, we will collect some log information on your use of our services. Such information is collected mainly for ensuring safe operation of the services, so that we may provide better services to you. Such information is usually collected through cookies used by us.

2. Parking Services

• When you use our hourly rental services in the parking area, we need to collect the plate number of your vehicle when you drive into the parking area, so as to provide convenient services to you and ensure safe and orderly operation of the parking area.
• When you use our long-term rental services in the parking area, you need to fill in relevant forms and submit relevant documents, so as to register your ID and the vehicle information. In particular, we may need to collect your personal information including your name, plate number of your vehicle, telephone number and your company name. Besides, certain parking areas require verification of your identity as a homeowner, so may need to collect your personal information including name and telephone number of your emergency contact, ID card and property ownership certificate; if you are not the homeowner, you should provide the name and ID card of the homeowner, your relationship with the homeowner, and the relevant certificate/document (such as household registration or marriage certificate).

3. Lucky Draw and Gift with Purchase over Certain Amount

• Online Lucky Draw. In order to verify your eligibility for the lucky draw, contact you for claiming rewards, carry out our compliance standards and perform our obligation of bookkeeping, we need to collect your name and phone number and request you to show us your shopping receipt and payment voucher. If you refuse to provide the said information to us, you may enjoy other products or services provided by us, but you will not be able to take part in the online lucky draw.
• Offline Lucky Draw. We need to collect your name and telephone number, in order to contact you for claiming rewards and perform our obligation of bookkeeping. Additionally, in order to verify your identity and carry out our compliance standards, when claiming the rewards, you need to show your ID card, which will be copied for filing. If you refuse to provide the said information to us, you may enjoy other products or services provided by us, but you will not be able to take part in the offline lucky draw.
• Gift with Purchase over Certain Amount (“GPCA”). We need to collect your name, telephone number and your shopping receipt, in order to verify your eligibility for receiving the gift, ensure the fairness and justice of the promotion event, carry out our compliance standards and perform our obligation of bookkeeping. If you refuse to provide the said information to us, you may enjoy other products or services provided by us, but you will not be able to take part in the GPCA promotion.

4. Market Survey

To help us better understand consumers’ demand, improve our service quality, and establish/maintain better cooperative and employment relationships with you, we may, from time to time, invite you to participate in our market survey. Our questionnaire may involve collecting and handling of your personal information, and for details, please refer to relevant questionnaires. We will also provide you with the option to opt out anytime.

5. Routine Property Management Services

If you visit any of Link’s properties, you may need to provide us with the following personal information: your name, identity information, telephone number, track record on travel code, nucleic acid testing record, and COVID-19 vaccine certificate, for security and property management purposes.

6. Contract Management

When you (on behalf of a legal entity) execute any contract with us, we may, based on the contents of such contract, collect information such as the name and address of your company, your name, identity information, bank account, title, telephone number, mobile phone number and e-mail address.

7. Subscription to 823 Channel

If you subscribe to 823 Channel, you need to provide us with your e-mail address. You have the right to cancel your subscription to the 823 Channel services at any time.

8. Application for Job

When you submit a job application to us through any channel, we may collect the following personal information as reference information for our recruitment or conduct a background investigation, including name, e-mail address, telephone number, country and city/region (optional) of residence, working experience, education background, professional qualification, language level, current remuneration level (optional), and criminal record. We will also collect the personal information contained in your CV, application letter and certificates provided by you.

9. Exchange of Business Cards in Commercial Activities

When you exchange business card with our business personnel, we may collect your personal information including name and address of the company, your name, title, telephone number, mobile phone number and e-mail address, so as to keep in touch and conduct business communication with you. You have the right to refuse our contact for business communication purposes at any time, however, such refusal may affect our business communication and cooperation with you or your company.

III. Usage of Your Personal Information

1. Your personal information may be used for routine management and operation of our business, improvement of the services provided by us to customers and tenants, and establishment/maintenance of better cooperative and employment relationships with our suppliers, partners, employees and job-seekers;
2. Your personal information may be used for application, management, renewal and termination of the leases or space use agreements in relation to Link’s malls, offices, warehouses, spaces and parking areas (“Link’s Properties”), and for the services provided in such properties;
3. Your personal information may be used to identify, match identities and/or for filing purposes, so that we can keep in touch and cooperate with our customers, tenants, employees, job-seekers, suppliers and other partners and update the information thereof;
4. Your personal information may be used to handle enquiries and feedback, so as to provide better services to tenants of and customers in Link’s Properties and to establish/maintain better employment and cooperative relationships with Link’s employees, job-seekers, suppliers and other partners;
5. Your personal information may be used for internal statistics and analysis; and
6. Your personal information may be used for us to provide our tenants, customers, employees, job-seekers, suppliers, and other partners with the latest information and activities relating to Link’s Properties, and the latest development of Link.

IV. Your Rights to Personal Information

In accordance with applicable laws, regulations and regulatory provisions, we procure that you may exercise the rights to your personal information, and we agree to reply or respond to your following requests/claims within 15 working days:

1. restrict or refuse our processing of your personal information;
2. access to relevant privacy policy and your personal information;
3. correct or supplement your personal information;
4. consult your personal information and make copies thereof;
5. request deletion of your personal information in circumstances where: the storage period has expired, the handling of your Personal Information is no longer necessary, or your consent has been withdrawn (only applicable to the handling of the personal information for which your consent is required), unless otherwise stipulated by relevant laws and regulations;
6. change the scope of your authorization/consent (only applicable to the handling of the personal information for which your consent is required), provided that the legality of handling personal information prior to such change will not be affected or prejudiced thereby;
7. de-register your account; and
8. transmit your personal information to other personal information data processors in compliance with provisions of laws and regulations.

You may understand the methods of exercising the abovementioned rights by reading relevant privacy policies. In any event, you may contact us at any time by sending an e-mail to [email protected].

We would like to draw your attention that, your restriction on/refusal to our processing of your personal information or change of the scope of your authorization/consent, or withdrawal of your consent, may under some circumstances affect Link’s employment with you, or affect Link to provide certain services/continue with the corporation with you or your company.

In order to ensure safety, we may require you to submit a written request and verify your identity before handling your request. You understand we may reject certain requests that are repeated without justifiable cause, require excessive technical means, cause risks to the legitimate rights and interests of others, or are extremely impracticable. Please note that if we decided not to respond to your request, we will inform you of the reason for such decision and provide you with the channel for making complaints.

In principle, we do not charge fees for any reasonable request but will charge certain costs for repeated requests within a period of time. For claims that rely on excessive technical means (for example, requiring development of new systems or making fundamental change to existing practices), require high costs, or involve significant difficulties in the implementation process, we will exert our best efforts to provide alternative options to you, so as to protect your legitimate rights and interests. Additionally, if your requests involve handling others’ personal information, you need to obtain others’ consent regarding handling their personal information. Lastly, if we decide to reject your requests according to law, we will notify you of the reason for our decision.

V. How We Process Personal Information of Minors

Our services and business cooperation are not oriented to any minors below the age of 14. If we find any personal information of minors collected without provable prior consent by their guardians, we will try our best efforts to delete relevant data as soon as possible.

Where you are the guardian of a minor below the age of 14, if you have any queries about the handling of information of a minor under your guardianship or have evidence proving that such minor has registered and used our services without your consent, please contact us through the communication methods as provided in Part IX of this Policy.  

VI. Storage and Security of Personal Information

We will take all reasonably practicable measures to ensure that no irrelevant personal information being is collected. Furthermore, we will retain your personal information only for the period necessary to achieve the purpose described in this Policy, unless an extension of the retention period is required, or the retention is permitted by relevant laws and regulations or authorized by you.

We exert our best efforts to protect your personal information and prevent your personal information from any unauthorized or accidental consulting, handling, deletion, or other illegal use. We try to protect your personal information and ensure its security by means of implementing various proper physical, electronic and administrative measures.

We have implemented industry-standard security measures to protect the personal information you provide from unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable measures to protect your personal information. For example, we will use encryption technology for ensuring confidentiality of information and data; we will use reliable protective mechanism to prevent the data from malicious attack; we will deploy access control systems, so that only authorized persons may have access to personal information; moreover, we will hold security and privacy protection training courses, to strengthen employees’ understanding on the importance of protection of personal information. In case divulgement, falsification or loss of personal information occurs or might occur, we will, in accordance with requirements of laws and regulations, timely notify you of the basic information of such security event and its influence, the measures taken or to be taken by us, our advice on how you could protect your personal information and to mitigate risks, and remedies provided to you. We will timely notify you of relevant details of such event by mail, letter, telephone or push notification, and if it is difficult to notify each owner of personal information individually, we will issue public announcements in a reasonable and effective way.

The internet environment is not absolutely safe, and we will exert our best efforts to ensure or guarantee the security of any information sent by you to us. If our physical, technical, or administrative protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information which causes damages to your legitimate rights and interests, we will bear the corresponding liabilities in compliance with applicable laws and regulations.

VII. Use of Cookies

Your visits to this website may be recorded for the purpose of analyzing visitor numbers and general usage patterns. Certain information may be collected through “cookies”. “Cookies” are small pieces of data automatically stored in the browser of the user’s computer and may be searched by this website. Cookies may, according to the information on your selection sequence of certain websites, enable the owner of such website to provide customary and personalized services or products to the users, so as to make the website efficient. The information stored in Cookies is anonymous integrated research information and does not contain personal information such as name or Domain Name Server address that may enable anyone to contact you by telephone, e-mail, or any other means. Most browsers are initially set to accept cookies.  You may set the browser not to accept cookies or to inform you when cookies are set. However, if you do not accept cookies, you may be unable to fully utilize this website.

VIII. Updates of this Policy

This Policy may be changed from time to time. Without your specific consent, we will not prejudice your rights under this Policy. We will publish any changes to this Policy on this page and send relevant notices. In respect of any material change, we will send more conspicuous notices (including the notice sent by us through e-mail in respect of certain services and businesses, specifying the detailed change in the personal information protection policy).

Material changes as referred to herein include but not limited to:

1. material changes in our service and business model, such as the purpose of processing personal information, the type of personal information processed, and the use of personal information;
2. material changes in structure of our ownership or organization, such as changes in ownership due to business adjustment, bankruptcy, restructure or merger;
3. changes in the principal subjects with or to whom personal information is shared, transferred or disclosed;
4. material changes in your rights to participate in processing of personal information or the way in which such rights are exercised;
5. changes in our department in charge of security of personal information, its contact methods or complaint channels; and
6. when the personal information protection impact assessment report indicates that there is a high risk.

You understand and acknowledge that, if you disagree with the updated contents, it may under some circumstances affect Link’s employment with you or affect Link to provide certain services/continue with the corporation with you or your company. Under such circumstances, you may choose to cease using relevant services, and de-register relevant accounts (if applicable), or you may contact us. If you continue to use the services or maintain your cooperative or employment relationship with us, you are deemed to have accepted the updated contents. You are advised to timely notify us of any change in your contact methods, in order to timely receive our notice.

XI. How to Contact Us

If you have any queries, opinion, or suggestions about this Policy, please contact us through the following method:

E-mail: [email protected]

Usually, we will reply within 15 working days after receiving your question, opinion or suggestion. If you are not satisfied with our reply, in particular, if you believe that our handling of personal information has damaged your legitimate rights and interests, you may file a lawsuit in the courts where we are situated or file a complaint to the competent authorities for solutions.

X. Language

This Policy is written in Chinese and English. In case of any discrepancy between the Chinese and English versions, the Chinese version shall prevail.