Purpose of this notice

This notice describes how we collect and use personal data about you, in accordance with the General Data Protection Regulation (“GDPR”) and any national implementing laws, regulations and secondary legislation, as amended or updated from time to time, in Pakistan. It should be read in conjunction with our Terms and Conditions and Cookies Policy.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

About us

HK Enterprises (“HKE”, “we”, “us” and “our”) is a real estate agent registered in Islamabad. Registered office address: Office 2-A, Shad Market, Sector G-8/2, Islamabad, Pakistan.

Personal data

Personal data is any information relating to an identifiable person who can be directly or indirectly identified by reference to that information.

Special category personal data:
– personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
– data concerning health or sexual orientation
– genetic and biometric data

The kind of personal data we collect about you

The information we collect about you may include the following:
– your personal details (such as your name and contact information, including job title and email address)
– your demographic information such as post code, preferences and interests
– your billing information, transaction and payment card information
– information about how you use our website, IT, communication and other systems
– your responses to surveys, competitions and promotions
– your attendance at conferences, travel and accommodation arrangements and dietary requirements
– your photograph
– information we receive from other sources, such as publicly available information

This personal information is required to provide our services to you. If you do not provide personal information we ask for, it may delay or prevent us from providing the services to you.

How your personal data is collected

We collect most of this personal information directly from you – in person, at conferences, via our website and by digital & non-digital communication. However, we may also collect information:
– from your professional firm
– from publicly available resources
– from an individual who you have authorised on your behalf
– from cookies on our website – for more information on our use of cookies, please see our Cookies Policy

How and why we use your personal information

Under GDPR, we can only use your personal information if we have a proper reason for doing so, e.g.:
– to comply with our legal and regulatory obligations;
– for the performance of our contract with you or to take steps at your request before entering into a contract;
– for our legitimate interests or those of a third party; or
– where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The following explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for:
– to provide our services to you
– ensuring business policies are adhered to, e.g. policies covering security and internet use
– operational reasons, such as improving efficiency, training and quality control
– ensuring the confidentiality of commercially sensitive information
– statistical analysis to help us manage our business, e.g. in relation to our services, partner firms, client representatives
– updating client records/internal record keeping
– ensuring safe working practices, staff administration and assessments
– marketing our services and those of selected third parties to: clients; prospective client; third parties who we may wish to engage to provide services for the benefit of our clients.

Our reasons:
– for the performance of our contract with our clients
– for our legitimate interests or those of our clients or other third party, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
– for our legitimate interests or those of our clients or other third party, i.e. to be as efficient as we can so we can deliver the best service to you
– for our legitimate interests or those of our clients or other third party, i.e. to protect your commercially valuable information
– to comply with our legal and regulatory obligations
– for our legitimate interests or those of a third party, i.e. to promote our business to existing, prospective and former clients

We may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data.

Promotional communications

We may use your personal information to send you updates (by email) about our products and services, including our newsletter, client services information, upcoming conferences or new services.

We have a legitimate interest in processing your personal information for promotional purposes (see above ‘How and why we use your personal information’). This means we do not usually need your consent to send you promotional communications.

We will always treat your personal information with the utmost respect and never sell it to or share it with other organisations for marketing purposes.

Who we share your personal information with

We may share your personal information with:
– third parties we use to help deliver our services to you, e.g. local agents helping to arrange conferences, hotels
– other third parties we use to help us run our business, e.g. website hosts; printers
– your firm or other clients, e.g., when making referrals or recommendations

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

Where your personal information is held

Information may be held at our offices and those of our third party agencies, service providers, representatives and agents as described above.

Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: ‘Transferring your personal information out of the EEA’.

Transferring your personal information out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:
– with your and our service providers located outside the EEA;
– if you are based outside the EEA;

These transfers are subject to special rules under European and UK data protection law.

Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

How long your personal information will be kept

We will keep your personal information while you remain a client or you remain a partner, employee, officer or representative of a client firm or we are otherwise providing services to you. Thereafter, we will keep limited personal information for as long as is necessary:
– to respond to any questions, complaints or claims made by you or on your behalf;
– to enable us to check whether individuals have previously been associated with client firms;
– to contact you in connection with professional referrals;
– to show that we treated you fairly;
– to keep records required by law.

When it is no longer necessary to retain your personal information, we will delete or anonymise it.

Your rights

For further information on rights, including the circumstances in which they apply, please see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the GDPR.

Keeping your personal information secure

We have appropriate security measures to prevent personal information from being accidentally lost, or used or accessed unlawfully.

Changes to this privacy policy

We may change this privacy notice from time to time – when we do we will post those changes on this page.