Privacy & Legal Notices
Privacy, Data Protection & Legal Notices
This page explains, in English and at a relatively high level of detail, how this website handles
personal data and related regulatory considerations, including under the Personal Data (Privacy) Ordinance
of Hong Kong (PDPO), the EU General Data Protection Regulation (GDPR)
and the California Consumer Privacy Act (CCPA).
For the avoidance of doubt, this website is operated from technical infrastructure located outside
Hong Kong, and is not specifically designed or marketed with Hong Kong residents as its primary target
audience, even though it provides tools to help users identify licensed estate agents in Hong Kong.
1. Nature of the Service
The sole purpose of this website is to assist users in identifying suitable licensed estate agents
in Hong Kong who may, in their own professional capacity, provide estate agency services directly to users.
The website itself does not carry out estate agency work, does not represent buyers, sellers or
landlords, and does not participate in negotiations or conclusion of any property transactions.
The website is operated on a non-profit basis. Contact details of Hong Kong licensed estate agents
made available through the matching functionality are aggregated from publicly accessible online sources
only. Should any licensed estate agent wish to have their contact details removed or corrected, they may
contact contact@pre.hk, and reasonable steps will be taken to respond
within a practicable timeframe.
2. Categories of Data Processed
Depending on how you interact with the website, the following categories of data may be processed:
- Technical and usage data – IP address, browser user agent and basic request metadata for security, abuse prevention and service operation.
- Matching signal data – free-text descriptions of preferences or requirements you choose to provide in order to improve the matching of a suitable licensed estate agent.
- Contact data – your name, telephone number and any optional description of your needs submitted via on-site forms so that a licensed estate agent can proactively contact you or send property information.
- Cookie data – limited-purpose cookies used to remember a previously matched licensed estate agent for a short period, so that the same match can be shown again without re-running the matching process unnecessarily.
3. Legal Bases and Purposes of Processing
Personal data is processed for the following purposes and, where GDPR applies, on the corresponding legal bases:
- Provision of the matching functionality – to help you identify one or more licensed estate agents in Hong Kong whose profile appears suitable for your high-level requirements (legitimate interests / performance of a quasi-contractual relationship).
- Forwarding contact requests to agents – to securely transmit your contact details and query to a licensed estate agent so that they can respond to you directly (performance of services requested by you).
- Security, fraud and abuse prevention – including the use of Cloudflare Turnstile or similar mechanisms to mitigate automated abuse, denial-of-service and misuse (legitimate interests in protecting the service and its users).
- Compliance and record keeping – maintaining minimal records that may be necessary to demonstrate compliance with applicable data protection requirements (legal obligations / legitimate interests).
4. Use of Cloudflare Turnstile and Encryption
Before certain requests (such as initiating an agent-matching sequence or submitting a contact form) are
processed, the website integrates with the Cloudflare Turnstile service. Turnstile is used to distinguish
genuine human use from automated or abusive traffic. In doing so, limited technical data is exchanged
with Cloudflare in accordance with their own privacy practices.
All form submissions and API requests are transmitted over encrypted connections using industry-standard
SSL/TLS. While no security measure can be absolutely guaranteed, reasonable technical and organisational
measures are implemented to reduce the risk of unauthorised access, disclosure or misuse of personal data.
5. Hong Kong Personal Data (Privacy) Ordinance (PDPO)
To the extent that the PDPO applies, personal data collected through the website is handled in line with
the core Data Protection Principles, including:
- Purpose and manner of collection – data is collected only for purposes that are directly related to the functions of the website (matching users with licensed estate agents and forwarding contact requests), and by lawful and fair means.
- Accuracy and retention – reasonable steps are taken to keep data accurate, and it is retained only for as long as is necessary to fulfil the purposes for which it is collected, or as required by law.
- Use – personal data is not used for new purposes that are unrelated to the original purposes notified to the user at the time of collection, unless with consent or otherwise permitted by law.
- Security – appropriate security safeguards are implemented to protect personal data from unauthorised or accidental access, processing, erasure or loss.
- Openness and access – information about personal data practices is made available through this page and, where applicable, users may request access to or correction of their personal data.
6. GDPR Information (EU / EEA Data Subjects)
For users located in the European Union or European Economic Area, the following additional information is
provided pursuant to the GDPR:
- Controller – For the purposes of the GDPR, the operator of this website acts as the data controller in relation to personal data processed via the website.
- International data transfers – Personal data may be processed on servers and by service providers located outside the EU/EEA, including in jurisdictions that may not provide the same level of data protection as under the GDPR. Appropriate safeguards or standard contractual protections may be implemented where required.
- Data subject rights – Subject to applicable conditions and limitations, you may have the rights of access, rectification, erasure, restriction of processing, objection to processing and data portability in respect of your personal data.
- Right to lodge a complaint – You may lodge a complaint with your local data protection authority if you believe that your rights under the GDPR have been infringed.
7. CCPA Information (California Residents)
For residents of California, personal information may be processed in a manner that falls within the scope of
the California Consumer Privacy Act (CCPA). In that context:
- Categories collected – identifiers (such as basic contact details you choose to provide), internet or other electronic network activity information (technical request data) and limited inferences drawn from the information you submit to enable matching.
- Business purposes – providing and improving the matching and contact-forwarding services, maintaining security and integrity, debugging and error-handling, and short-term, transient uses that are reasonably aligned with your expectations.
- Sale of personal information – personal information is not sold in the ordinary sense of the term.
- Consumer rights – you may have the right to request access to or deletion of personal information about you, and the right to non-discrimination for exercising any such rights.
8. Cookies and Short-Term Matching Memory
The website uses a limited cookie to remember the outcome of a previous licensed estate agent match for a
short period (for example, up to approximately 48 hours). This allows the same match result to be shown
again if you repeat the action within that period, which helps avoid unnecessary computational work and
associated resource usage in re-running the matching process.
The cookie is not used for behavioural advertising or cross-site tracking; it is narrowly scoped to the
matching functionality and expires automatically after a relatively short duration.
9. Contact for Data Protection Enquiries
If you have questions about how your personal data is handled, or if you wish to exercise any data protection
rights available to you under applicable law, you may contact:
Email: contact@pre.hk
Please describe your request with sufficient detail so that it can be properly understood and processed.
10. Changes to this Page
This Privacy, Data Protection & Legal Notices page may be updated from time to time to reflect changes
in the website’s practices, applicable legal requirements or guidance from regulators. The version displayed
on this page supersedes any previous versions.
Last updated: