Legal, Privacy and Data Protection Notice

1. Nature of the Service and Regulatory Position

The website operates as an informational and matching interface which assists users in identifying one or more licensed estate agents located in Hong Kong who may be able to provide professional estate agency services to them. The website itself does not provide estate agency services, does not enter into any estate agency agreements with users, and does not act as a party to any transaction for the disposition, acquisition, leasing or mortgaging of real property.

For the avoidance of doubt, any estate agency services, regulated advice or transactional work are provided solely and independently by the individual licensed estate agents or firms with whom users may subsequently engage. The operator of this website does not purport to be, and should not be construed as, a licensed estate agent, property agent or real estate broker in any jurisdiction, including but not limited to Hong Kong.

The technical infrastructure supporting this website is hosted outside the Hong Kong Special Administrative Region. While it may contain information about licensed estate agents in Hong Kong for the convenience of users who are considering engaging such agents, the website is not primarily directed at or targeted towards Hong Kong residents as a specific audience class, and is intended to support a geographically diverse user base that may include individuals outside Hong Kong who are interested in Hong Kong property matters.

Contact information concerning Hong Kong licensed estate agents displayed or used for matching on this website is compiled from publicly available sources, such as official registers and information that agents or their firms have themselves made accessible on the open internet. The website is maintained on a non‑profit basis, and there is no intention to monetise, resell or otherwise commercially exploit such publicly sourced contact details. Any licensed estate agent or firm who, for any reason, wishes to have their contact details amended or removed from the website’s internal listings may write to contact@pre.hk; reasonable efforts will be made to honour such requests in a timely manner.

2. Use of Artificial Intelligence and OpenAI Services

The matching flow made available on this website may rely on artificial‑intelligence‑driven components and natural language processing, including models or APIs provided by OpenAI or similar providers. These components are used to interpret user‑supplied descriptions, to infer likely areas of interest and to suggest a suitable subset of licensed estate agents that may be relevant to the user’s high‑level criteria.

The AI‑assisted matching is heuristic in nature and does not constitute regulated advice, a recommendation in the investment sense, or a representation that any particular agent is objectively “best” or “appropriate” for a given user. Rather, it is a convenience feature designed to reduce search frictions. Users remain responsible for independently assessing the suitability, competence and regulatory status of any agent they ultimately choose to instruct.

For transparency, the operator of this website notes that AI‑model usage typically incurs computational and token‑based costs. The system is therefore designed to re‑use existing short‑term matching results for a limited period (for example, by making use of browser cookies that retain non‑sensitive matching output for up to forty‑eight hours) rather than repetitively triggering new AI calls on every button press. This behaviour is intended to conserve resources while maintaining a consistent user experience.

3. Personal Data (Privacy) Ordinance (Cap. 486) – Hong Kong (“PDPO”)

To the extent that activities conducted through this website fall within the territorial and material scope of the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong, the operator seeks to align its practices with the Data Protection Principles (“DPPs”) contained in Schedule 1 of the PDPO on a good‑faith and proportional basis.

In broad terms:

• DPP1 – Purpose and Manner of Collection: Personal data are collected by fair and lawful means, with reference to clearly defined purposes, such as (i) AI‑assisted matching of users with licensed estate agents and (ii) secure forwarding of user contact details and enquiries to such agents at the request of the user.
• DPP2 – Accuracy and Retention: Only such data as are reasonably necessary for the above purposes are requested, and reasonable steps are taken to ensure that those data are accurate based on the user’s own submissions. Non‑essential personal data are not retained for longer than is necessary for the stated purposes, and short‑term browser storage mechanisms (for example, certain cookies) are used in a limited and time‑bound fashion.
• DPP3 – Use of Personal Data: Personal data are used solely for the purposes for which they were collected or for directly related purposes that a data subject might reasonably expect in the context of a property enquiry. Personal data are not sold, licensed or otherwise provided to unrelated third parties for their own marketing purposes.
• DPP4 – Security of Personal Data: Appropriate technical and organisational safeguards are implemented with a view to protecting personal data against unauthorised or accidental access, processing, erasure, loss or use. These safeguards include transport encryption (e.g. SSL/TLS) for data in transit and access controls for any limited operational handling.
• DPP5 – Information to be Generally Available: This Legal, Privacy and Data Protection Notice is intended, among other things, to serve as a readily accessible statement of the kinds of personal data held, the purposes of use and the policies and practices in respect of personal data.
• DPP6 – Access and Correction: Data subjects who believe that the website operator holds personal data relating to them may submit a request for access or correction by writing to contact@pre.hk. Reasonable steps will be taken to respond in accordance with applicable law, subject to any lawful grounds for refusal.

Given the cross‑border nature of modern hosting environments and AI services, it is possible that personal data provided by users may be processed on servers located outside Hong Kong. Where this occurs, the operator seeks to ensure that data are treated with a level of care that is broadly consistent with the protections described above, recognising that data‑protection laws vary by jurisdiction.

4. General Data Protection Regulation (“GDPR”)

To the extent that the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and/or the United Kingdom General Data Protection Regulation (“UK GDPR”) applies, the following additional information is provided for individuals located in the European Economic Area (“EEA”) or the United Kingdom.

4.1 Roles and Legal Bases

In relation to the operation of this website and the AI‑assisted matching interface, the website operator acts, in general, as a data controller with respect to the limited categories of personal data that users actively choose to submit (e.g. contact details and property‑related requirements), and as a joint controller or independent controller in respect of technical usage data collected for security or operational purposes.

The primary legal bases relied upon for processing are:

• Article 6(1)(b) GDPR – Contractual necessity, where processing is necessary to take steps at the request of the data subject prior to entering into a contract with an estate agent (for example, passing on contact details so that an agent can respond to an enquiry).
• Article 6(1)(f) GDPR – Legitimate interests, where processing is necessary for the legitimate interests pursued by the website operator, such as operating and improving the matching service, ensuring the security of the service, and preventing abusive or automated misuse of interactive forms.
• Article 6(1)(a) GDPR – Consent, where certain optional analytics or AI‑processing operations are only performed on the basis of the user’s informed and specific consent, which may be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.

4.2 Data Subject Rights

Subject to applicable exemptions, individuals within the scope of the GDPR/UK GDPR may have the right to request access to, rectification or erasure of, or restriction of processing of their personal data; to object to certain processing; and to data portability, in each case under the conditions and limitations set out in the relevant legislation. Requests may be directed to contact@pre.hk.

Individuals also have the right to lodge a complaint with a competent supervisory authority, in particular in the Member State or jurisdiction of their habitual residence, place of work or place of the alleged infringement, if they consider that the processing of personal data relating to them infringes the GDPR or UK GDPR.

5. California Consumer Privacy Act (“CCPA”) and Similar Regimes

While the website is not specifically targeted at residents of any particular U.S. state, including California, and while the volume of personal information processed is limited, the operator nonetheless endeavours, where reasonably practicable, to structure its practices in a manner that is compatible with the transparency and choice‑oriented framework reflected in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) and analogous state‑level privacy statutes.

In particular:

• Personal information is not “sold” or “shared” in the sense given to those terms under the CCPA; third‑party access to personal information is limited to service providers and professional recipients (such as licensed estate agents) who require such information in order to respond to user‑initiated enquiries.
• Users may contact contact@pre.hk to request access to, or deletion of, personal information about them, subject to applicable legal limitations and the need to maintain certain records for security, anti‑fraud or compliance purposes.
• Non‑discrimination: to the extent CCPA applies, users will not be discriminated against for exercising any privacy rights conferred by applicable law.

6. Cookies, Short‑Term Storage and Technical Logs

The website may make use of strictly necessary and functional cookies or similar technologies in order to maintain session integrity, prevent automated abuse (for example, by integrating Cloudflare Turnstile or similar anti‑abuse mechanisms), and temporarily remember the outcome of AI‑assisted matching so that identical requests within a short window do not trigger redundant processing.

Where cookies are used to store non‑sensitive AI‑matching output (such as a previously suggested agent’s name and telephone number), such storage is designed to expire automatically after a defined period (for example, around forty‑eight hours) and is not intended to create a persistent behavioural profile of the user. Users can generally manage or delete cookies via their browser settings.

Technical logs, including IP address, browser information and timestamps, may be recorded by hosting or security providers for the legitimate purposes of ensuring service reliability, diagnosing errors, detecting malicious traffic and complying with legal obligations. These logs are typically retained only for as long as is necessary to achieve those purposes.

7. Data Security and Transmission

Communications between your browser and the website are intended to be protected by industry‑standard transport encryption (such as SSL/TLS), as indicated by the presence of “https” in the address bar and a lock symbol in modern browsers. When you submit contact forms requesting that a licensed estate agent reach out to you or provide property information, the details you choose to supply are transmitted using such encrypted channels to the relevant operational recipient.

The website is not designed to permanently store end‑user contact details supplied via these forms. Instead, such details are transmitted through controlled channels (which may include secure APIs or messaging interfaces) to the relevant licensed estate agent or coordination endpoint, after which only limited operational traces or logs may remain for security and troubleshooting purposes. Users are encouraged not to include unnecessary or overly sensitive personal information in free‑text fields.

8. Changes to this Notice

This Legal, Privacy and Data Protection Notice may be updated from time to time to reflect changes in applicable law, regulatory expectations, technological developments or the functionality of the website. The version published on this page at any given time should be regarded as the prevailing version. Material changes that significantly affect the way personal data are handled may, where appropriate, be highlighted through an on‑site notice or similar mechanism.