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Privacy Policy

This Statement sets out the policy of TOP CAPITAL GROUP in connection with the collection and use of your personal data through this Website.

General Statement of Principle

TCG respects the privacy of the users of this Website, and complies with its obligations under the Personal Data (Privacy) Ordinance (Cap. 486), the governing legislation in Hong Kong.

Kinds of Personal Data Held

There are two broad categories of personal data held by TCG. They are personal data contained in:

  • Customer files and records, which include records containing information supplied by visitors to our Website or otherwise voluntarily supplied to TCG by clients or potential clients; and
  • Other records, which include administration and operational files and personal data provided to TCG in respect of promotional, operational and administrative activities (including the personal data of service suppliers to TCG).

Purpose of Holding Your Personal Data

TCG holds your personal data for the following purposes:

  • Customer files and records are kept for the purpose of facilitating the provision of information to you about TCG, including the range of property services and related activities offered to clients of TCG; and
  • Other records are kept for various purposes which vary according to the nature of the record, such as administration of office functions and activities, promotional and marketing activities, selection of service suppliers, and so forth.

How We Collect Personal Data

While browsing an internet site, collection of personal data without a user’s express consent will occur. The services provided on this Website:

  • do not use IP address (Internet Protocol Addresses) to collect information. However, IP addresses are stored in navigation information;
  • use navigation data as aggregate data for statistical purposes only;
  • use cookies to improve browsing, but not for statistical purposes. You may disable the use of cookies, but this may impair your ability to browse this web site; and
  • do not use internet tags.

This Website applies the following policy to the active collection of personal data:

  • E-Mail: Data received by e-mails sent to the Website are used to reply to requests in those e-mails and are then stored for statistical purposes.
  • Mailing List: Names are included in mailing lists only if the express consent of the recipient has been obtained.
  • Registration: Data received upon completion of on-line forms are used to reply to requests for services set out in those on-line forms.

Personal data is also collected by TCG when it receives forms, applications, correspondence and other documents from its clients and other individuals.

How We Use Your Personal Data

TCG may use your personal data to:

  1. provide you with information about TCG including the range of property services and related activities offered to clients of TCG;
  2. liaise with property agencies and vendors and other service providers to TCG (including introducers, lawyers, etc.) in connection with property services provided to you;
  3.  verify your identity;
  4. confirm payment details with banks or credit card companies;
  5. send you, upon your prior consent, information about other services provided by TCG;
  6. liaise with government and regulatory authorities as required by law;
  7. protect and defend the rights of TCG or other third parties, or to enforce the terms and conditions that apply to use of this site; and conduct other activities of TCG required or permitted by law.

Who Can We Disclose Your Personal Data To?

Your personal data may be disclosed by TCG to:

  1. other companies owned or operated by TCG;
  2. professional service providers to TCG (such as agents, legal advisers, financial advisers, and other professionals);
  3. service providers to TCG in connection with the maintenance and operation of this Website;
  4. government and regulatory authorities as required by law; and
  5. other persons who are under a duty of confidentiality to TCG, or to lawful successors and assigns of TCG.

Access to Your Personal Data

You have a right to:

  1. request access to your personal data;
  2. correct any errors in your personal data;
  3. upon payment of a reasonable fee, obtain a copy of your personal data; and
  4. upon written request, withdraw your consent to the use by TCG of your personal data.

However, if you withdraw your consent, then TCG may not be able to provide property services to you or to contact you.

Data Protection Officer

If you have queries concerning your personal data (including requesting access to, or correcting the details of, your personal data), you should contact:

The Data Privacy Officer
Top Capital Group Limited
26th Floor, 42-46 Gloucester Road
Wan Chai, Hong Kong

Governing Law and Jurisdiction

The terms and conditions of use of the Website shall be governed by and construed in accordance with the laws of Hong Kong and TCG and the Client irrevocably submit to the exclusive jurisdiction of the Courts in Hong Kong and waive any objection to any legal action or proceedings in such Courts on the grounds of venue or on the grounds that the proceedings have been brought in an inconvenient forum or on any other grounds whatsoever.


TCG is the trading name of Top Capital Group Limited.

You acknowledge that:

  1. (i) the information contained in this Website, TCG emails and such other material issued in connection therewith (the “Content”) are for information purposes;
  2. the Content is provided on an “as is” basis and by way of a summary and we do not guarantee the accuracy, completeness, or timeliness of the Content;
  3. the Content may be subject to the terms and conditions of other agreements to which we are a party;
  4. the Content does not constitute a solicitation or offer to invest in securities or collective investment schemes or other financial or investment concerns;
  5. the Content should not be regarded as advice on securities or collective investment schemes or other financial or investment concerns;
  6. the Content has not been authorised or approved by the Securities and Futures Commission of Hong Kong or any other regulatory body of competent authority whether in Hong Kong or elsewhere;
  7. the property market is volatile and illiquid and property prices and rental yields may fluctuate widely or be affected by a broad range of risk factors;
  8. all plans and specifications in the Content are intended as a guide only and are subject to such variations, modifications and amendments as may be required by the relevant authorities or the relevant consultants or architects;
  9. all renderings and illustrations in the Content are artists’ impressions only and all measurements are approximate subject to final survey and confirmation; and
  10. the Content is not intended for use by, or distribution to, any person or entity in any jurisdiction or country where such use or distribution would be contrary to law or regulation.

Accordingly, you assume all responsibility and risk for reliance upon and the use of the Content and, we, our agents, directors, officers, employees, representatives, successors, and assigns expressly disclaim any and all responsibility for any direct or consequential loss or damage of any kind whatsoever arising directly or indirectly from:

(i) the use of the Content
(ii) reliance on any information contained in the Content
(iii) any error, omission or inaccuracy in any such information including, without limitation, financial data, forecasts, analysis and trends, or
(iv) any action or non-performance resulting from the foregoing.

This exclusion clause shall take effect to the fullest extent permitted by applicable laws.

We and our representatives only work in relation to real estate located outside Hong Kong.

Neither TCG nor its representatives is licensed under the Estate Agents Ordinance (Cap. 511 of the Laws of Hong Kong) to deal with Hong Kong real estate (nor are we required to be so licensed).

Neither TCG nor its representatives engages in regulated activities in Hong Kong such as dealing or advising on securities or providing asset management services. Therefore, neither TCG nor its representatives are licensed under the Securities and Futures Ordinance (Cap. 571 of the Laws of Hong Kong).

Professional Advice

Any statement contained in the Content is made on a general basis and we have not given any consideration to nor have we made any investigation of the investment objective, financial situation or particular need of any user or reader, any specific person or group of persons.

You are advised to make your own assessment of the relevance, accuracy and adequacy of the information contained in the Content. You should obtain independent professional advice before making an investment decision in relation to the Content. Investigations as may be necessary or appropriate for the purpose of such assessment including the investment risks involved. You should consult an appropriate professional advisor for legal, tax, accounting, or investment advice specific to your situation, as to whether any governmental or other consents are required or if any formalities should be observed for the purposes of making such investments as are mentioned in the Content. If you are unsure about the meaning of any of the information contained in the Content, please consult your financial or other professional advisor.

Third Party References

References to third party publications are provided for your information only. The content of these publications are issued by third parties. As such, we are not responsible for the accuracy of information contained in those publications, nor shall we be held liable for any loss or damage arising from or related to their use.