EXP HONG KONG PRIVACY NOTICE

EXP Hong Kong Limited (hereinafter referred to as “eXp Hong Kong” or “Company”) is a subsidiary of eXp World Holdings, Inc, company incorporated in the state of Delaware, United States (“eXp US”). In this Privacy Notice, references to “eXp” mean eXp Hong Kong and eXp US and each of them.

This Privacy Notice describes how eXp collects and uses your personal information in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “PDPO”), any other applicable national implementing laws, regulations and secondary legislation, and any other laws applicable to the processing of your personal information to which eXp is subject, in each case as amended or updated from time to time (“Data Protection Legislation”).

eXp pledges to comply with the obligations and requirements of the PDPO. Our staff shall respect the confidentiality of all personal data collected and/ or stored and/ or used by eXp and endeavor to protect all the personal data of customers. Please read the following carefully to understand eXp’s practices
regarding the treatment of your personal data:

• when you visit or use a website or any mobile application owned or operated by eXp (the “Sites”), including opening and using an online user account, regardless of where you visit or use the Sites from; and/or
• which we otherwise receive or collect from you in the course of the provision of our services. It also describes certain privacy rights and data protection laws that may apply to you

It is important that you read this Privacy Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your data. This Privacy Notice supplements other such notices and is not intended to override them.

DATA USERS

For the purpose of the Data Protection Legislation, eXp Hong Kong and eXp US are each a “data user” of any personal information that you provide to eXp or that eXp collects from you. This means that eXp Hong Kong and eXp US are each responsible for deciding how each of them collects, uses, processes, retains and discloses your personal information. There may also be processing activities for which eXp Hong Kong and eXp US will be joint responsible parties in that they may jointly determine the purposes and means by which your personal information is processed by them.

For certain data processing activities, eXp US may act as a “data processor” for eXp Hong Kong. For the purpose of the PDPO, “data processor” means a person who processes personal data on behalf of another person, and does not process the data for any of the person’s own purposes.

It should be noted that eXp is not the data user for any personal information provided by you to eXp Hong Kong real estate brokers prior to the execution of a contract with eXp Hong Kong for representation as a buyer, seller, lessee, lessor, or as otherwise required to complete a real estate transaction, who shall remain solely responsible for the processing of your personal information in accordance with the Data Protection Legislation and their own privacy policies for all such precontract data use. The execution of a contract with eXp Hong Kong and/ or the act of visiting the Sites marks the beginning of eXp Hong Kong’s role as a data user under the PDPO and the Data Protection Legislation.

WHAT PERSONAL INFORMATION IS COLLECTED FROM YOU?

For the purpose of provision of real estate agency services by eXp, we will only collect personal information about you that is required to serve the purpose or purposes for which it was collected. The type of personal information collected will depend upon whether you are an eXp customer, a prospective customer, or a site visitor, the purpose for which the data is required, and eXp’s legal and regulatory obligations. eXp may collect your personal information as an operator on behalf of an agent. Your personal information may be collected in a number of ways, including when you communicate or register with eXp through the Sites, or by telephone, post, or e-mail.

Generally, eXp will not process your personal information without your knowledge or consent, save as to for the following purposes of (i) prevention or detection of crime; (ii) apprehension, prosecution or detention of offenders; (iii) prevention, preclusion or remedying of unlawful or seriously improper conduct, or dishonesty or malpractice; and (iv) prevention or preclusion of significant financial loss arising from (a) any imprudent business practices or activities; or (b) unlawful or seriously improper conduct, or dishonesty or malpractice, where the requirement of consent is exempted.

If you are a user of the Sites, then the information that eXp collects (including when you interact with features of the Sites or request information) may include the following:

• your name and contact details (i.e., corresponding/ residential address, home and/or mobile phone numbers, email address);
• your username and password;
• anything you download from the Sites;
• any information that you input into the Sites

Cookies

eXp uses “cookies” on the Sites to learn how you interact with our content and to improve your experience when visiting the Sites.

A cookie is a small file of letters and numbers that is placed on your computer’s hard drive when you visit certain websites. Cookies may be used, for example, to identify whether you have visited a website before or if you are a new visitor and to help identify website features in which you may have the greatest interest. Cookies may enhance your online experience by saving your preferences while you are visiting a particular site.

eXp does not use, and has no intention to use the visitor data to personally identify anyone. Most web browsers are initially set up to accept cookies. You can choose to refuse cookies by turning them off in your browser and/or deleting them from your hard drive. you have a choice not to accept the cookies and continue to browse the Sites, but if you do, certain functionality may not be available. For further details on how eXp uses cookies, please see our separate Cookie Policy. 

WHY IS YOUR PERSONAL INFORMATION COLLECTED?

Unless otherwise consented by you in advance, or as may be permitted or required by applicable law, we will only use and disclose your personal information to fulfil the purposes for which it was collected and in accordance with this Privacy Notice.

For the purpose of complying with the laws of Hong Kong, including but not limited to the Estate Agents Ordinance (Cap. 511 of the laws of Hong Kong) and its subsidiary legislations and regulations, in the verification of the identity of both the vendor/ landlord and the purchaser/ tenant, the preventing of money laundering and in order to market properties and provide services or market information, perform registration and administration functions of eXp, its affiliates, subsidiaries or associated
companies, your personal data will be collected upon your:

(a) signing an estate agency agreement to appoint us as your estate agent;
(b) signing a provisional sale and purchase agreement/ tenancy agreement;
(c) purchasing firsthand property;
(d) applying customer due diligence;
(e) contacting us for enquiry or complaint;
(f) participating in marketing and promotion activities, competitions, prize draws through us;
(g) using our intermediary service;
(h) enquiry about becoming an eXp Hong Kong estate agent;
(i) applying and onboarding with eXp Hong Kong to be an estate agent;
(j) using or visit our Sites.

If you refuse to provide the personal data, we have discretion not to provide services to you for the avoidance of breaching the relevant laws and regulations.

eXp may process your personal information for certain additional purposes with your consent, and in these limited circumstances where your consent is required for the processing of your personal information then eXp will obtain your separate consent at that time and you will also have the right to withdraw your consent to processing for these specific purposes (see ‘Right to Withdraw Consent’ section below).

Please note that eXp may process your personal information for more than one lawful ground depending on the specific purpose for which it is using your data.

All personal information collected is processed in compliance with relevant Data Protection Legislation.

Purpose and Lawful Basis for Processing

When processing your personal information, the purposes for which and the lawful bases upon which your personal information is processed include the following, to the extent that they apply to you:

• to perform customer services to fulfill eXp’s contractual obligations toward you, and on the basis of its legitimate interests, or your legitimate interests, to provide the best customer service we can;
• to support eXp’s business processes including information technology, electronic communications and electronic documents storage, management and transmissions, business creation and development, statistical and researches, to fulfil its contractual obligations toward you, or, if not applicable, on the basis of its legitimate interests to provide the best customer service it can, to support its business operations, administration, IT services, and network security, and to prevent fraud;
• to safeguard your personal information and eXp’s IT system with appropriate security, on the basis of your and its legitimate interest in such security;
• to exchange information, conduct due diligence, and answer your initial questions, to take steps required to enter into a contract with you, or for the purposes of its legitimate interests to protect its legal rights and a third party’s rights, or, if not applicable, on the basis of your consent;
• to keep you up-to-date with news that may be of interest to you, on the basis of your consent;
• to present eXp websites and online content in the best possible way for you and on your computer, on the basis of its legitimate interests to keep its websites updated and relevant, to develop our outreach and business operations, and to develop marketing strategy;
• for business transactions such as a merger, acquisition by another company, or sale of all or a portion of our assets on the basis of our legitimate interests to sell or expand our business operations; and/or
• to comply with legal and regulatory requirements applicable to us (including the need to prevent and combat money laundering).

Where the processing of your personal information is based on your consent only, you have the right to withdraw this consent at any time. eXp will then erase your personal information or otherwise put it beyond use and will stop processing it.

If you fail to provide certain information when requested, eXp may be unable to perform a contract entered into with you, or may be prevented from complying with our legal obligations.

eXp will only use your personal information for the purposes for which it collected it, pursuant to this Privacy Notice, unless it reasonably considers it needs to use it for another reason, and the reason is compatible with the original purpose. If eXp needs to use your personal information for an unrelated purpose, eXp will notify you, and will explain the legal basis which allows it to do so.

Marketing

eXp intends to use the name, telephone number, fax number, e-mail address and correspondence address of customers and prospective real estate professionals for direct marketing of the real estate agency services provided by eXp.

Even if you have given consent to eXp on the use and/ or transfer to the third parties of your personal data for direct marketing, you may still have the right, at any time, without charge, to request eXp to cease to use and/ or transfer your personal data to third parties for direct marketing.

You may follow the unsubscribe links on any marketing message sent to you or by emailing [email protected] at any time. eXp will cease using your personal data for such purpose.

HOW LONG IS YOUR DATA HELD?

eXp will retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, legitimate administrative or operational purposes, and any reporting requirements.

Personal data provided by you are retained until the completion of the purpose for which such data were collected and will not exceed 7 years in general, or such longer period as prescribed by applicable laws, rules and regulations as well as guidelines, practice circulars, code of ethics and practice directions issued by the regulatory authorities and applicable to eXp.

When it is no longer necessary to retain your personal information, eXp will securely delete or, in some  circumstances, anonymise your personal information (so that it can no longer be associated with you and is no longer treated as personal information), in which case eXp may use this information indefinitely without further notice to you.

If you request that eXp stop sending you marketing materials, it will keep a record of your contact details and appropriate information to enable it to comply with your request not to be contacted again.

All practicable steps will be taken to ensure that personal data is not kept longer than is necessary or permitted, under, and is otherwise kept in compliance with, the Data Protection Legislation.

SHARING YOUR PERSONAL INFORMATION

eXp intends to transfer the name and contact details (including telephone number, fax number, email and/ or corresponding address) of the customers to the third parties for use in direct marketing of the following services and eXp may derive gain as such:

(a) real estate agency.

Personal data of customers held by eXp, may be transferred to the following parties:

(a) co-operative estate agents;
(b) service providers of eXp offering rewards and/ or promotions;
(c) solicitors, surveyors, and other professionals to facilitate property transactions;
(d) government agencies, regulatory bodies and/ or other lawful authorities; and/ or
(e) courts, tribunals and/ or parties to the legal proceedings;

Provision of personal data is on a voluntary basis. It is necessary for eXp to collect your information for providing you the various services and information offered on the website of eXp. However, failure to supply personal data indicated as “required” item may result in eXp being unable to provide any or all of the services to you.

Purpose and Lawful Basis for Processing- Categories of Recipients

Your personal information may be transferred and/or disclosed to any of the following categories of recipients for purposes specified under the above heading of “Purpose and Lawful Basis for Processing”:

• Software as a service providers that enable our provision of the real estate services or website functionality like viewing real estate listings;
• Estate agents that are affiliated with eXp;
• Estate agents that are not affiliated with eXp if they need to receive your personal information to complete a transaction that you have authorized;
• Lenders, if you have expressed an interest in receiving details about their services;
• Law enforcement and government agencies; and/or
• eXp affiliate entities that need access to your personal information as part of the shared services model that is in place between our local entity in Hong Kong and our global affiliates, including eXp Realty, LLC in the United States.

eXp has entered into contracts with its data processors in terms of data storage and handling. Data processors are also obliged to notify its data user and the Privacy Commissioner in case of any data breaches without undue delay.

All data processors are contractually required to take appropriate security measures to protect your personal information and are not allowed to use your personal information for their own purposes without obtaining your consent directly. eXp only permits them to process your personal information for specified purposes and in accordance with its instructions.

eXp reserves the right to transfer your personal information in the event of a sale or transfer of all or a portion of its business or assets. Should such a sale or transfer occur, the transferee will be required to use your personal information in a manner consistent with this Privacy Notice and the applicable legal framework.

International transfers of your personal information

eXp US and eXp Hong Kong, along with their global affiliate organizations share infrastructure, personnel and service providers. eXp US also provides certain customer and support services to eXp Hong Kong and for this purpose eXp US will receive or have access to and will process your personal information. Whenever eXp Hong Kong transfers your personal information outside of Hong Kong to process it for the original purposes of collection, it will continue to adhere to the requirements under
the PDPO and will ensure the overseas data processor will comply with these requirements.

If eXp Hong Kong otherwise wishes to transfer your personal information outside of Hong Kong, then it will separately obtain your written consent to that transfer.

Please contact eXp if you want further information on the specific mechanisms used when transferring any of your personal information out of Hong Kong, which shall be in compliance with the requirements of the PDPO standard contractual clauses.

DATA SECURITY

eXp places great importance on the security of all personal information of its customers and other data subjects. eXp has put in place appropriate security measures designed to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered, or disclosed.

In addition, access to your personal information is limited by eXp to those persons who have a business need to know. They will only process your personal information under eXp’s instructions, and they are subject to a duty of confidentiality.

All your personal data will be restricted for access by eXp’s staff who need to contact you to provide service to you or in reasonable need. 

eXp’s electronic security system is designed on the account of the PDPO’s requirements and your personal information will be maintained securely in our system.

eXp has put in place procedures to deal with any suspected data security breach and will notify you and the Office of the Privacy Commissioner for Personal Data of Hong Kong in the event of a suspected breach where it is legally required to do so.

YOUR RIGHTS IN RELATION TO YOUR PERSONAL INFORMATION

Depending on the facts and circumstances related to the personal information collected or obtained about you – including, for example, the nature of the information processed or where you are located or reside – you may have rights regarding the personal information held about you under relevant Data Protection Legislation. These may include the right to submit a data access request (“DAR”) about, or access to, the personal information held, and rights to complain about how your personal information is handled. eXp is committed to honouring your legal rights whilst ensuring that such rights are exercised in accordance with eXp’s own legal and ethical obligations. Subject to further amendment of Data Protection Legislation, we will comply with your request within 40 calendar days after receipt of your DAR in written Chinese or English.

Right to access

You may request whether eXp holds personal information about you and request from us, free of charge depending on the nature and frequency of your requests, a record or a description of your personal information including information about the identity of all third parties, or categories of third parties, who have, or have had access to the information under Data Protection Legislation.

Right to correction and deletion.

Under the PDPO, you have the right to access and/ or correct your personal data. You may request from us, subject to our right to charge you a reasonable fee depending on the nature or frequency of your requests, the correction or deletion of your personal information where it is inaccurate, irrelevant, excessive, out of date, incomplete, misleading or obtained unlawfully. You may also request the destruction or deletion of a record of personal information that eXp is no longer authorised to retain.

Right to withdraw consent

We will obtain your voluntary and explicit consent prior to or when collecting, using, processing, retaining or disclosing your personal data for any purpose not described in this Privacy Notice, or for a purpose that was not identified to you nor reasonably expected at the time of collection, unless we are required or permitted by the Data Protection Legislation not to obtain your consent.

In the limited circumstances where you may have provided your consent to the collection, processing, and transfer of your personal information for a specific purpose – for example, in relation to direct marketing you have indicated you would like to receive from eXp – you have the right to withdraw your consent for that specific processing.

You can exercise this option at any time by contacting eXp either by post: eXp Realty, ATTN: Legal Department, 2219 Rimland Dr., Suite 301, Bellingham, WA 98226, by filling out our data subject request form, or by email: [email protected]. Once eXp has received notification that you have withdrawn your consent, eXp will no longer process your information for the purpose or purposes you originally agreed to, unless eXp has another legitimate basis for doing so in law.

If you would like to unsubscribe from any electronic marketing communication you can also click on the ‘unsubscribe’ button at the bottom of the relevant communication. It may take up to 10 days for this to take place, no fees will be charged for an opt-out request.

Right to complain

eXp hopes that we can resolve any query or concern you raise about eXp’s use of your personal information. However, if you believe that your personal information is not being lawfully processed by eXp under applicable Data Protection Legislation, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data of Hong Kong (the “PCPD”), the current contact details are listed below:

• By Post/ In Person: Room 1303, 13/F, Sunlight Tower, 248 Queen’s Road East, Wanchai, Hong Kong (Monday to Friday: 8:45 a.m. to 12:45 p.m. & 1:50 p.m. to 5:40 p.m.)
• By Fax: 2877 7026
• By Email: [email protected]

CONTACT DETAILS

If you have any questions about our privacy notice, or any other matter, please feel free to contact us. You can reach us in the following way:

Contact: eXp Realty (Attn: Privacy Department)

Mail:

EXP Hong Kong Limited
Room 709
8 Queen’s Road East
Wan Chai, Hong Kong
with a copy by email to [email protected].

AMENDMENTS TO THIS PRIVACY NOTICE

eXp may update this Privacy Notice from time to time, and reserves the right to do so at any time to comply with applicable Data Protection Legislation. If we make material changes to the way that we collect, use or share personal information that you have provided, we will post the revised Privacy Notice on the Sites.

Privacy Notice last updated: July 18, 2025