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Privacy Policy and Personal Data Collection
Statement
These Statements are, except where separate and distinctive statements
are provided, applicable to the Hutchison Global Communications group
of companies, including Hutchison Global Communications Limited and Hutchison
Multimedia Services Limited. Accordingly, references to "we", "us", or
"our company" etc. mean , as the case may be, the relevant company within
the Hutchison Global Communications group of companies.
I. Privacy Policy Statement
Our Pledge
We are committed to safeguarding the privacy of individuals with respect
to personal data. We therefore make sure that our policies and practices
in relation to the collection, use, retention, transfer and access of
personal data comply with the requirements of the Personal Data (Privacy)
Ordinance (Chapter 486) under the laws of Hong Kong.
Types of Personally Identifiable Information
Collected At times, you may be required to give your personally identifiable
information including, but not limited to, your name, gender, age, identity
document number, telephone number, fax number, home address, email address,
credit card information, bank account number, education level, occupation,
household income, interests and favourite activities etc.. Refusal to
provide such information may render us unable to handle any application
or request you are making, or may deny you of access to certain parts
of our web site, or may otherwise defeat the objectives of your visit.
If you are under the age of 18, consent from your parent or guardian is
required before you give us any personally identifiable information.
Use of Personally Identifiable Information Collected
Specific purposes for which your personally identifiable information may
be used are set out in our Personal Data Collection Statement set out
in II below (particularly those contained in points (i) through to (vi)
in the third paragraph of II below).
Direct Marketing
If you have once given us your personally identifiable information, you
may receive from us or from our affiliated companies from time to time
telephone calls, email and direct mailings containing promotional materials.
If you do not want to receive them, please write to our Data Protection
Officer. You may be asked to indicate your preference before signing up
for any of our paid services.
Retention of the Information
If you are our paid customer, your personally identifiable information
which you have given us via application form, Internet or other means,
during the subscription period will be retained for a reasonable period
after termination of your subscription.
Access to and Correction of Information
If you want to access to and/or correct your personally identifiable information
which you have given us via application form, Internet or other means,
you may write to our Data Protection Officer. We may charge you a reasonable
fee for each successful access current from time to time. However, such
fee will be waived if the access is necessary to make a genuine and reasonable
correction.
Disclosure of Information
Normally, we may share your information with, or transfer it to, Hutchison
Whampoa Limited, its subsidiaries and affiliated companies. For details,
please refer to our Personal Data Collection Statement set out in II below.
If you do not want to have your information disclosed to any third party,
please write to our Data Protection Officer.
Security
We use various encryption techniques to transmit via the Internet your
Personal Data, which can only be accessed by our authorised personnel.
Given the nature of the Internet, we cannot guarantee that the transmission
is 100% secure. Please, however, refer to our Security Statement for details
on the steps that we have taken to ensure that any Personal Data collected
by us via our websites is safe and secure from third party interference.
Use of Cookies
Your visiting our web site(s), may trigger our use of cookies. For your
information, Cookies are small computer files that can be stored in web
surfers' computers for the purposes of obtaining configuration information
and analysing web surfers' viewing habits. They can save you from registering
again when re-visiting a web site and are commonly used to track your
preferences in relation to the subject matter of the web site. You may
refuse to accept Cookies (by modifying the relevant Internet options or
browsing preferences of your computer system), but to do so you may not
be able to utilize or activate certain available functions in our web
sites.
On-line Services
We may have on-line stores or service providers hosted in our web site
which are operated by third party merchants. If you want to use or order
any services or products from any of them, please note that any information
you provide, once transferred to the relevant merchant, is beyond our
control and thus outside the scope of protection afforded by us.
Enquiries
Should you have any enquiries concerning our Privacy Policy Statement,
please feel free to contact our Data Protection Officer. The address is
as follows:
Data Protection Officer
1 9/F Two Harbourfront
22 Tak Fung Street Hunghom,
Kowloon Hong Kong
II. Personal Data Collection Statement
a customer of our company, or a visitor or user of our web site(s), it
may be necessary for you to provide us with your personal information
("Personal Data") when you apply to us and/or continue to subscribe with
us for a service and/or product ("Services"). If your Personal Data is
incomplete or incorrect, we may not be able to provide or continue to
provide the Services to you. We shall keep your Personal Data confidential
at all times. Our policies and practices with respect to the collection,
use, retention, disclosure, transfer, security and access of Personal
Data will be in accordance with the Personal Data (Privacy) Ordinance
("Ordinance") and are as set out in this Statement. You agree that your
Personal Data provided by you to us may be used and retained by us for
the following purposes and for other purposes as shall be agreed between
you and us or required by law from time to time:
- i. provisioning of the Services;
- ii. marketing of goods and/or services by us, our agents or our subsidiaries,
in relation to the Services;
- iii. processing of any benefits to you arising out of or in connection
with the Services;
- iv. analyzing, verifying and/or checking of your credit, payment and/or
status in relation to the provision of the Services;
- v. processing of any payment instructions, direct debit facilities
and/or credit facilities requested by you;
- vi. enabling the daily operation of your account and/or the collection
of amounts outstanding in your account in relation to the Services;
and
- vii. enabling us to comply with our obligations to interconnect or
other industry practices.
You further agree that we may disclose and transfer (whether in Hong
Kong or abroad) to our agents, contractors, any telecommunications operators,
any third party service providers, any third party collection agencies,
any credit reference agencies, any security agencies, any credit providers,
banks, financial institutions, our professional advisers, any other persons
under a duty of confidentiality to us and any of our actual or proposed
assignees or transferees of our rights with respect to you to use, disclose,
hold, process, retain or transfer such Personal Data for the purposes
mentioned above.
In addition, in accordance with your agreement with us or consent given
to us (as the case may be), we may disclose and transfer your Personal
Data (whether in Hong Kong or abroad) to any company within, Hutchison
Whampoa Limited, Cheung Kong (Holdings) Limited, any of their subsidiaries
and any company in which the same has a direct or indirect interest or
with which it is in joint venture or co-operation or their respective
successors and assigns ("Hutchison Group") and to include that Personal
Data in one or more databases held by us or the Hutchison Group (which
may contain other information collected by us or the Hutchison Group)
for the purposes mentioned above, the carrying out of market research,
credit assessments, marketing of goods and/or services by us and/or the
Hutchison Group and for the performance of procedures for comparing Personal
Data with other information supplied by you to us and/or the Hutchison
Group for such purposes and for other purposes as shall be agreed between
you and us or required by law from time to time. If you do not wish to
receive marketing information from us with respect to goods and/or services
not related to or in connection with the Services, or for us to disclose,
transfer or use your Personal Data for the purposes as set out in this
paragraph, please write to us at the address above
quoting your name, address and account number(s).
Under and in accordance with the Ordinance, you have the right to:
- i. check whether we hold any of your Personal Data;
- ii. access your Personal Data held by us;
- iii. require us to correct any Personal Data which is inaccurate;
and
- iv. ascertain our policies and practices (from time to time) in relation
to Personal Data and the types of Personal Data held by us.
In accordance with the Ordinance, we have the right to charge a reasonable
fee for the processing of any Personal Data access request. All requests
for access to or correction of Personal Data or information regarding
policies and practices and types of Personal Data held should be in writing
and addressed to our Data Protection Officer.
Please note that this Statement may be amended from time to time. Notices
regarding amendments will be posted at our home-page to inform you of
the effective dates of the amendments. Amendments will not have retrospective
effect.
Security Statement
This Statement is, except where separate and distinctive statements are
provided, applicable to the Hutchison Global Communications group of companies,
including Hutchison Global Communications Limited and Hutchison Multimedia
Services Limited. Accordingly, references to "we", "us", or "our company"
etc. mean, as the case may be, the relevant company within the Hutchison
Global Communications group of companies.
While the Internet is not an inherently secure environment for communications,
Internet communications can be made safer by the application of appropriate
technology as we have done (see below). Internet security, however, is
not solely a "technology" issue. Common sense and normal practice in safeguarding
personal and transaction data are of equal importance. "Hackers" need
a "door" to get into the system. Often, access through this "door" is
provided to "hackers" due to simple carelessness in the physical distribution
of sensitive documents and the handling of sensitive data (such as passwords
or personal identification numbers). Users must, therefore, handle such
sensitive documents and data with extreme care.
We take security matters very seriously and treat all personally identifiable
information obtained from users of our websites confidential. In addition
to the firewalls and other sophisticated equipment implemented, we also
provide and maintain the following measures to protect our system, and
the information and data contained in them from accidental or malicious
disruption or destruction.
Adopt Security Standards
We will adhere to international standards to ensure transaction integrity
and protect confidential information. Such standards relate to, for instance,:
- i. business and information privacy practices;
- ii. transaction integrity; and
- iii. information protection.
Internal Guidelines on Access to Personally Identifiable Information
All of our staff will adhere to our internal Guidelines on Access to
Personally Identifiable Information drawn up to restrict access to personal
data to only the members of staff who have legitimate needs to have such
access.
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