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Privacy Policy


Privacy Policy andPersonal Information Collection Statement

1. Privacy Policy Statement

1.1 Our Pledge

We are committed tosafeguard the privacy of individuals with respect to your personal data. Weassure that our policies and practices, and those adopted by our affiliatedcompanies and agents in relation to the collection, use, retention, disclosure,transfer, security and access of your personal data comply with therequirements under the Personal Data (Privacy) Ordinance (Chapter 486) (the"Ordinance") under the laws of Hong Kong, as well as the relevantcode of practice and guidance issued by the Office of the Privacy Commissionerfor Personal Data, Hong Kong. The meaning of the term "personal data"adopted in this Statement is defined in the Ordinance.

Where ouroperations are subject to privacy legislation other than that of Hong Kong(such as due to our carrying out of operational functions outside of HongKong), this Statement shall apply so far as it is consistent with such locallegislation.

1.2 Collection ofpersonal data

At times, you maybe required to provide your personal data including, but not limited to, yourname, gender, date of birth, identity document number and/or its copy,telephone number, fax number, location, postal address and/or its proof, emailaddress, credit card information, bank account number etc. Refusal to providesuch information may render us unable to handle any application or request youare making, or may deny you access to certain parts of our websites, or mayotherwise defeat the objectives of your visit. If you are under the age of 18,consent from your parent or guardian is required before you provide us with anypersonal data.

Informationrelating to your use of our services, such as usage of program, duration oflogin and other value added services whether provided by us, our affiliatedcompanies or our business partners, may be automatically collected for ouraccurate reporting and administration of your accounts.

When you visit ourwebsites, we will record your visit only but will not collect any personal datafrom you unless otherwise stated. Cookies used (if any) in any part of ourwebsites will not be deployed for collecting personal data. For yourinformation, Cookies are small computer files that can be stored in websurfers' computers for the purposes of obtaining configuration information andanalyzing web surfers' viewing habits. They can save you from registering againwhen re-visiting a website and are commonly used to track your preferences inrelation to the subject matter of the website. You may refuse to accept Cookiesby modifying the relevant Internet options or browsing preferences of yourcomputer system, but to do so you may not be able to utilize or activatecertain available functions in our websites. Our websites may bar users who donot accept Cookies.

Calls between youand our Customer Service may be recorded for the purposes of staff training,improvement of service quality and clarification of contractual issues.

1.3 Accuracy ofpersonal data

Your applicationfor our services may be subject to verification of your personal details. If weregard results of such checking is unsatisfactory, we will not enter into anagreement with you. Under certain circumstances, data provided by you will bevalidated by using generally accepted practice. We may also require you to showthe original documentation before the data may be used, such as personalidentification document and/or proof of address.

1.4 Use of personaldata collected

Specific purposesfor which your personal data may be used are set out in our "PersonalInformation Collection Statement" set out in Part 2 below (particularlythose contained in points (i) through to (viii) in the first paragraph of Part2.1 below).

1.5 Data access andcorrection

Under theOrdinance, you have the right to:

i. Check whether wehold any of your personal data;

ii. Access yourpersonal data held by us;

iii. Request us tocorrect any inaccurate personal data held by us; and

iv. Ascertain ourpolicies and practices established (from time to time) in relation to personaldata and the types of personal data held by us.If you want to access and/orcorrect your personal data which you have given us via application form,internet or other means, or if you want to ascertain our policies and practicesin relation to personal data and the kind of your personal data held by us,please contact our Data Protection Officer in writing, we will respond within40 days after receiving the request. We may charge you a reasonable fee foreach personal data access. However, such fee will be waived if the data accessis made for the purpose of correcting your personal data.

1.6 Security ofpersonal data

We use variousencryption techniques to transmit via the Internet your personal data, whichcan only be accessed by our authorized personnel. Given the operational natureof the Internet, we cannot guarantee that the transmission is fully secure.Please refer to our "Security Statement" in Part 3 below for detailson the steps that we have taken to ensure that any personal data collected byus via our websites is safe and secure to avoid unauthorized interference bythird parties.

1.7 InternalGuidelines on Record Retention and Access to Personal Data

Our staff arerequired to strictly adhere to our Internal Guidelines on Record Retention andAccess to Personal Data. Physical records containing personal data are securelystored in locked areas when not in use. Access to such physical and/or computerrecords is strictly controlled and requires management approval for eachaccess. Approvals for access to customers' personal data are granted only on a"need to know" basis. Where we retain, use and/or transmit customers'personal data, we have put in place adequate measures to protect it fromaccidental and/or unauthorized disclosure, modifications, loss and/ordestruction.

1.8 Retention ofpersonal data

If you are acustomer of ours, your personal data which you have given us via applicationform, internet or other means, during the service subscription period will beerased after two years upon termination of your subscription. If you are aparticipant of any of our business collaboration programs, your personal datawhich you have given us via the channel(s) designated by us will be erasedafter one year upon occurence of the latest business activity carried out byyou under the relevant business collaboration program unless otherwisespecified.

2. Personal Information Collection Statement

2.1 As a customerof our company, or a visitor or user of our website(s), it may be necessary foryou to provide us with your personal data when you apply to us and/or continueto subscribe with us for any service and/or product, or participate in anybusiness collaboration program launched by us. If your personal data isincomplete or incorrect, we may not be able to provide or continue to providethe services to you or to allow you to participate in any businesscollaboration program launched by us. We shall keep your personal dataconfidential at all times. Our policies and practices with respect to thecollection, use, retention, disclosure, transfer, security and access ofpersonal data will be in accordance with requirements under the Ordinance andthis Statement. We may use and retain the personal data provided by you for thefollowing purposes and for other purposes as shall be agreed between you and usor required by law from time to time:

i. Processing ofyour application for service or participation in any business collaborationprogram launched by us, and provisioning of the services by us, our affiliatedcompanies or our business partners (as the case may be);

ii. Processing ofany benefits for you arising out of the services and carrying out marketresearch to enhance service quality or experience;

iii. Analyzing,verifying and/or checking of your credit, payment and/or account status inrelation to the provision of the services;

iv. Processing ofany payment instructions, direct debit facilities and/or credit facilitiesrequested by you;

v. Facilitating thedaily operation of your account, provisioning of customer services and/or thecollection of overdue amounts in your account in relation to the services;

vi. Enabling us inprevention of crime.

2.2 We may discloseand transfer (whether in Hong Kong or overseas) your personal data to thefollowing parties to use, disclose, process or retain your personal data forthe purposes mentioned above:

i. Our agents andcontractors and service providers for the provision of our services;

ii. Our affiliatedcompanies and business partners;

iii. Banks,financial institutions and credit providers;

iv. Debt collectionagencies, credit reference agencies and security agencies;

v. Regulatorybodies, law enforcement agencies and courts; and

vi. Ourprofessional advisers.

2.3 If at any timein the future you do not wish to receive direct marketing promotionalinformation from us with respect to the telecommunication and/or othercategories of products/services mentioned above, or do not wish us to disclose,transfer or use your personal data for the aforesaid direct marketing purposes, please contact our Data Protection Officer via email.

3. Security Statement

3.1 While internetis not an inherently secure environment for communications, security ofinternet communications can be enhanced by the application of appropriatetechnology. However, internet security is not solely a technical issue,knowledge on security of personal and transaction data as well as general measureare equally important. "Hackers" could only attack a system through a"door". However, in most cases imprudent transmission and handling ofsensitive data such as confidential documents, password, personal identifiersetc. would facilitate unauthorized access to such a "door" by"hackers". Hence, internet users should be cautious when handlingsuch kind of sensitive documents and data.

In order toprudently preserve all personal data obtained from users of our websites, apartfrom firewalls and other sophisticated technical facilities, we also provideand maintain other stringent security measures so as to protect our system aswell as the information and data retained therein from accidental or maliciousdestruction or damage.

4. Enquiries

4.1 Should you haveany enquiries concerning this Statement,

please feel free tocontact our Data Protection Officer in writing via post or email at:


to our DataProtection Officer.