this statement is, except where separate and distinctive statements are provided, applicable to the telecom digital holdings limited’s group of companies (the “group”), including but not limited to telecom digital services limited, telecom digital data limited and telecom digital mobile ltd. accordingly, references to "we", "us", or "our company" shall mean, as the case may be, the relevant companies within the group.
we value the privacy rights of customers. we endeavor to ensure that all our collection, transmission, processing, storage and usage of our customers’ personal data shall comply with the personal data (privacy) ordinance, cap 486 of the laws of the hong kong special administrative region ("pdpo").where our operations are subject to privacy legislation other than that of hong kong (such as due to our carrying out of operational functions outside of hong kong), this statement shall apply so far as it is consistent with such local legislation.
1. i. aim and collection of personal data
we will collect your personal data incircumstances including but without limitation to the following:
1. purchase a product from us through the telephone, online, in our store or through our company’s authorized dealers or agents;
2. subscribe or register a service with us (including registration or subscription of the service at our store, through the telephone or online or through our company’s authorized dealers or agents);
3. register and use near field communication mobile payment services which are provided by third party financial institutions;
4. update your personal information in relation to your registration or subscription to our services;
5. enquire information about a product or service;
6. contact us with an enquiry or complaint;
7. enter any promotions, competitions, prize draws through our services;
8. use our company’s products or services;
9. take part in market research;
10. visit or browse our company’s websites;
11. use our company’s networks (mobile / broadband or others); or
12. browse or otherwise access the internet, wap sites and/or the mobile internet through our services.
ii. types of personal data collected
we might collect your personal data including but not limited to one or more of the following:
1. personal information, including full name as registered on the hong kong identity card or other travel document, date of birth, gender and hong kong identity card number, marriage status, household income range and personal interest;
2. contact information, including mobile telephone number, social media contact, email address and correspondence address;
3. payment information, including credit card, debit card and banking information;
4. account information, including account details or data relating to services registered with us with relevant pin, username or password, account numbers and/or service numbers
5. computer or mobile device information, including ip address, real-time geographic location data, browser settings, browsing records, and/or other internet log information of your computer or mobile device;
6. information relating to services registered with our company at any time;
iii. purpose of personal data collection
we may collect your personal data for the following purposes:
1. to verify your identity;
2. to process your application to subscribe to our products and services and loyalty programs;
3. to provide the related service and loyalty program
4. to process order, billing and fulfilment
5. to design service for you
6. to provide customer service to you
7. to enforce our contractual rights
8. to process any payment instructions, direct debit facilities and/or credit facilities in relation to supply of goods and services to you;
9. to offer rewards and promotions and share promotional benefits;
10. to provide updates, offers and invitations to events and deliver relevant advertising;
11. to conduct appropriate checks for credit-worthiness and for fraud;
12. to perform research or analysis by us and/or any other independent contractors instructed by usin order for us to improve our products, services and loyalty programs and for survey,marketing, promotional, behavioral scoring and/or business planning purposes;
13. to carry out market and product analysis in order to generate statistical reports which may beshared with external companies who are not affiliates oftelecom digital holdings ltd for their own use. thesereports are aggregated and will not contain any information that identifies you;
14. to maintain and develop our business systems and infrastructure, including testing andupgrading of these systems;
15. to handle your complaint and account enquires;
16. to assist in the prevention, detection or investigation of crime or possible criminal activities.
17. to audit
18. to comply with our telecommunications license obligations in respect of interconnection arrangements with other telecommunications operators and related industry practices;
19. to comply with applicable laws, rules and regulations;
20. to serve any other purposes directly related to the purpose for which the personal data were originally collected.
iv. direct marketing
provided that you have given your consent, we may use your personal information for direct marketing of telecommunications services and products (including all services and products provided by the group companies of telecom digital holdings ltd), and to send you marketing communications and materials in other services and products offered by our business partners including without limitation securities and investment, insurance, banking, credit card, entertainment, spa and massage, transportation, household, apparel, food & beverages, education, health and wellness, social networking, media and consumer products, via email, sms, text message, telephone call and message broadcasting, etc.
we respect all the request on termination of personal data collection. if you prefer not to receive any direct marketing communications from us, you can opt out at any time by email to email@example.com for termination with no extra charge on this.
v. retention, disclosure and securities of personal data
ersonal data will only be collected and retained for as long as is necessary to fulfil the original or directlyrelated purposes for which it was collected, unless the personal data is also retained to satisfyany applicable legal, regulatory or contractual obligations.
in order to deliver the services you requested, we may disclose your personal data to organizationsoutside of our company (within or outside of hong kong), to the extent permissible under applicablelaws and regulations. your personal data is disclosed to these organizations only for the purpose ofassisting us to provide our services to you. these organizations carry out our:
1. customer enquiries;
2. courier/delivery services;
3. mailing operations;
4. billing and debt-recovery functions;
5. information technology services;
6. installation, maintenance and repair services;
7. marketing and telemarketing services;
8. market research; and/or
9. website usage analysis.
in addition, we may disclose your personal data to:
1. your authorized representatives or your legal advisers when requested by you to do so;
2. fraud-checking agencies;
3. collection agencies, security agencies, credit providers or other financial institutions (for credit related purposes such as credit-worthiness, credit rating, credit provision and financing);
4. our affiliates (which shall mean, any entities which directly or indirectly control, are controlled by, or are under common control with us), assignees, transferees and representatives;
5. our professional advisers, including our accountants, auditors and lawyers;
6. banks, hotels, insurance companies, billing agents and various business partners for reward redemption purposes and benefits as applicable to members of our loyalty programs, including without limitation for purposes of registering members for loyalty program related events;
7. any financial institutions, charge or credit card issuing companies, credit providers, credit information or reference bureau, or collection agencies, security agencies, necessary to establish and support the payment of any services being requested;
8. government and regulatory authorities and other organizations, as required or authorized by law; and
9. any proposed or actual participant, assignee or transferee of all or any part of our operation or business.
in some instances, we take reasonable steps to ensure that these organizations are bound byconfidentiality and privacy obligations in relation to the protection of your personal data and thatthey use your personal data only for the above purposes, and not for their own or other purposes(including direct marketing).
you should be aware that no system is impenetrable and no information provided over the internet can be guaranteed as completely secure. accordingly, we cannot guarantee the security of any information that you transmit to us or receive from us over the internet.
vi. transfer of personal data outside hong kong
at times it may be necessary and/or prudent for us to transfer certain personal data to places outsideof hong kong for the prevention, detection or investigation of crime or in order to carry out thepurposes, or directly related purposes, for which the personal data were collected. where such atransfer is performed, it will be done in compliance with the prevailing requirements of the
some of websites may place a "cookie" on your computer or device; for example to personalizethe services we provide whilst you are using our website(s) and/or maintain your identity acrossmultiple pages within or across one or more sessions. this information may include, but is notlimited to, relevant login and authentication details as well as information relating to your activitiesand preferences across our websites.
you can disable cookies on your web browser, however if you do so you may not be able to accessall parts of our websites.
ix. data access or correction
you are entitled to request access to and correction of your personal information. requests in writing may be sent to
19/f, yhc tower,
no.1 sheung yuet road,
attention to: personal data officer
the company reserves the right to charge you a reasonable fee for complying with a data access request as permitted by the pdpo.
this privacy statement may be amended from time to time and all handling of personal data willbe governed by the most recent version of this privacy statement, available on our website atwww.tdhl.cc.if there is any inconsistency or conflict between the english and chineseversions of the privacy statement, the english version will prevail.