Privacy Policy
Privacy Policy and
Personal Information Collection Statement
This Statement is, except where separate and distinctive
statements are provided, applicable to OWTEL Limited (the "Company")
Please note that this Statement may be amended from time to
time without prior notice. You are advised to check for the latest version on a
regular basis. If there is any inconsistency or conflict between the English
and Chinese versions of this Statement, the English version shall prevail.
1. Privacy Policy Statement
1.1Our Pledge
We are committed to safeguard the privacy of individuals
with respect to your personal data. We assure that our policies and practices,
and those adopted by our affiliated companies and agents in relation to the
collection, use, retention, disclosure, transfer, security and access of your
personal data comply with the requirements under the Personal Data (Privacy)
Ordinance (Chapter 486) (the "Ordinance") under the laws of Hong
Kong, as well as the relevant code of practice and guidance issued by the
Office of the Privacy Commissioner for Personal Data, Hong Kong. The meaning of
the term "personal data" adopted in this Statement is defined in the
Ordinance.
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.
1.2Collection
of personal data
At times, you may be required to provide your personal data
including, but not limited to, your name, gender, date of birth, identity
document number and/or its copy, telephone number, fax number, location, postal
address and/or its proof, email address, credit card information, bank account
number etc. Refusal to provide such information may render us unable to handle
any application or request you are making, or may deny you access to certain
parts of our websites, 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 provide us with any personal data.
Information relating to your use of our services, such as
usage of data, SMS, voice call connection time, duration, origin and
destination and other value added services whether
provided by us, our affiliated companies or our business partners, may be
automatically collected for our accurate reporting and administration of your
accounts.
Some of our websites may disclose non-personally
identifiable aggregate statistics relating to our visitors to advertisers. Some
of our websites may collect aggregate information about our visitors, e.g. statistics on the number of visits. This type of data
may include, but is not limited to, the browser type and version, operating
system, IP address and/or domain name.
When you visit our websites, we will record your visit only
but will not collect any personal data from you unless otherwise stated.
Cookies used (if any) in any part of our websites will not be deployed for
collecting personal data. For your information, Cookies are small computer
files that can be stored in web surfers' computers for the purposes of
obtaining configuration information and analyzing web
surfers' viewing habits. They can save you from registering again when
re-visiting a website and are commonly used to track your preferences in
relation to the subject matter of the website. 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 websites. Our websites may bar users who do
not accept Cookies.
Calls between you and our Customer Service may be recorded
for the purposes of staff training, improvement of service quality and
clarification of contractual issues.
1.3Accuracy
of personal data
Your application for our services may be subject to credit
assessment and verification of your personal details. If we regard results of
such checking is unsatisfactory, we will not enter into an agreement with you.
Under certain circumstances, data provided by you will be validated by using
generally accepted practice. We may also require you to show the original
documentation before the data may be used, such as personal identification
document and/or proof of address.
1.4Use of
personal data collected
Specific purposes for which your personal data may be used
are set out in our "Personal Information Collection Statement" set
out in Part 2 below (particularly those contained in points (i) through to (viii) in the first paragraph of Part 2.1
below).
1.5Data
access and correction
Under 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.Request
us to correct any inaccurate personal data held by us; and
iv.Ascertain
our policies and practices established (from time to time) in relation to
personal data and the types of personal data held by us. If you want to access
and/or correct your personal data which you have given us via application form,
internet or other means, or if you want to ascertain our policies and practices
in 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 within
40 days after receiving the request. We may charge you a reasonable fee for each
personal data access. However, such fee will be waived if the data access is
made for the purpose of correcting your personal data.
1.6Security
of personal data
We use various encryption techniques to transmit via the
Internet your personal data, which can only be accessed by our authorized
personnel. Given the operational nature of the Internet, we cannot guarantee
that the transmission is fully secure. Please refer to our "Security
Statement" in Part 3 below 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 to avoid unauthorized interference by third parties.
1.7Internal
Guidelines on Record Retention and Access to Personal Data
Our staff are required to strictly adhere to our Internal
Guidelines on Record Retention and Access to Personal Data. Physical records
containing personal data are securely stored in locked areas when not in use.
Access to such physical and/or computer records is strictly controlled and
requires management approval for each access. 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 from accidental and/or unauthorized
disclosure, modifications, loss and/or destruction.
1.8Retention
of personal data
If you are a customer of ours, your personal data which you
have given us via application form, internet or other means, during the service
subscription period will be erased after two years upon termination of your
subscription unless your service account shows a negative credit or payment
history as assessed. If you are a participant of any of our business
collaboration programs, your personal data which you have given us via the
channel(s) designated by us will be erased after one year upon occurence of the latest business activity carried out by
you under the relevant business collaboration program unless otherwise
specified.
1.9Promotion
and selling of products and services of third party
service providers
We may promote and sell products and services of on-line
stores or service providers operated by third party merchants on or through our
website. If you want to use or order any services or products from them, please
note that once the information that you provided is transferred or provided to
the relevant merchant, it will be beyond our control and thus outside the scope
of protection afforded by us.
2. Personal Information Collection Statement
2.1As a
customer of our company, or a visitor or user of our website(s), it may be
necessary for you to provide us with your personal data when you apply to us
and/or continue to subscribe with us for any service and/or product, or
participate in any business collaboration program launched by us. If your
personal data is incomplete or incorrect, we may not be able to provide or
continue to provide the services to you or to allow you to participate in any
business collaboration program launched by us. 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 requirements under the Ordinance and
this Statement. We may use and retain the personal data provided by you 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.Processing
of your application for service or participation in any business collaboration
program launched by us, and provisioning of the services by us, our affiliated
companies or our business partners (as the case may be);
ii.Subject
to your consent, we may use your personal data (including name, gender,
telephone number, fax number, location, postal address, email address, month
and year of birth, as well as the information on usage of telecommunications
and related telecommunications value-added services and relevant account and
service numbers, as applicable) for marketing the categories of goods and/or
services as set out in the customer consent form or other designated form of
customer consent which may be subject to change from time to time (irrespective
of whether we are remunerated for such marketing activities) relating to us,
our affiliated companies and business partners. We may dispatch to you the
promotional information via direct marketing telephone calls, e-mail,
e-message1, facsimile, direct mailings etc.
iii.Processing
of any benefits for you arising out of the services and carrying out market
research to enhance service quality or experience;
iv.Analyzing, verifying and/or checking of your credit,
payment and/or account 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.Facilitating
the daily operation of your account, provisioning of customer services and/or
the collection of overdue amounts in your account in relation to the services;
vii.Enabling
us to perform any obligations on interconnection or conform with other industry
practices, or to comply with any requests stipulated by governmental or
regulatory authorities; and
viii.Enabling
us in prevention of crime.
1 E-message means electronic messages delivered via the
following means: mobile short messaging service (SMS) / multimedia messaging
services (MMS) / cross-platform mobile messaging application (e.g. smartphone messaging application).
2.2We may
disclose and transfer (whether in Hong Kong or overseas) your personal data to
the following parties to use, disclose, process or retain your personal data
for the purposes mentioned above:
i.Our
agents and contractors (including IT, network, customer service, sales agents
and contractors), telecommunications operators, and service providers for the
provision of our services;
ii.Our
affiliated companies and business partners;
iii.Banks,
financial institutions and credit providers;
iv.Debt
collection agencies, credit reference agencies and security agencies;
v.Regulatory
bodies, law enforcement agencies and courts; and
vi.Our
professional advisers.
2.3If at any
time in the future you do not wish to receive direct marketing promotional
information from us with respect to the telecommunication and/or other
categories 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 Customer Service Hotline 1033
or to update the instruction by logging in the 3Care platform through 3HK's
website. You may also visit our "3" shops to obtain and complete the
"Opt Out Direct Marketing Application Form"
by returning the form to our Customer Service Department either in person to
"3" shops or by post: P.O. Box No.999, Tsuen Wan Post Office, New
Territories, Hong Kong.
2.4 If you would like to request deletion of your personal data that has been collected by our platform, please follow these steps:
3. Security Statement
While internet is not an inherently secure environment for
communications, security of internet communications can be enhanced by the
application of appropriate technology. However, internet security is not solely
a technical issue, knowledge on security of personal and transaction data as
well as general measure are equally important. "Hackers" could only
attack a system through a "door". However, in most cases imprudent
transmission and handling of sensitive data such as confidential documents,
password, personal identifiers etc. would facilitate unauthorized access to
such a "door" by "hackers". Hence, internet users should be
cautious when handling such kind of sensitive documents and data.
In order to prudently preserve all personal data obtained
from users of our websites, apart from firewalls and other sophisticated
technical facilities, we also provide and maintain other stringent security
measures so as to protect our system as well as the information and data
retained therein from accidental or malicious destruction or damage.
4. Enquiries
Should you have any enquiries concerning this Statement,
please feel free to contact our Data Protection Officer in writing via post or
email at:
OWTEL Limited
By post :
Rm 1509, West Tower, Shun Tak Centre
168-200 Connaught Road Central, Sheung Wan
Hong Kong
By email:
info@owtel.com