- This Statement is made in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the “Ordinance”) and serves to notify the data subjects (amongst others) why personal data is collected, how it will be used and whom the Company shares it with.
- For the avoidance of doubt, this Statement applies to personal data collected or generated through the app only.
- In case of discrepancies between the English and Chinese versions, the English version shall apply and prevail.
- Nothing in this Statement shall limit the rights of data subjects under the Ordinance.
COLLECTION AND RETENTION OF PERSONAL DATA
- From time to time, it is necessary for users of the app (collectively “data subjects”), to supply the Company with personal data in connection with matters and purposes set out in this Statement. The Company may also collect personal data, directly or indirectly:
- in the ordinary course of providing services made available through the app (“Services”) (for example, when a data subject registers a user account on the app);
- from a person acting on behalf of the data subjects whose data is provided;
- from the data subjects’ use of the app (including through behavioural tracking tools); and
- other sources (for example, information obtained from the Company’s partners, sponsors, or other affiliates).
- We will only collect information that we believe to be relevant and required to fulfil the purposes for which it is collected. The types of personal data we collect from data subjects will depend on the circumstances in which that information is collected. The Company may collect from a data subject personal data including (without limitation) his name, phone number, email address, profile picture, physiological data (for example, fingerprint, facial images), consumption habits, digital footprints (such as cookies, search history and patterns, internet protocol (IP) address, and social media data), health data tracked and collected by the data subject’s phone and supplied by the data subject from time to time (such as walking distance).
- The collection of personal data is necessary to allow the Company to provide data subjects with the Services. Failure to supply such data may result in the Company being unable to approve the registration of a personal profile on the app or to maintain or provide Services to a data subject.
- We retain the data subjects’ personal data for as long as required to satisfy the purpose for which they were collected and used (for example, for the time necessary for us to resolve technical problems) unless a longer period is necessary for our legal obligations or to defend a legal claim.
PURPOSES AND USE OF PERSONAL DATA
- Broadly, the Company may use data subjects’ personal data for the following purposes:
- considering applications for account registration or Services on the app;
- the daily operation and maintenance of the app and the Services provided via the app;
- to provide you with access to the content on the app or on a third party platform;
- analysing how data subjects access and use the Company’s services from time to time;
- advertising and marketing services, products and other subjects (including in connection with direct marketing as detailed in paragraph 12 below), and customising such services, products and other subjects based on the personal data of the data subjects;
- to assist in law enforcement purposes, investigations by police or other government or regulatory authorities and to meet requirements imposed by applicable laws and regulations or other obligations committed to government or regulatory authorities;
- exchanging information with the Company’s partners, sponsors, or other affiliates participating in or involved in the provision of the Services (whether such Services are provided directly on the app or on a third party platform);
- verifying data subjects’ identities in connection with redemption of rewards conducted via the app by the Company, the Company’s partners, sponsors, or other affiliates (where applicable);
- other purposes as notified at the time of collection; and
- purposes relating thereto.
DISCLOSURE OF PERSONAL DATA
- Data held by the Company relating to a data subject will be kept confidential but the Company or an affiliate of the Company may provide such information to the following parties (whether within or outside Hong Kong) for the purposes set out in paragraph 9 above:
- any agents, contractors, sub-contractors, service providers or other affiliates of the Company (including their employees, directors, officers, agents, contractors, service providers, and professional advisers);
- any third party service provider who provides administrative, telecommunications, computer or other services to the Company in connection with the operation of its business and provision of the Services (including their employees, directors and officers);
- third parties (such as the Company’s partners, sponsors, or other affiliates) participating in or involved in the provision of the Services (whether such Services are provided directly on the app or on a third party platform);
- any government or regulatory bodies in any jurisdiction or any person to whom the Company must disclose data of a data subject: (a) under a legal and/or regulatory obligation in that or any other jurisdiction applicable to the Company; or (b) pursuant to an agreement between the Company and the relevant government, regulatory body or other person;
- any persons acting on behalf of an individual whose data is provided; and
- any actual or proposed assignee of the Company or participant or sub-participant or transferee of the Company’s rights in respect of the data subject.
- Personal data of a data subject may be processed, kept and transferred or disclosed in and to a jurisdiction outside Hong Kong. Such data may also be processed, kept, transferred or disclosed in accordance with the local practices and laws, rules and regulations (including any governmental acts and orders) in that jurisdiction.
USE OF PERSONAL DATA IN DIRECT MARKETING
- Where a data subject has given consent (which includes an indication of no objection) for the Company to do so, the Company may use the data subject’s data to provide the data subject with direct marketing. In this connection, please note that:
- the Company may use the following categories of data for its direct marketing purposes:
- the name, contact details and demographic data of a data subject held by the Company from time to time; and
- information relating to the data subject’s use of the Company’s app from time to time, whether through cookies or otherwise;
- the following classes of services, products and subjects may be marketed:
- related services and products provided by third parties through the rewards points program; and
- services and products offered by co-branding partners and sponsors of the Company.
ACCESS AND CORRECTION OF PERSONAL DATA
- Under and in accordance with the terms of the Ordinance, any data subject has the right:
- to check whether the Company holds data about him/her and/or of access to such data;
- to require the Company to correct any data relating to him/her which is inaccurate;
- to withdraw any consent that he/she has previously given the Company with respect to the Company’s use of his/her personal data; and
- to ascertain the Company’s policies and practices in relation to data and to be informed of the kind of personal data held by the Company and/or the data subject has access to.
- In accordance with the terms of the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access request.
SECURITY OF PERSONAL DATA
- The Company is committed to protect the security of personal data. The Company will take all reasonable steps, including technical and organisational security measures, to safeguard the personal data of each data subject (including personal data in transit and storage).
- Data subjects should be aware that the Internet may not be a secure form of communication and sending the Company personal data over the Internet may carry with it risks (including the risk of access and interference by unauthorised third parties).
AMENDMENT TO THIS PRIVACY STATEMENT
- The Company reserves the right, at any time and without notice, to add to, change, update or modify this Statement, simply by notifying you of such change, update or modification. If we decide to change our personal data policy, those changes will be notified on the app so that you are always aware of what information we collect, how we use the information and under what circumstances the information is disclosed. Any such change, update or modification will be effective immediately upon posting. Where required by applicable law, we may also notify you in the event of material changes to this Statement and, where required, seek your consent to those changes.
CONTACT THE COMPANY
- The contact details of the Company to which requests for access to data or correction of data or for information regarding policies and practices and kinds of data held are to be addressed is as follows:
Data Protection Officer
Techture Event Limited