1. General
This privacy policy sets out the policies and practices of Infotronic Technology Limited (‘ITT’) in the collection, use, sharing and protection of customers’ personal information. ITT may update or change this policy and these changes will be posted in ITT’s website.
2. Collection of Customer’s Personal Information
a) For the purpose of carrying on ITT’s business including sale, provision, registration and advertisements of ITT’s solution, including but not limited to ITT trademarked InfoSMART solutions and related products and services, ITT will collect your personal information when you:
(i) purchase a product from ITT or through ITT’s authorized dealers or agents;
(ii) subscribe or register a service of ITT from ITT’s website, app or through ITT’s authorized dealers or agents;
(iii) update your personal information in relation to your registration or subscription to ITT’s services;
(iv) enquire information about a product or service from ITT;
(v) contact ITT with an enquiry or complaint;
(vi) enter any promotions, competitions, prize draws through ITT’s services;
(vii) use ITT’s products or services; or
(viii) take part in market research;
(ix) visit or browse ITT’s or ITT’s products or services websites.
b) ITT may also collect information about you from other organizations including general business directories and credit information or reference bureau necessary to establish and support the payment of any services being requested by you.
3. Types of Personal Data Collected
a) For the purpose of carrying on ITT’s business including sale, provision, registration and administration of ITT’s solutions, related products and services (including relevant on-line products and services), the information that ITT collects includes but is not limited to the following:
(i) your name;
(ii) service installation address, correspondence address and/or billing address;
(iii) account details, including account numbers, service numbers or user accounts;
(iv) payment details including credit card information, bank account and other banking information;
(v) contact details, including contact name and fixed and mobile telephone number and email address;
(vi) your date of birth;
(vii) information for the verification of your identity, including identification type and identification number
(viii) your preferences for particular products, services or your hobbies and leisure activities;
(ix) a note or recording of a call that you made to ITT’s hotlines;
(x) an email or letter you send to ITT; and other records of any contact you have with ITT;
(xi) your account information, such as dates of payment, top-up information, the service plans you have subscribed; and any other information relating to your account.
b) In support of the products and services provided by ITT, information may be automatically collected by ITT on how you use ITT’s products and services, including but not limited to:
(i) the telephone numbers and/or email addresses registered with or initiated the use of the ITT’s products and services;
(ii) your browser type and version, searching, IP address and location data;
(iii) internet PC location for broadband, address location for billing, delivery and installation.
ITT may use cookies across its websites in order to improve their performance and enhance your online experience. You may disable cookies on your web browser but if you do so, you may not be able to access certain areas or features of our websites.
c) In certain situations, you may need to provide personal data of other individuals to ITT, for example, of other users collaborating with you to access same set of data managed by ITT’s service. By providing ITT with such personal data, you represent to ITT that you have obtained those individuals’ authorisation and/or consent to the use, disclosure and transfer of personal data from you to ITT and from ITT to third parties and possible disclosure of the individual’s details (including information on service usage) by ITT to you.
d) If you choose not to provide your personal data, ITT may not be able to provide you with its products or services or carry out the activities mentioned in this policy.
4. Use of Customers’ Personal Information ITT may use and analyse your information for purposes including but not limited to:
(i) the daily operation of ITT’s services;
(ii) verifying your identity and conducting credit checks when required;
(iii) designing services or products for customers’ use;
(iv) processing your order and providing the products and services that you have bought from ITT and keeping you updated with the progress of your order;
(v) keeping you updated of ITT’s latest offers or promotions;
(vi) marketing products and services (in respect of which ITT may or may not be remunerated) in the manner set out in the “Direct Marketing” section below.
(vii) assisting you with any products or services enquiries, including investigating and resolving service affecting issues and dealing with any billing queries you may have;
(viii) billing you for using ITT’s products or services;
(ix) analysing usage of ITT’s products and services by you and other customers so that ITT can further improve ITT’s products and services and/or better tailor the type of products and services presented to customers;
(x) carrying out research and statistical analysis and monitoring customer use of ITT’s products and services on an anonymous or depersonalised basis;
(xi) assisting ITT in fraud and crime prevention;
(xii) debt tracing, debt recovery and credit management;
(xiii) contacting you if necessary.
5. Retention of Personal Data
ITT will destroy any personal data it may hold in accordance with its internal policy. Personal data will only be retained for as long as ITT needs it for the purposes of use stated in this policy (and directly related purposes) unless the personal data is also retained to satisfy any applicable statutory, regulatory or contractual obligations or for the purpose of investigation, detection and prosecution of crime.
6. Disclosure and Sharing of Personal Data
a) All personal data held by ITT will be kept confidential but ITT may disclose information about you to the following parties to use, disclose, process or retain your personal data for the purposes mentioned above and any other purposes indicated in this paragraph below:
(i) companies of ITT;
(ii) contractors, agents or suppliers who are involved in delivering the products and services you have ordered or used;
(iii) any banking or financial institutions, charge or credit card issuing companies;
(iv) credit information or reference bureaux;
(v) debit-collection agencies or other debt-recovery organizations;
(vi) professional advisers (which shall include lawyers and auditors);
(vii) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment, data analytics or other services to ITT in connection with the operation of its business;
(viii) law-enforcement or government bodies, regulatory bodies, courts or as required by law;
(ix) any person to whom ITT is under an obligation to make disclosure under the requirements of any law binding on ITT or under and for the purposes of any guidelines issued by regulatory or other authorities with which ITT is expected to comply;
(x) third party reward, loyalty and privileges programme providers;
(xi) external service providers (including but not limited to mailing houses, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that ITT engages for the purposes set out in paragraph 4;
b) ITT may promote or refer to online stores or websites operated by its business partners or other third parties on ITT’s website. If you want to use or order any services or products from them and click on their links, any information that you provided which is transferred to them will be beyond ITT’s control. ITT takes no responsibility over such links. You are advised to study their privacy policies.
7. Direct Marketing
a) ITT intends to use your personal data such as your contact details, including contact name, fixed and mobile telephone number, email address, correspondence address and other information such as information about the products or services you have viewed online or purchased and your location data so that ITT and/or its business partners can send you information, materials, products, offers and news about the following products and services (in respect of which ITT may or may not be remunerated):
(i) all products or services by ITT including its online platforms and mobile applications;
(ii) reward, loyalty or privileges programmes and related products and services; and
(iii) products and services offered by ITT’s business partners including travel, dining, entertainment, apparel, health & beauty, education, household, transportation, banking, insurance and other consumer products and services. ITT will seek your consent or indication of no objection before ITT uses your personal data in direct marketing.
b) You may opt out (free of charge) from receiving direct marketing communications at any time in writing by post to the address stated in paragraph 10(c) below or by other means stated in ITT’s websites from time to time.
8. Security of Personal Data
a) ITT has adequate measures to protect your personal information from unauthorized access, accidental loss or destruction.
b) If ITT has a contract with another third party organization to provide a service on its behalf, ITT will ensure they have appropriate security measures and only process your information as ITT has authorized. Those organizations will not be entitled to use your personal information for their own purposes. ITT will take reasonable steps to check these organizations to make sure that they are meeting the security requirements set by ITT.
9. Transfer of Personal Data Outside of Hong Kong
At times it may be necessary and/or prudent for ITT to transfer certain personal data to other group companies or service providers outside of the Hong Kong Special Administrative Region (‘Hong Kong’). This may happen if ITT’s servers or suppliers and service providers are based outside of Hong Kong. ITT will take steps to ensure that your personal information is used by such third parties in accordance with this policy.
10. Your Privacy Rights
a) In accordance with the Personal Data (Privacy) Ordinance (‘the Ordinance’) and subject to exemptions specified in the Ordinance, you have the right to:
(i) check whether ITT holds personal data about you and to receive copies of such data;
(ii) require ITT to correct any personal data relating to you which is inaccurate; and
(iii) ascertain ITT’s policies and practices in relation to personal data and to be informed of the kind of personal data held by ITT.
b) In accordance with the Ordinance, ITT has the right to charge a reasonable fee for processing a data access request.
c) Requests for access to personal data, correction of personal data, information relating to the kind of data held and to stop receiving or re-start receiving direct marketing, may be made in writing by post to:
The Data Protection Officer
Infotronic Technology Limited
25/F, Linkchart Centre,
2 Tai Yip Street, Kwun Tong, Hong Kong
Please identify yourself with your name and contact number when writing to the Data Protection Officer.
11. Privacy Policy Published at www.infosmart.io
This Privacy Policy is subject to change from time to time without prior notice and any changes will be posted on ITT’s website, www.infosmart.io. You are advised to check for the latest version regularly. If there is any inconsistency or conflict between the version posted on the website and the previous versions, this version shall prevail. All handling of personal data will be governed by the most recent version of the policy. If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version will prevail.
Registered office: 25/F, Linkchart Centre, 2 Tai Yip Street, Kwun Tong, Hong Kong