Personal Data & Privacy Statement
Persons (“Individual” or “Individuals”) covered by this Statement may include:
1. Visitors to the Website (“Visitors”) whether or not associated with companies considering the use of the Service (“Company” or “Companies”),
All data collection from the Website (which may include Personal Data of individuals acting on behalf of a Company or Subscriber Company to which they are associated) and the use of such data collected in accordance to this Statement is to enable UC Now Communication to provide related communications, customer service and support to Companies in the course of regular business activities associated with our products and services.
UC Now Communication endeavor to ensure that all our collection, transmission, storage and usage of Personal Data shall be carried out in compliance with the Personal Data (Privacy) Ordinance, Cap 486 ("PDPO") of the Laws of the HKSAR as amended from time to time.
The term "Personal Data" shall have the meaning ascribed to it by the PDPO. Certain terms that are capitalized in this Statement are defined and have the meaning applied to them in this Statement and in our Terms & Conditions of Service (“T & C”).
Purpose of Collection and Use of Personal Data
1. Personal Data is collected from Individuals to enable UC Now Communication, upon request, to provide information and service to the Companies or Subscriber Companies with which such Individuals are associated.
2. UC Now Communication shall indicate the items of Personal Data without which UC Now Communication shall be unable to follow up on service request(s)
3. Visitors do not need to supply any Personal Data if he/she is merely visiting the Website and not seeking access to information, service follow up or not seeking assistance in relation to gaining access to or use of the Service. However, if Visitors require follow-up by UC Now Communication’s responsible officers, including but not limited to requesting for catalogues, promotional brochures or materials, scheduling a demonstration, requesting for Service Plans or quotations, requesting for access to free trials, or seeking updates on our service, then the provision of his/her name and at least one of the following contact details are obligatory for UC Now Communication to provide corresponding follow-up services:
- Contact mailing or postal address, or
- Contact email address, or
- Contact telephone number.
4. Personal Data collected from Individuals may be used by UC Now Communication for:
- Marketing to the Company to which the Individual is associated;
- Marketing to the Company to which the individual is associated regarding 3rd party products and services (“3rd Party Product & Services”) of the UC Now Communication’s business partners that may be used in conjunction with our service;
- Conducting market research, User surveys and End User surveys pertaining to UC Now Communication and 3rd Party Product & Services of the UC Now Communication’s business partners that may be used in conjunction with our service ;
- Provisioning of all follow up and customer services for the Company to which the individual is associated;
- Meeting obligations, requirements or arrangements, whether compulsory or voluntary, of Now Communication or any of its related bodies or affiliates (referred to as members of the “UC Now Communication Group”) to comply with, or in connection with:
- any law, regulation, judgment, court order, voluntary code, sanctions regime, within or outside HKSAR, existing currently and in the future ("Laws");
- any guidelines, guidance or requests given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside Hong Kong existing currently and in the future and any international guidance, internal policies or procedures;
- any present or future contractual or other commitment with local or foreign legal, regulatory, judicial, administrative, public or law enforcement body, or governmental, tax, revenue, monetary, securities or futures exchange, court, central bank or other authorities, or self-regulatory or industry bodies or associations of financial service providers or any of their agents with jurisdiction over all or any part of UC Now Communication (together the "Authorities" and each an "Authority"); or
- any agreement or treaty between Authorities;
- Complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information between members of the UC Now Communication Group and/or any other use of data and information in accordance with any programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities;
- Conducting any action to meet obligations of UC Now Communication or any member of the UC Now Communication Group to comply with Laws or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any Laws relating to these matters;
- Meeting any obligations of UC Now Communication or any member of the UC Now Communication Group to comply with any demand or request from the Authorities;
- In conjunction to any other purposes as may be separately notified to or agreed with an individual, including the purposes stated in any special terms and conditions and in applications for the supply of specific goods and services; and
- In conjunction to any other purposes directly related to the above .
5. UC Now Communication will not transfer Personal Data to others except for the specific classes of data transferees as listed in the section
Types of Personal Data Collected
1. Types of Personal Data collected by UC Now Communication may include (but not limited to ) the following:-
- Personal information and contact information such as name, gender, contact information including mailing/postal address(es), email address(es) and contact phone number(s);
- Business information such as company name and business title;
Confidentiality, Disclosure and Security of Personal Data
1. Data held by UC Now Communication relating to an individual will be kept confidential but UC Now Communication may provide such information to the following parties (whether within or outside Hong Kong) for the purposes set out above:
- Any Authorities;
- Any third party service provider who provides sales, marketing, administrative, telecommunications, computer, payment or securities clearing or other services to UC Now Communication in connection with the operation of its business (including their employees, directors and officers), including but not limited to UC Now Communication developers, digital marketing agencies, marketing consultants, professional advisors, digital marketplace operators, banks, financial institutions, payment gateways operators, credit card issuing companies, debt collection agencies, telecommunication service operators and other service providers who is acting for or on behalf or jointly with UC Now Communication and is involved in the marketing, promotion, subscription, sale, administration or provision of our products and services (or any part thereof) (“Third Party Service Providers”);
- Any other person or company who is under a duty of confidentiality to UC Now Communication including anyprovided he/she is able to prove the right to the data and has undertaken to keep such information confidential; iv Persons who may be entitled to disclosure under circumstances described in Part VIII of the PDPO (meaning Personal Data exempt from Data Protection Principal 3 of the PDPO);
- Any agents, contractors, sub-contractors, service providers or associates of UC Now Communication;
- Any person to whom UC Now Communication or any member of the UC Now Communication Group is under an obligation or required or expected to make disclosure;
- Any member of the UC Now Communication Group;
- Charitable or non-profit making organisations; and
- External service providers (including but not limited to mailing houses, telecommunication companies, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that Now Communication engages.
2. UC Now Communication’s Third Party Service Providers are under a duty of confidentiality and are contractually bound to use your Personal Data in connection with the purposes specified above, and not for their own purposes (including direct marketing).
3. UC Now Communication have implemented, based upon appropriate physical, electronic and managerial measures and controls to safeguard all Personal Data provided by Individuals and to secure the transmission of such data to the third parties listed above. Individuals’ Personal Data are only accessible by UC Now Communication’s own personnel or the personnel of the third parties listed above for the purposes specified above. UC Now Communication’s own personnel and the personnel of the Third Party Service Providers will be instructed to observe duty of confidentiality and the terms of this Statement when accessing your Personal Data and handle Personal Data only in accordance with this Statement.
4. Any questions, comments, suggestions or information (including materials or data inputted, submitted, uploaded, posted, disclosed, displayed, linked to or otherwise made available on the Website, sent or posted to the Website by individuals) will be considered as voluntarily provided to the UC Now Communication on a non-confidential, non-private, publicly available and non-proprietary basis. UC Now Communication reserves the right (without any obligation, without any charge and without any liability whatsoever to UC Now Communication, its officers, personnel, agents, contractors and third party service providers) and without giving any notice to the Individuals who provided them to:
- To use, reproduce, disclose, transmit, publish and/or post elsewhere such information freely, including passing it to any associated company for example, in connection with the development, manufacturing and marketing of products and services and to meet customer needs, and
- To validate data provided or made available using generally accepted practices including, in accordance with the PDPO, requiring review of original documentation before the Personal Data may be used.
5. All reasonable efforts are made to ensure that any Personal Data held by UC Now Communication is stored in a secure and safe place.
Transfer of Personal Data Outside Hong Kong
1. If necessary, UC Now Communication may transfer the Personal Data to places outside of Hong Kong for carrying out the purposes, or the directly related purposes specified above. All the transfer of those Personal Data will be carried out in compliance with the requirements of the PDPO. As Personal Data may be stored or processed in another jurisdiction, it may be accessible to law enforcement and national securities of that jurisdiction.
Retention of Personal Data
1. Unless there is a mandatory legal requirement for UC Now Communication to keep your Personal Data for a specified period, UC Now Communication will only retain your Personal Data for as long as necessary to fulfill the purposes specified above for which the Personal Data was originally collected. UC Now Communication will periodically redact, purge, anonymize or destroy unnecessary Personal Data in our system in accordance with our internal procedures.
1. Individuals’ name and contact details, including contact email address(es), contact mailing or postal address(es) and contact phone number(s) may be used by UC Now Communication for direct marketing of:
- Our products and services, including but not limited to, the latest UC Now Communication or 3rd Party services, offers, gifts, discounts, benefits and information associated; and
- Third Party Products and Services; and
- Non-profitable services including solicitation of donations sought by charitable organizations.
2. UC Now Communication may not so use an Individual’s Personal Data unless UC Now Communication has received his/her consent. The Individual’s consent is considered given to UC Now Communication at the time when the Personal Data is provided, or by writing to UC Now Communication Personal Data Officer.
3. Individuals acknowledge that telephone calls with UC Now Communication staff may be recorded and used as evidence by UC Now Communication.
4. UC Now Communication may receive money or other property in return for providing the data to the other persons and, when requesting your consent, UC Now Communication will inform if it will receive any money or other property in return for providing the data to the other persons.
5. Individuals may also write to UC Now Communication’s Personal Data Officer at the address or email below if he/she wishes to withdraw any consent given to Now Communication previously.
1. UC Now Communication may use “cookies” on the Website and systems directly associated with the Service for the following purposes:
- Enable tighter security;
- Build online visitor profiles; and
- Any new purpose that UC Now Communication deems necessary to enable the provision of Updates.
This Statement only applies to the Website but no other 3rd Party/non-UC Now Communication websites. The Website may contain links to other websites and pages.
By activating a link explicitly connecting to such non-UC Now Communication websites, the Individual acknowledges that he/she is intentionally leaving the Website and the Service, and that UC Now Communication does not exercise control over any Personal Data or any other information the Individual gives to any other entity after such departure. Access to and use of such other websites is at the Individual’s own risk and therefore is advised to refer to the privacy policies of those other locations, if any.
Data Access and Correction
Under and in accordance with the terms of the Personal Data (Privacy) Ordinance (“Ordinance”), any individual has the right
- to check whether UC Now Communication holds data about him and of access to such data;
- to require UC Now Communication to correct any data relating to him which is inaccurate; and
- to ascertain UC Now Communication’ policies and practices in relation to data and to be informed of the kind of personal data held by the UC Now Communication.
In response, UC Now Communication may ask the Individual to provide certain details about himself/herself so that UC Now Communication can be ascertain the rightful ownership of the Personal Data under discussion. UC Now Communication is required to respond to such requests within 40 days and UC Now Communication will endeavor to do so where possible, but UC Now Communication may charge the Individual a reasonable fee for doing so as permitted by the PDPO.
Personal Data Officer
The person to whom
(1) Requests (a) for access to data or correction of data; (b) for general information regarding our policies and practices with respect to Personal Data; and (c) about the kinds of Personal Data that Now Communication hold and.
(2) General questions and complaints should be addressed as follows:
UC Now Communication Limited
Personal Data Officer
Address: 25F, Greenwich Centre, 260, King’s Road, North Point, Hong Kong.