1. What information do we collect?We may collect and process the following data about you:
- your name, your phone number and your location data
- details about the device you use to access MobiJuce, which may include your IP address or other unique device identifiers;
- cookies information as set out in section 7 below;
- any information available through other databases that you grant us access;
- any other information provided by you pursuant to your use of MobiJuce; and
- if you contact us, we may keep a record of that correspondence.
2. What do we use your information for?The purposes for our collection of information and data about you on MobiJuce include the following:
- to verify your identity;
- to provide the MobiJuce services to you including processing any purchases and payments;
- to notify you about changes to MobiJuce or respond to any communication or request from you;
- to monitor the use of MobiJuce;
- to investigate any complaints or potential breaches of the service;
- to provide you with marketing and promotional materials for your enjoyment of benefits as users of MobiJuce;
- to identify those of you who have enjoyed benefits as users of MobiJuce by receiving and using marketing and promotional materials;
- to design and provide products and services to you in relation to the above purposes;
- to compile aggregate statistics about you and to analyze MobiJuce and service usage;
- matching (as defined in the Ordinance) your personal data with other data collected for other purposes and from other sources including third parties in relation to the provision of goods and services to you; and
- to facilitate our use of your personal data for purposes relating to the provision of services offered by us and the marketing services, special events and/or promotions of us and/or our partners and clients.
3. Do we disclose any information to outside parties?We generally only permit our duly authorized staff to access your personal information and data, and we will not release such personal information and data to any third parties save and except for the following circumstances:
- where the information and/or data is disclosed and/or transferred to any third-party suppliers or external service providers who have been duly authorized by us to use such information and/or data and who will facilitate the services on MobiJuce, under a duty of confidentiality;
- where the information and/or data is disclosed and/or transferred to our agents, affiliates or associates who have been duly authorized by us to use such information and/or data;
- where the information and/or data is disclosed and/or transferred to any other party in connection with a sale or proposed sale of all or part of our business or portfolio of products or other assets;
- to credit reference agencies, debt collection agencies, fraud detection and/or prevention agencies;
- to any relevant public authority or law enforcement agency, including for example where we suspect you have committed a criminal offence or we suspect fraud where required by applicable law, regulation or legal proceedings;
- in order to enforce or apply the terms and conditions of MobiJuce or any other agreement to which you and we are a party, as applicable; and
- where we deem necessary in order to maintain and improve the MobiJuce services.
You should take care when using any MobiJuce social networking features since the information you choose to make available can be seen by other users in the selected group. We do not monitor the use of such features in the normal course of business although we reserve the right to do so at our discretion.
At times, it may be necessary and/or prudent for us to transfer certain personal information and/or data to our companies or service providers outside of Hong Kong SAR or such other countries and jurisdictions where MobiJuce operates. This may happen if our servers or suppliers and service providers are based overseas or if you use MobiJuce’s services and products while in such overseas countries and jurisdictions. We will take steps to ensure that your personal information and/or data is used by such overseas third parties in accordance with this policy and that such overseas third parties observe strict confidentiality and data protection obligations.
4. Do we use any information for direct marketing?
We and our affiliates may send you marketing messages to your telephone number if you have given us consent, or if you have not registered with any applicable do-not-call registry (or its equivalent) or the sending of such messages is permissible under applicable laws and regulations.
We and our affiliates may from time to time send to you newsletters, promotional materials and marketing materials based on the personal information and data that you have provided to us. We may use your information and data in direct marketing and we require your consent (or an indication of no objection) for that purpose.
The following classes of services, products and subjects may be marketed:
- Mobile charging or related services;
- special events hosted by us and/or our affiliates for you and MobiJuce members, including but not limited to competitions and social gatherings;
- reward, loyalty or privileges programs and related products and services;
- special offers including coupons, discounts, purchase offers and promotional campaigns;
- products and services offered by our affiliates and advertisers (the names of such affiliates and advertisers can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); and
- donations and contributions for charitable and/or non-profit making purposes.
The above products, services and subjects may be provided or solicited by us and/or our affiliates, third party service providers providing the above products, services and subjects and charitable or non-profit making organizations (“Outside Parties”). We may provide your personal information and/or data to Outside Parties for use by them in marketing the above products, services and subjects and we require your written consent (or indication of no objection) for that purpose.
You may opt out from receiving such marketing communications at any time by sending an email to us at email@example.com. Any such request should also clearly state the details of personal data in respect of which the request is being made.
Please note that after opting out, you may still receive non-marketing messages, such as product updates and service notices as permitted under applicable local laws and regulations.
5. Can I access and correct my personal data?In accordance with the terms of the Ordinance and subject to the exemptions specified in the Ordinance, you have the right to:
- check whether we hold personal data about you and to receive copies of such data;
- require us to correct any personal data relating to you which is inaccurate; and
- ascertain our policies and practices in relation to personal data and to be informed of the kind of personal data held by us.
In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for processing a data access request.
Requests for access to personal data, correction of personal data, information relating to the kind of data held and to stop receiving direct marketing, may be made by contacting our Data Privacy Officer by email at firstname.lastname@example.org or by post at MobiJuce, Level 22, Ho Lee Commercial Building, 38-44 D’Aguilar St, Central, Hong Kong. Any such request should also clearly state the details of personal data in respect of which the request is being made.
6. How do we protect your personal data?
We have adequate measures to protect your personal information from unauthorized access, accidental loss or destruction. Where we have given you (or you have chosen) a password which enables you to access certain parts of the MobiJuce service, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secured. While we will do our best to protect your information and data, we cannot guarantee the security of data transmitted to MobiJuce’s service; any transmission is at your own risk. Once we have received your information and data, we will use strict procedures and security features to try to prevent unauthorised access.
7. Retention of Personal Data
Once we have obtained your personal information and/or data, it will be maintained securely in our system. Subject to legal requirements and our internal policy, your personal information and/or data may be retained by us after deactivation of the relevant service until you request us in writing to erase your personal information and/or data from our database. We will retain your information for only as long as there is a business or legal need.
8. Links to Third Party Websites
Occasionally, at our discretion, we may include or offer third party products or services on MobiJuce. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of MobiJuce and welcome any feedback about these sites.