UWAI is committed to protecting and respecting your privacy.
1. Information collection
1.1 In order to provide a better service to you, we receive and store any information you enter on our websites, mobile applications, and related applications (the “Website”), or you give us in any other way. This includes information that can be used to identify you as an individual or contact you directly (“Personal Information”).
1.2 We may receive, store and process the following information, including Personal Information, about you that you make available to us:
(a) information that you provide by filling in forms on our Website. This includes, but is not limited to, information provided at the time of registering an account to use our Website, subscribing to our service, updating the details of your account, posting material or requesting further services. We may also ask you for information at other times, for example in connection with a promotion or when you report a problem with our Website;
(b) if you contact us, we may keep a record of that communication;
(c) we may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
(d) details of transactions you carry out through our Website and of the fulfilment of your orders;
(e) details of your visits to our Website and the resources that you access;
(f) linking your account on a third-party websites (for example, WeChat or Facebook) to your UWAI account, in which we will obtain any Personal Information you have provided to that third-party website, to the extent allowed by your settings with that third-party website and authorised by you.
1.3 We also may receive, store and process the following information, including Personal Information, when you access or use our Services, including, but not limited to:
(a) mobile data including different types of information about your location, including general information (for example, IP address, zip code) and more specific information (for example, GPS-based functionality on mobile devices used to access the Services or specific features of our Website).
(b) contact information such as your email address, phone number or Facebook account ID to create or customize your account or to enable certain account features, for example, for login verification. If you provide us with your email address or phone number, you agree to receive emails to that email address or text messages to that phone number, as the case may be. We may use your contact information to send you information about our Services, to market to you, and to help prevent spam, fraud, or abuse.
(c) log data including information that is automatically recorded by our servers whenever you access or use the Services, regardless of whether you are registered with UWAI or logged in to your UWAI Account, such as your IP Address, the date and time you access or use the Services, the hardware and software you are using, referring and exit pages and URLs, the number of clicks, device event information, pages viewed and the order of those pages, and the amount of time spent on particular pages.
(i) Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
(ii) Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
(iii) Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
(iv) Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
1.4 We only retain Personal Information for so long as it is necessary. Information may be archived as long as the purpose for which the information was used still exists.
2. Uses made of the information
2.1 The purposes for which information may be used by us in and outside the Hong Kong Special Administrative Region include:
(a) to enable you to access and use our Services and our Website;
(b) ensuring that content from our Website is presented in the most effective manner for you, for your computer and/or device as well as other users and their respective computers and/or devices;
(c) providing you with alerts, newsletter, education materials or information that you requested or signed up to;
(d) carrying out our obligations arising from any contracts entered into between you and us;
(e) allowing you to participate in interactive features of our service, when you choose to do so;
(f) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
(g) complying with laws and regulations applicable to us or any of our affiliates in or outside the Hong Kong Special Administrative Region;
(h) legal proceedings, including collecting overdue amounts and seeking professional advices;
(i) researching, designing and launching services or products including seminars/events/forums;
(j) promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in Clause 2.2 below);
(l) to prevent potentially prohibited or illegal activities; or
(m) purposes directly related or incidental to the above.
2.2 We intend to use your data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
(a) your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing;
(b) the following classes of services, products and subjects may be marketed in direct marketing:
(i) services and products related to our Website and/or our affiliates (including marketing affiliates programs we are a part of);
(ii) reward, loyalty or privileges programmes, promotional offers and related services; and
(iii) invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
(c) We may conduct direct marketing via email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
3. Disclosure of your information
We will keep the personal data we hold confidential but may provide information to:
(a) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;
(b) our overseas offices, affiliates, business partners and counterparts (if any);
(c) persons under a duty of confidentiality to us;
(d) persons to whom we are required to make disclosure under applicable laws and regulations in or outside the Hong Kong Special Administrative Region; or
(e) actual or proposed transferees or participants of our services in or outside the Hong Kong Special Administrative Region.
4.1 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted using TLS technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
4.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6. Data transfers
We may hold your data on servers from time to time. We may also transfer your data to our overseas offices or to any people listed at Clause 3 above, who may be located in or outside of the Hong Kong Special Administrative Region.
7. Your consent and rights
7.1 By using our service, making an application or visiting our Website, you consent to the collection and use of your information and other activities as outlined in this policy.
7.2 Under the Hong Kong Personal Data (Privacy) Ordinance (the “Ordinance”), individuals have the right:
(a) to check whether we hold personal data about you and to access such data;
(b) to require us to correct as soon as reasonably practicable any data relating to you that is inaccurate;
(c) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and
(d) to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.
7.3 You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to: firstname.lastname@example.org.
7.4 In accordance with the terms of the Ordinance, we have the right to and may charge a reasonable fee for processing any data access request.
7.5 In the event that you wish to access or amend your Personal Information and data, the Company may request you to provide personal details in order to verify and confirm your identity. A HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to a user’s request within ten (10) business days of his or her request and will endeavor to do so wherever possible.
Governing law and jurisdiction
Last updated: 1 June, 2017