For Customers | Privacy Statement

Privacy Statement

This Privacy Statement sets out how we collect, use and protect the personal data (“Data”) that we may collect from or about you. It applies to all individuals whose Data may be handled, whether as controller or processor, by the HKT Group (“HKT”, “we”, “us” or “our”, being HKT Limited, its subsidiaries, affiliates and associated companies), including without limitation, customers of 1O1O, csl., NETVIGATOR, LiKE1OO, HKT Home Phone, eye, IDD 0060, Now TV, Now E, HKT Smart Living, HKT Smart Warranty, HKT Premier, HKT education, HKT Financial Services, HKT Merchant Services, HKT Fixed Line, HKT Business Broadband, HKT Enterprise Solutions, HKT SME, Star Home Call, Tap & Go, HKT Flexi, PayLater@, HKT Advance, GoWallet, Club Care, Club Shopping, Club Like, Club Travel, Club Hope, Club SIM, Hong Kong Yellow Pages, ypTrade, ypShop, uHub plus, one communications services, members of The Club and INSPIRE and users of My HKT.

Some of our subsidiaries, affiliates and associated companies have their own brand identity and their own separate privacy statements to provide relevant information for specific products and services they provide. You should refer to the relevant privacy statements as directed by those subsidiaries, affiliates and associated companies in relation to how they use your personal data.

Protecting Your Privacy

We are committed to protecting the privacy of your Data and handling your Data in a transparent and secure manner. This Privacy Statement sets out the information related to how your Data is being handled, your rights and how you can contact us if you want to know more.

Before collecting and processing your Data for the purposes as set out in this Privacy Statement, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use your Data in the manner as specified.

Collection of Your Data

1. What Types of Data We Collect

We may collect, process and hold a range of different Data about you. For the purposes of carrying on our business (collectively, “Service(s)”) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, we may collect Data such as, but not limited to:

personal particulars including name, date of birth, age, gender, ethnicity and nationality;
contact details including address, telephone number, mobile phone number and email address;
identification information including, details on your identification documentation such as Hong Kong Identity Card, passport, student card, staff card, driver’s licence, any other personal identifiers and biometric information including fingerprints and speech patterns;
Data that you have shared with third party social media platform operators including account login name, profile picture and contact details;
transactional information and payment details including credit card, debit card and other electronic banking Data;
account details or Data relating to Services registered with us including PIN, username, password, account numbers and service numbers;
device specific information including cookies, browser type, operating system, IP address, connection data, hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
information about how you use our Services including network usage and your location when you are using our Services;
health and biometric information which could be provided to us when you use our health and wellbeing related services;
credit and service history information to enable us to assess your eligibility for our offers of Services or to accommodate your request for transfer of Services or your account with us;
blockchain data including wallet addresses, public keys and transaction information;
website, mobile application and TV application usage data including user agent, domain name, referral URLs, location, phone contacts, browser and search history, online activities and statistics, log data, device and software characteristics and configurations;
employment information including education, profession, salary range, previous employment details, marital status, family and household information;
behavioural information including hobbies, preferences and leisure activities;
all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
any other Data as may be required by any members of HKT and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Services.

Where possible, we will indicate during Data collection whether specific Data is mandatory for us to enter into a contract with you or provide the Service to you. Failure to provide Data that is indicated as mandatory will prevent us from providing those particular Services to you.

2. How We Use Cookies

Some of our websites use cookies or similar tracking tools on your machine or device for us to, for example, personalise your user experience and/or maintain your identity across multiple webpages and/or Internet sessions. This Data may include, but is not limited to, relevant login and authentication details as well as Data relating to your activities and the preference configurations on your device and across our websites and mobile and TV apps. Our websites are set up to accept cookies by default. You can opt out of or delete historical cookies by changing the settings on your web browsers; however, if you do so, this may impact your usage of our website(s) and/or our mobile applications.

3. How We Collect Your Data

We collect your Data in several ways, including from:

you directly, for example, when you provide Data by phone or via email, attend our functions, complete an application form or agreement for one of our Services, or when you submit your Data through our websites, mobile or TV apps, or over any customer service hotlines or online chat sessions; or when you contact us with a query or request; or during the ordinary course of the continuation of our business relationship with you; or when we are legally required to do so;
third parties such as related entities, business partners, other customers, or your representatives with appropriate consent from or notification to you;
publicly available sources;
our own records of how you use our Services;
your visits on our websites, or mobile or TV apps; and/or
your participation in surveys or marketing promotions organised by us or on our behalf.

Occasionally, you may need to provide Data about other individuals (e.g. “Users” as defined in our Mobile Service Agreement) to us. If so, you should obtain those individuals’ authorisation and/or consent to such use, disclosure and transfer (or the extent to which such authorisation and/or consent was obtained). You should also advise them where they can find a copy of this Privacy Statement and that we can be contacted for further information as stated under the “How to Contact Us” section below.

4. What is Our Legal Basis for Processing Your Data

We will only process your Data when we have a legal basis to do so, for instance:

Contract performance – to perform our obligations under an existing contract you have entered with us;
Consent – to carry out the processing for the purposes you have given consent;
Legal obligation – to comply with applicable laws, court orders, government requests or other legal processes; and
Legitimate interest – to maintain the quality and availability of our business operation, by verifying your identity, contacting you, detecting fraud, ensuring the security of our systems and networks, etc.

Use of Your Data

1. How We Use Your Data

We may collect, retain and use your Data for the following purposes:

a. Services Administration

to verify your identity and facilitate your user account/profile creation;
to verify your eligibility for our offers of Services, games and/or promotions or other events;
to process your application to subscribe to our Services and loyalty programmes; to provide, activate and/or renew Services, loyalty programmes and My HKT that you may have subscribed for;
to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Services to you;

b. Optimisation, Personalisation and Marketing

to provide you with rewards, promotional benefits, updates, offers and invitation to events;
to promote and market our Services to you;
to perform research or analyses so that we may improve and optimise the Services and/or loyalty programmes that can be made available to you;
to conduct surveys and marketing, promotional, behavioural scoring for business operations and/or planning purposes;
to carry out behavioural, market and product analyses in order to generate statistical or actuarial reports (containing aggregated data that does not relate to any identified or identifiable individual);
to maintain, enhance and develop our products and service offerings;
to develop various services and products;
to distribute our publications and research materials as well as those of our business partners and counterparties;
to maintain and develop our systems and infrastructure, including testing and upgrading of these systems;

c. Legal and Administration

to conduct credit checks and detect fraudulent activities in compliance with the Anti-Money Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance (Cap. 615) and in relation to other compliance purposes;
to enforce our contractual rights and statutory rights;
to comply with our telecommunications licence(s) obligations in respect of interconnection arrangements with other telecommunications operators and related industry practices;
to evaluate your financial needs and insurance claims made by or against you, and to process claims involving you (including but not limited to making, defending, analysing, investigating, processing, assessing, determining, responding to, resolving or settling such claims); and
to comply with applicable laws in or outside Hong Kong as may be required by applicable government authorities, courts, law enforcement, or regulatory or investigation bodies, in relation to the supply of Services and/or loyalty programmes to you, including to assist in the prevention, detection of crime or possible criminal activities.

2. How We Share and Disclose Your Data

Your Data will be held by one or more members of HKT and will be accessible by employees of such member(s) consistent with the situations or for the purposes set out in this Privacy Statement or as otherwise indicated by prior notice to you or, where required, by obtaining your consent.

To provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose or make available your Data to organisations or parties outside of HKT (which may be within or outside of Hong Kong) (collectively, “Organisations”). Your Data is disclosed to these Organisations, who may also be able to determine the purposes and means for using your Data, for the key purpose of enabling us to supply our Services to you.

Parties, without limitation, to whom we may disclose and/or who may have access to your Data:

HKT Group and PCCW Group, our affiliates, overseas offices, assignees, transferees and representatives (including any actual or proposed participant, assignee or transferee of all or any part of our business or operations);
Business partners including without limitation Organisations providing administrative services; legal and compliance advisory services; operational and customer support services; process management services; banking, charge and credit card issuance, payment processing, transactions and financial services; telecommunications network operations services; mailing, courier, delivery, logistics and warehouse services; billing services; information technology services; cloud storage services; maintenance, installation and repair services; analytical, customisation, research, marketing and advertising services; business and corporate strategy services; reward and benefits redemption services; insurance, underwriting and insurance brokerage services; blockchain services; artificial intelligence and machine learning services; transfer, sale merger and acquisition services; investment and funding services; as well as agencies providing debt collection services, account management services, collection and security services, credit-reporting, fraud-checking and loss prevention services;
Government and regulatory authorities and other organisations, as required or authorised by law;
Professional advisors including our/ your authorised agents, representatives, accountant, auditors, insurers and/or legal advisors; and
Charitable or non-profit organisations, as required for fulfilment of our contractual obligations.

We take the required steps to ensure that the Organisations involved in these circumstances are bound by appropriate confidentiality and data privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing).

3. Direct Marketing (If Applicable)

We may, in compliance with applicable laws, rules, regulations and licence requirements, and, where applicable, with your consent use your Data (including without limitation name, contact information, phone number, residential/office address and email address and information about the Services you have purchased), for us (including PCCW Limited and its respective subsidiaries, affiliates and associated companies) and our respective dealers, suppliers, licensors, providers and/or business partners (collectively, “Service Providers”) to provide you with direct marketing content (pursuant to which we may or may not receive remuneration in return), including sending to you notices and/or updates about gifts, discounts, privileged offers, benefits and promotions related to Services offered by us and/or the Service Providers, including without limitation: TV, telecommunications, over-the-top (OTT) services, content services, mobile voice, SMS and data communications, IDD/roaming, Internet connectivity, cloud services, electronic/mobile payment, entertainment, secretarial services, personal assistant services and information services (such as weather, finance and news information), device accessories, mobile applications and software, computer peripheral, accessories and software (including notebooks, handsets, mobile devices and accessories, keyboards, security installations and mobile applications), reward, loyalty and privilege programmes, lifestyle, networking events, travelling, banking, alcohol, sports, music, gaming, transportation, household products, food and beverages, finance, stored value facilities, electronic wallets, cryptocurrencies, digital assets, insurance, wealth and asset management services and products, pensions, investments, brokering, financial advisory, credit and other financial services and products, education, health and wellness, beauty products and services, fashion and accessories, electronics, social networking, technology, e-commerce, digital assets and related offerings and services, logistics, retail, home and décor, media and high-end consumer products and services, shopping malls and outlets, property developments, public services, utility services, donations and contributions for charitable and/or non-profit making purposes.

We may carry out marketing through a variety of ways (such as in the form of a letter, bill insert/message, email, digital SMS, MMS, instant message, app push notification, targeted TV message, broadcast message on eye device, by telephone, social media or advertisements on websites or other means). We will honour your request to not use your Data for the purposes of direct marketing. You may opt-out from receiving direct marketing material and/or communications from the relevant Service, loyalty programmes and/or My HKT. At the same time, you may resume receiving the same (if you have previously opted-out of receiving such material and/or communications from the relevant Service, loyalty programmes and/or My HKT) by making a written request to our Group Data Protection Officer together with your registered name and service account number, registered telephone number or login name (as applicable).

4. Use of Artificial Intelligence and Big Data (If Applicable)

We may utilise artificial intelligence and big data, for the purpose of facilitating data analyses to optimise the Services that can be made available to you. We are committed to safeguarding your Data in the use of artificial intelligence and big data in adherence to our privacy protection standard, including but not limited to:

HKT Group and PCCW Group, our affiliates, overseas offices, assignees, transferees and representatives (including any actual or proposed participant, assignee or transferee of all or any part of our business or operations);
we only utilise such technology when we have obtained your consent or have a legal basis to do so;
we only use personal data that is appropriate and necessary for the purpose;
we employ adequate data security measures throughout the entire data lifecycle; and
we apply the same standards to any third party involved.

Export of Data

At times it may be necessary and/or prudent for us to transfer your Data to places outside the jurisdiction in which the Data was initially located, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data was collected. In the event that we do transfer your Data cross-border, appropriate safeguards will be put in place in compliance with the prevailing requirements of applicable data protection regulations.>

Safety of Your Data

All required efforts are made to ensure that any Data held by us is stored in a secure and safe place and is accessible only by our authorised employees or other Organisations referred to in this Privacy Statement.

When we pass your Data to third party Organisations for them to process, we seek to ensure that they have appropriate security measures in place to keep your Data safe and to comply with applicable principles in relation to data protection.

Retention of Your Data

We will retain your Data in accordance with our internal policies. Our policies comply with applicable data privacy and protection regulations and cover the following principles:

Data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
Data is securely purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.

Links

Our websites (including but not limited to www.hkt.com, https://www.hktchina.com, www.1010.com.hk, www.hkcsl.com, www.netvigator.com, www.like100.hk, www.hkt-eye.com, www.nowtv.now.com, www.nowe.com, www.yp.com.hk, www.yptrade.com, www.ypshop.com.hk www.uhub.com, https://smartliving.hkt.com, www.hkt-homephone.com, www.hktpremier.com, www.hkteducation.com, www.hktfinancialservices.com, www.hktmerchantservices.com, www.tapngo.com.hk, www.hktflexi.com, https://www.pay-later.com.hk, www.hktcare.com, https://clubcare.theclub.com.hk, https://shop.theclub.com.hk, www.clublike.com.hk, www.clubtravel.com.hk, https://trip.clubtravel.com.hk, www.clubhope.com.hk, www.clubsim.com.hk, www.theclub.com.hk, www.cs.hkt.com, www.biznetvigator.com and https://www.hkt-enterprise.com) and mobile and TV applications (if any) may contain links to other websites, webpages and mobile and TV applications operated by third parties. We have no control over the content of the linked websites, webpages and mobile and TV applications or the way in which the operators of those websites, webpages and mobile and TV applications deal with your Data, and are not responsible for the content of such third party websites, webpages or mobile and TV applications. You should review the privacy policy of such third party websites, webpages and mobile and TV applications to understand the ways in which your Data may be used by those third parties.

Your Rights

We are committed to safeguarding your Data and ensuring that you may exercise your rights. In particular, you have the following rights:

To request access to your Data that we hold. We may apply an administrative charge for providing you with access to your Data in response to such request;
To request correction to your Data that we hold;
To request us to stop using your Data for direct marketing; and
To make a complaint to a data protection authority about how we are using your Data.

If you are a user of My HKT, you may exercise your right of access and correction by logging on to your My HKT account where you will be able to view and correct the Data held by us about you. If you are not a user of My HKT, you may write to our Group Data Protection Officer at the details stated in the “How to Contact Us” section below.

If you wish to exercise any of your rights, or would like to enquire about these rights, you may contact us in the manner as set forth under the “How to Contact Us” section.

You may decline to share Data with us and/or withdraw any consent which you may have provided, in which case, we may not be able to provide you with some of our Services.

How to Contact Us

For all issues and enquiries regarding our obligations and compliance under applicable data protection regulations, and any request for access to, correction or deletion of your Data, please contact us in writing:

Group Data Protection Officer
HKT Limited

Mailing address: GPO Box 9896, Hong Kong
or
email: privacy@pccw.com

You may also contact us to raise an issue regarding our handling of your Data.

Changes to this Privacy Statement

This Privacy Statement may be amended from time to time and all handling of Data will be governed by the most recent version of this Privacy Statement, available on our website at www.hkt.com/legal/privacy.html. If there is any inconsistency between the English and Chinese versions of the Privacy Statement, the English version will prevail.

This Privacy Statement was last updated on 13 December 2024.