Privacy Policy

COMBA TELECOM SYSTEMS HOLDINGS LIMITED
PERSONAL DATA (PRIVACY) ORDINANCE - PRIVACY POLICY STATEMENT

GENERAL

This policy statement provides information on the obligations and policies of Comba Telecom Systems Holdings Limited, its subsidiaries, affiliates, and associated companies (the "Company") under the Hong Kong SAR Personal Data (Privacy) Ordinance 1995 - Cap.486 (the "Ordinance"). Although this policy specifically addresses the Company's obligations in respect of the laws of the Hong Kong SAR, the Company believes the principles embedded in the Ordinance are equal to any in the world in respect of the protections they provide to an individual. As such, the Company undertakes to apply, where practicable, those principles and the processes set out herein to its operations globally. Where the Company's operations are subject to privacy legislation other than that of Hong Kong SAR, then this policy shall be applied so far as practicable and consistent with such local legislation. For further details on the Company's compliance with the Ordinance and any other privacy legislation, please contact the Company's Privacy Compliance Officer at the address listed below. Throughout this policy, our use of the term "personal data" has the meaning ascribed to it by the Ordinance.

OUR CORPORATE POLICY

The Company shall fully comply with the obligations and requirements of the Ordinance. The Company's officers, management, and members of staff shall, at all times, respect the confidentiality of and endeavor to keep safe any and all personal data collected and/or stored and/or transmitted and/or used for, or on behalf of, the Company. The Company shall endeavor to ensure all collection and/or storage and/or transmission and/or usage of personal data by the Company shall be done in accordance with the obligations and requirements of the Ordinance. Where an individual legitimately requests access to and/or correction of personal data relating to the individual, held by the Company, then the Company shall provide and/or correct that data in accordance with the times and manner stipulated within the Ordinance.

STATEMENT OF PRACTICES TYPES OF PERSONAL DATA COLLECTED

For the purpose of carrying on the Company's business, including registration and administration of the Company's telecommunications and related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:

(a)

Your name;

(b)

Service installation address, correspondence address, and/or billing address;

(c)

Account details, including account numbers, service numbers, or user accounts;

(d)

Payment details, including credit card and banking information;

(e)

Contact details, including contact name and telephone number or email address; or

(f)

Information for the verification of identity, including identification type and identification number.

In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product is dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:

(a)

Your age;

(b)

Gender;

(c)

Salary range and employment details;

(d)

Education and Profession;

(e)

Hobbies and leisure activities;

(f)

Other related products and services subscribed to; and

(g)

Family and household demographics.

In support of the telecommunications and other services offered by the Company, information may be automatically collected relating to those services so we may perform accurate reporting and administration of your accounts such as, but not limited to, call/connection time, duration, origin, and destination.

The Company's web servers may also collect data relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server's usage so that we may better meet the demands and expectations of visitors to our sites. This type of data may include, but is not limited to:

(a)

The browser type and version;

(b)

Operating system; and

(c)

The IP address and/or domain name.


Some of the Company's web sites may place a "cookie" on your machine; for example to provide personalised services and/or maintain your identity across multiple pages within or across one or more sessions. This information may include, but is not limited to, relevant login and authentication details as well as information relating to your activities and preferences across our web sites. Under certain circumstances, telephone calls made to our order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. Unless expressly indicated at the time of calling, such recordings are NOT personal data of the caller and therefore, in respect of the caller, are not subject to the various provisions of the Ordinance and the caller has no rights and/or claims; either statutory, contractual or tortious, over or to such data. At all times, every care is taken to protect such recordings from inadvertent and/or unauthorized access.

ACCURACY OF PERSONAL DATA

Where possible, we will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate the data provided against pre-existing data held by the Company. In some cases, as per the requirements of the Ordinance, the Company is required to see original documentation before we may use the personal data such as with Personal Identifiers and/or proof of address. Although we do not currently provide online access to and correction of personal data held by the Company, we fully comply with the "Rights of Access and Correction" obligations of the Ordinance. Please refer to the section titled "Access and Correction of Personal Data" below for details on how you can obtain and correct any personal data relating to you that we may hold.

RETENTION OF PERSONAL DATA

The Company will destroy any personal data it may hold in accordance with our internal retention policy. The policy states that:

(a)

Personal data will only be retained for as long as is necessary to fulfil the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and

(b)

Personal data are purged from the Company's electronic, manual, and other filing systems in accordance with specific schedules based on the above criteria and the Company's internal procedures.

DISCLOSURE OF PERSONAL DATA


All personal data held by the Company will be kept confidential but the Company may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:

(a)

Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with the Company;

(b)

Any person or company who is acting for or on behalf of the Company, or jointly with the Company, in respect of the purpose or a directly related purpose for which the data was provided;

(c)

Any other person or company who is under a duty of confidentiality to the Company and has undertaken to keep such information confidential, provided such person or company has a legitimate right to such information; and

(d)

Any financial institutions, charge or credit card issuing companies, credit information or reference bureaux, or collection agencies necessary to establish and support the payment of any services being requested.

Personal data may also be disclosed to any person or persons that have a right under the Ordinance to gain access to such information provided they are able to prove their authority to access such information. For example, if the Company were served with a court order demanding certain customer information then the Company would disclose the information to the duly appointed officer of the court or such other persons as the court orders.

TRANSFER OF PERSONAL DATA OUTSIDE OF HONG KONG

At times it may be necessary and/or prudent for the Company to transfer certain personal data to places outside of the Hong Kong SAR in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the Ordinance.

SECURITY OF PERSONAL DATA

Physical records containing personal data are securely stored in locked areas and/or containers when not in use. Computer data are stored on computer systems and storage media to which access is strictly controlled and/or are located within restricted areas. Access to records and data without appropriate management authorization are strictly prohibited. Authorizations are granted only on a "need to know" basis that is commensurate with an individual's Company responsibilities and their training. Records of the Company are under the control of assigned information officers who are responsible to ensure the transfer of or access to information is legitimate and complies with the Ordinance. Audit records may be produced to validate data modifications in order to verify the data's integrity. There may be violations logging processes for investigation of any unauthorized attempt to access information. Encryption technology, such as SSL, may be employed for the transmission of data collected online.

ACCESS AND CORRECTION OF PERSONAL DATA

Under the terms of the Ordinance, individuals have the right to:

(a)

Check whether the Company holds any personal data relating to them and, if so, obtain copies of such data;

(b)

Require the Company to correct any personal data relating to them which is inaccurate for the purpose for which it is being used; and

(c)

Ascertain the Company's policies and practices in relation to personal data, which are those policies and practices set out in their entirety herein.

The Company will, upon satisfying itself of the authenticity and validity of the access request, make every endeavor to comply with and respond to the request within the period set by the Ordinance.

An individual may exercise their right of correction by:

(a)

Writing to the Company's Privacy Compliance Officer at the address listed below, specifying the data which they believe to be incorrect, the reason they believe it is incorrect, and the applicable corrections; and

(b)

Providing "proof of identity" verifying that the individual making the request is authorized to request such corrections.
The Company will, upon satisfying itself of the authenticity and validity of the correction request, make every endeavor to comply with and respond to the request within the period set by the Ordinance.

DIRECT MARKETING

In accordance with the requirements of the Ordinance, the Company will honor an individual's request not to use his or her personal data for the purposes of direct marketing. Should you wish not to receive direct marketing material from the Company, please write to the Company's Privacy Compliance Officer at the address listed below. Any such request should clearly state details of the personal data in respect of which the request is being made. Specifically, we request that you include the corresponding Company assigned account numbers which are printed on the Company's statements/invoices. Please also state clearly the authority under which you are authorized to make such a request. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for marketing purposes.

RECRUITMENT AND EMPLOYMENT RECRUITMENT

During the recruitment process, job applicants may be required to provide sufficient personal data so that the Company may, as appropriate and/or applicable:

(a)

Assess the applicant's suitability for the position being applied for;

(b)

Assess the applicant's suitability for other positions the Company may have available;

(c)

Determine preliminary remuneration and benefit packages;

(d)

Verification of credentials and/or experience; and

(e)

Perform security vetting and/or integrity checking

At a minimum, such personal data will include:

(a)

The applicant's name and contact details, including address and telephone number(s);

(b)

Previous employment and relevant experience; and

(c)

Education and relevant training.


Additional information may also be required dependant on the nature of the position being applied for. The applicant is responsible for ensuring all personal data they provide is accurate and complete. The provision of inaccurate information or the withholding of requested information may prevent the Company from making an offer of employment, invalidate such offer if the inaccuracy or omission is discovered after an offer has been made, or lead to termination of employment if the inaccuracy or omission is discovered after employment has commenced. The personal data so provided may be transferred to persons within the Company who are involved in the assessment of the applicant's suitability for the position applied for and/or other positions, which may be, or may become, available within the Company. The data may also be transferred to other third parties, such as investigation agencies, as are necessary to satisfy the purposes set out above. The Company shall retain the personal data of unsuccessful applicants for future recruitment purposes for a period of two years from the date of application. The personal data of successful applicants shall be retained for the duration of their employment by the Company and as described below under the heading of "Employment, Including Post Employment". In respect of the Company's practices regarding matters not directly addressed in this section "Recruitment", the practices, and procedures set out in the preceding sections of this Privacy Policy Statement shall apply.

EMPLOYMENT, INCLUDING POST EMPLOYMENT

In the course of employment by the Company, personal data of employees and their families, as appropriate, will be collected and used on an ongoing basis for various Human Resource purposes including but not limited to; administering staffing, performance management, training, career development, salary and benefits administration, communication, medical benefits, provident fund administration, insurance, taxation, welfare and providing information in compliance with legal requirements. It will be transferred to those internal departments, intra-company, and/or to other third parties as is necessary for the purposes. The Company retains certain personal data of employees when they cease to be employed by the Company. Such data are required for any residual employment-related activities of the former employee including, but not limited to:

(a)

The provision of job references;

(b)

Processing applications for re-employment;

(c)

Matters relating to retirement benefits; and

(d)

Allowing the Company to fulfil contractual or statutory obligations.


Further details regarding the Company's polices and practices in respect of its handling of personal data relating to its employees, including post employment, are included in the Company's Human Resources Policies and Staff Handbooks. They are also available to the Company's employees from either the Company's Privacy Compliance Officer or directly from their respective Human Resources representative.

THE COMPANY'S PERSONAL DATA (PRIVACY) ORDINANCE CONTACT DETAILS All enquiries regarding the Company's compliance with its obligations under the Ordinance should be in writing to:

COMBA TELECOM SYSTEMS HOLDINGS LIMITED

611 East Wing,No.8 Science Park West Avenue

Hong Kong Science Park

Tai Po,Hong Kong

Tel: +852 2636 6861    Fax: +852 2637 0966 / +852 2116 6055

Or via email to:

This email address is being protected from spambots. You need JavaScript enabled to view it.

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Note 1:

The Company will honor requests made either on its own form, "Personal Data (Privacy) Ordinance 1995 – Comba Telecom Systems Holdings Limited Data Subject Access Request", or on that prescribed by the Hong Kong SAR Privacy Commissioner for Personal Data (form no.: OPS003), which is available from the Privacy Commissioner's Office, provided all mandatory data as specified in the Comba Telecom Systems Holdings Limited form has been supplied.

(If there is any inconsistency or conflict between the English and Chinese versions, the English version shall prevail.)