POLICY AND PERSONAL DATA COLLECTION STATEMENTS

PRIVACY POLICY STATEMENT

Our Pledge

Mobile Link Technology Limited is committed to safeguarding the privacy of individuals with respect to personal data. We therefore make sure that our policies and practices in relation to the collection, use, retention, transfer and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486) under the laws of Hong Kong.

Use of Cookies

Your visiting of our Websites (including the pivothk Websites apart from those hyperlinked services which are subject to arrangements in their original Websites) may trigger our use of cookies. Cookies used (if any) in any part of our Websites will not be deployed for collecting personally identifiable information. If cookies are deployed for collecting personally identifiable information in the future, we will make separate notices accordingly. For your information, Cookies are small computer files that can be stored in web surfers' computers for the purposes of obtaining configuration information and analyzing web surfers' viewing habits. They can save you from registering again when re-visiting a Website and are commonly used to track your preferences in relation to the subject matter of the Website. You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but you may not be able to utilize or activate certain available functions in our Websites as the result.

Types and Use of Personally Identifiable Information Collected

Certain commercial services are provided through our Websites. For the purposes of the provision of Commercial Services via the said Websites, you may be required to provide your personally identifiable information including, but not limited to, your name, gender, age, identity document number, telephone number, fax number, home address, email address, credit/smart card information, bank account number, education level, occupation, household income, interests and favourite activities etc.
We may use the said personally identifiable information for the purposes set out under this statement and the Personal Data Collection Statement set out below (particularly those contained in points (i) through to (vi) in the second paragraph under II below). All references to "Personal Data" contained herein and in the Personal Data Collection Statement are to the said personally identifiable information provided for the purpose of the Commercial Services.

Direct Marketing

If you have once given us your Personal Data, you may receive from us or from our affiliated companies from time to time telephone calls, email and direct mailings containing promotional materials. If you do not want to receive them, please write to our Customer Service Officer at sales@pivothk.com. You may indicate your preference to the Customer Service Officer before providing us with your Personal Data.

Retention of the Information

If you are our subscriber or member, your Personal Data which you have given to us via the Internet or otherwise, during the currency of the subscription period or the membership, will be retained for a reasonable period after termination of your subscription or membership.

Disclosure of Information

Normally, we may share your Personal Data with, or transfer it to, Mobile Link Technology Limited, its subsidiaries and affiliated companies. For details, please refer to our Personal Data Collection Statement set out below. If you do not want to have your information disclosed to any third parties, please write to our Customer Service Officer.

Security

We use various encryption techniques to transmit via the Internet your Personal Data as well as personally identifiable information provided for the purpose of the provision of Commercial Services. Only our authorized personnel may access such Personal Data or information. Given the nature of the Internet, we cannot guarantee that the transmission is 100% secure.

Enquiries

If you have any questions or concerns regarding our Privacy Statement, or if at any time you need help related to our services, please contact:

E-mail: sales@pivothk.com

II. PERSONAL DATA COLLECTION STATEMENT

We shall keep your Personal Data confidential at all times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of Personal Data will be in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and are as set out in this Statement.

You agree that your Personal Data provided by you to us may be used and retained by us for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time: 

i. provisioning of the Commercial Services;
ii. marketing of goods and/or services by us, our agents or our subsidiaries, in relation to the Commercial Services;
iii. processing of any benefits to you arising out of or in connection with the Commercial Services;
iv. analyzing, verifying and/or checking of your credit, payment and/or status in relation to the provision of the Commercial Services;
v.  processing of any payment instructions, direct debit facilities and/or credit facilities requested by you; and
vi. enabling the daily operation of your account and/or the collection of amounts outstanding in your account in relation to the
     Commercial Services.
vii. enabling us to comply with our obligations to interconnect or other industry practices.

You further agree that we may disclose and transfer (whether in Hong Kong or abroad) to our agents, contractors, any telecommunications operators, any third party service provider, any third party collection agencies, any credit reference agencies, any security agencies, any credit providers, banks, financial institutions, our professional advisers and any other persons under a duty of confidentiality to us and any of our actual or proposed assignees or transferees of our rights with respect to you to use, disclose, hold, process, retain or transfer such Personal Data for the purposes mentioned above.

In addition, in accordance with your agreement with us, we may disclose and transfer your Personal Data to any company within Mobile Link Technology Limited, and/or any of their subsidiaries and any company in which the same has a direct or indirect interest or with which it is in joint venture or co-operation or their respective successors and assigns and to include that Personal Data in one or more databases held by us for the purposes mentioned above, the carrying out of market research, credit assessments, marketing of any goods and/or services by us and for the performance of procedures for comparing Personal Data with other information supplied by you to us for such purposes and for other purposes as shall be agreed between you and us or required by law from time to time. If you do not wish to receive marketing information from us with respect to any goods and/or services not related to or in connection with the Services, or for us to disclose, transfer or use your Personal Data for the purposes as set out in this paragraph, please write to us at the address below quoting your name, address and personal identity and other reference number(s).

Under and in accordance with the Ordinance, you have the right to

i.     check whether we hold any of your Personal Data
ii.    access your Personal Data held by us
iii.   require us to correct any Personal Data which is inaccurate;
iv.   ascertain our policies and practices (from time to time) in relation to Personal Data and the types of Personal Data held by us.

All requests for access to or correction of Personal Data or information regarding policies and practices and types of Personal Data held should be in writing and addressed to our Data Protection Officer whose contact details are set out in section I above.

Please note that the Statements may be amended from time to time. Notices regarding amendments will be posted at our home-page to inform you of the effective dates of the amendments. Amendments will not have retrospective effect.

Mobile Link Technology Limited