DCConnect Global Limited (“the Company”)                                          26 August 2021

Privacy Policy 

1.      Privacy Statement

1.1    The purpose of this Privacy Policy Statement is to set out the policies and practices of the Company’s commitment to protecting personal data privacy in accordance with the requirements of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) where applicable.

         Before using and providing 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.

1.2    This Privacy Statement applies to all contracts, services and websites, including our API , whether visited by job applicants, customer or supplier representatives, or anyone else offered by DCConnect Global Limited (“DCCONNECT”, “we”, “us” or “our”). This Privacy Statement also applies to ‘prospective customers’ that have not yet created any account on our websites or API. It sets out how we collect, use, manage and protect the personal data or information (“Data”) that we collect from or about you. It also explains your rights regarding our use of your information, how long we keep your information and how to contact us.

2.      Your Data

2.1    We may collect, use, and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, and the billing and charging of our products and services (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, you may be requested to provide Data such as, but not limited to:

1. the name, date of birth and other details documented on your Identity Card or other legal identity card, travel document, student card and/or driver’s licence;
2. contact details including name, address, phone number, mobile telephone number and/or email address;
3. Data that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details);
4. payment details including credit card, debit card and other electronic banking Data;
5. account details or Data relating to Services registered with us including the relevant PIN, username or password, account numbers and/or service numbers;
6. device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
7. information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
8. information that allows us to identify you for verification purpose including biometric information like your fingerprints and voice pattern;
9. your credit and service history to enable us to assess your eligibility to our offers of Services or to accommodate your request for transfer of Services or your account with us;
10. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet (from which we can infer your generalized location), your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
11. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Websites (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, videos watched, and mouse-overs), and methods used to browse away from the page
12. 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; and
13. any other Data as may be required by any members of DCCONNECT 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.

2.2    In some instances, where required by law to do so, we may seek your consent to process the following types of “Special Data” to us so that we may further improve our Services and/or better tailor the type of information or content that we present to you:

1. age;
2. gender and ethnicity;
3. marital status;
4. salary range and employment details;
5. education and profession;
6. hobbies and leisure activities;
7. the Services that you have subscribed for; and
8. family and household demographics.

2.3    Provision of the Special Data mentioned immediately above is optional although, where the requested Service is a personalised Service or provision of a product is dependent upon your provision of all requested Data, failure to provide the requested Data may prevent us from providing those particular Services to you.

2.4   Occasionally, you may need to provide Data about other individuals (e.g. “Users”) to us. If so, we may require you to confirm your compliance including confirming that you have informed those individuals of the use, disclosure and transfer of Data from you to us and from us to third parties and possible disclosure of the individual’s details by us to you; and that you have obtained 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 that we can be contacted for further information at the details stated under the “How to contact us” section below.

2.5    Data supplied by you will be held by one or more members of DCCONNECT and will be accessible by employees of such member(s) and authorised third parties (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.

3.      How we collect Data

         We collect Data in a number of ways, including from:

1. 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 API apps 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;
2. each of your visits to the Website. This is enabled by various common tracking technologies like cookies (small files stored on an individual’s browser or computer hard drive to optimize the individual’s interaction with a website) and web beacons (tiny graphics files containing unique identifiers to recognize someone as having received an email or visited our website before).  Some cookies are purely technical and necessary for the Website to work properly and others track user behaviour in an aggregated anonymous fashion. However, where cookies are designed to track your behaviour in a personally identifiable manner, they will only be deployed on your device if you consent thereto during your first visit to our Website;
3. third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;
4. publicly available sources;
5. our own records of how you use our Services; and/or
6. your visits on our websites, or mobile or API apps (see “Privacy Data” section below)

4.         Privacy Data

4.1       To better serve your needs and preferences, our web servers may collect Data relating to your website, device or app activity. We may also collect aggregated, anonymous, statistical data on the server’s usage so that we may better cater to the behaviour of users of our websites and mobile apps. This type of Data may include, but is not limited to:

1. browser type, version and user agent;
2. operating system;
3. IP (Internet Protocol) address and/or domain name;
4. connection data, statistics on page views and/or referral URLs;
5. device ID, location and phone contacts;
6. videos watched or searched for;
7. links or images clicked on;
8. cookies and/or browser, app or web server log data; and
9. device and software characteristics and/or configuration.

4.2       Some of our websites use cookies or similar tracking tools on your machine or device in order 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 initially set up to accept cookies. You can opt-out of or delete historical cookies by changing the settings on your web browsers; however, if you do so, you may find that certain features on our website and/or our app do not work properly.

5          How we use your Data

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

1. to verify your identity;
2. to process your application to subscribe to our Services and loyalty programs;
3. to carry out matching procedures;
4. to conduct credit checks and detect fraudulent activities as required by law;
5. to enforce our contractual rights;
6. to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Services to you;
7. to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
8. to maintain, enhance and develop our products and service offerings;
9. to develop financial services and products;
10. 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);
11. to comply with our telecommunications licence obligations in respect of interconnection arrangements with other telecommunications operators and related industry practices;
12. to comply with applicable laws 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 programs to you, including to assist in the prevention, detection of crime or possible criminal activities; and
13. to distribute our publications and research materials as well as those of our business partners and counterparties.

6          Our legal basis for using your Data including how we disclose your Data

6.1      We have a legitimate interest in properly administering the Services.  In addition, our use of your personal data may be necessary for the performance of the Services that you have requested.  In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organisations or parties outside of DCCONNECT (collectively, “Organisations”). Your Data is disclosed to these Organisations for the strict purpose of enabling us to supply our Services to you.

6.2       In some circumstances as mentioned above, we may need to ask for your consent to use your Special Data where required by law to do so.

6.3       In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to the following third parties:

1. data processors, who are service providers and suppliers who provide: (i) services relates to customer enquiries; (ii) courier, delivery, logistic and warehouse services; (iii) mailing operations; (iv) billing and debt-recovery functions; (v) information technology services; (vi) installation, maintenance and repair services; (vii) marketing, advertising and telemarketing services; (viii) market research; (ix) customer usage and behavioural analysis; (x) process management; (xi) after sale services; (xii) surveys; (xiii) website usage analysis; (xiv) cloud storage services; and (xv) network connectivity services, including international and local connectivity service of any technology types such as IP, DWDM, IPLC, satellite, etc.
   1. your authorised representatives and/or your legal advisers when requested by you to do so;
   1. for the purposes of providing administrative, payment, collection, business, legal and/or operational support to the following parties: (i) credit-reporting and fraud-checking agencies; (ii) financial institutions, charge or credit card issuing companies, credit providers, credit bureau, collection agencies or security agencies; (iii) telecommunications network operators; and (iv) our professional advisers, including our accountants, auditors, lawyers and insurers;
   1. organisations who manage our business and corporate strategies, including those involved in a transfer or sale of all or part of our assets or business and those involved in managing our corporate risk and funding functions;
   1. to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business;
   1. companies in the same group as us;
   1. local and foreign regulators, governments, law enforcement authorities, advisors, courts and tribunals; and
   1. other third parties, with your consent.

Some of these third parties are based outside the European Economic Area (the “EEA”). If we do transfer your information outside the EEA we will take appropriate steps to protect that information which include one of the following: (i) transferring to third parties in jurisdictions that the EU Commission has determined offers adequate protection for your information’ (and information relating to Adequacy Decisions made by the European Commission are available; (ii) entering into an agreement with the third party, which includes clauses that the EU Commission has determined offers adequate protection for your information; or (iii) transferring to third parties that have agreed to comply with schemes approved by the European Commission to protect your information.   

7          Transfer of Data

At times it may be necessary and/or prudent for us to transfer your Data, for instance, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data were collected. In the event that we do transfer your Data, we will do so in compliance with the prevailing requirements of the GDPR where applicable.

8          The safety of your Data is important to us

            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.  Some of the people we share your Data with may process it overseas.  You can contact us for more information about the safeguards we use to ensure that your Data is adequately protected in these circumstances.

            Our security measures include, but are not limited to:

1. educating our staff as to their obligations with regard to personal information;
   1. encrypting data sent from your computer or your mobile device to our systems during internet transactions and customer password transmitted across internet or application (“app”);
   1. employing firewalls, intrusion detection systems and virus scanning tools to protect against unauthorized persons and viruses from entering our systems;
   1. using dedicated secure networks or encryption when we transmit personal data for purposes of outsourcing;
   1. ensuring security controls in place to protect against unauthorized access of personal data maintained in the Company’s premises as well as loss of personal data obtained in off-site venue for marketing activities.
   1. For personal data transferred to data processors, the Company must adopt contractual or other means to prevent such data from unauthorized or accidental access, processing, erasure, loss, and use.

9          Retention of your Data

            We will retain your Data in accordance with our internal policies. Our policies are in compliance with the GDPR where applicable, and cover the following principles:

1. 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
2. Data are purged from our electronic, manual, and other filing systems based on the above criteria and our internal procedures.

10        Your right to access, correct and delete Data

10.1     We take all reasonable precautions to ensure that the Data we collect, use and disclose is accurate, complete and up to date. However, the accuracy of that Data depends to a large extent on the Data you provide. You have a right to request access to, and correction of, your Data and we recommend that you:

1. let us know if there are any errors in your Data; and
2. keep us up to date with changes to your Data.

10.2     If you wish to access or amend any of your Data we hold, or request that we delete (only applicable where the rights to erasure is required by law) any of your information that is no longer necessary for the provision of our Services, you may contact us in the manner as set forth under the “How to Contact Us” section.

10.3     You may write to our officer in charge at the details stated in the “How to contact us” section below to view and correct the Data held by us about you.

10.4     We may apply an administrative charge for providing you with access to your Data in response to such request.

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

10.6     At any time, you may object to us holding or processing your Data, on legitimate grounds, save and except as otherwise permitted by the applicable law.

11        How to contact us

            For all issues and enquiries regarding our compliance with our obligations under the GDPR where applicable, and any request for access to, correction or deletion of your Data, please contact us in writing at:

            DCConnect Global Limited

            Unit 815, 8/F, DTHub,

            5 Chun Cheong Street,

            TKO Industrial Estate,

            TKO, NT, Hong Kong

            or via email to: alliance@dcconnectglobal.com

            To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.

            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 https://www.dcconnectglobal.com/legal. If there is any inconsistency between the English and Chinese versions of the Privacy Statement, the English version will prevail.