November 22, 2018
We are committed to protecting and respecting your privacy rights under the Personal Data (Privacy) Ordinance in Hong Kong (the "PDPO").
Capitalized terms used but not defined herein have the meanings assigned to them in the General Terms and Conditions for the Services.
Information we may collect from you
1. "Personal Data" refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. We may collect the following Personal Data from you:
a. your full name;
b. the number of your passport, HKID card or other identification document which bears your photograph;
c. your contact details (including address, telephone number, e-mail address) and proof of the same;
d. information about your transactions made via your Prepaid Card Account (including balances, parties to the transactions and account usage);
e. other personal data which you have provided to us or ePaylinks in any forms of interaction with you; and
f. information we collect when you use our App, the Prepaid Cards or visit our online platforms, website and other services, including your IP address (see "Cookies" below).
2. It is mandatory for you to provide Personal Data; or else we will not be able to:
a. provide you with the functions available on our App and website;
b. verify your identity or facilitate your use of Prepaid Cards and related services once you have activated your Prepaid Card Account; or
c. display information including transactions records of Prepaid Card Account or the Services.
Otherwise provision of your Personal Data is voluntary.
You may also submit information to us at your option via other methods, including but not limited to (i) posting on social media or online forums, (ii) in response to marketing or other communications, or (iii) through participation in an offer or program.
The purposes of how we use your Personal Data
3. We will collect and use your Personal Data for the following purposes:
a. verifying your identity and records of your account(s);
b. opening, managing and maintaining the continuation of your accounts with us and/or your Prepaid Card Account;
c. determining, displaying and communicating with you regarding the transaction status or the amount owed to or by you in your Prepaid Card Account;
d. performing our obligations under any agreement between you and us or ePaylinks;
e. facilitating the provision of Services by us or ePaylinks to you;
f. complying with our requirements to make disclosure under any law, regulation or court order, or under and for the purposes of any guidelines issued by regulatory or other authorities;
g. conducting marketing and statistical research and analysis;
h. ensuring, checking or reviewing your ongoing creditworthiness;
i. designing financial services or related products for your use; and
j. any other purpose directly related to the above-mentioned purposes.
To whom your Personal Data may be transferred
4. We may disclose your Personal Data to the following third parties for the following purposes:
a. any of our and ePaylinks’ agent, contractor, auditors or third party service provider, insurer, investment service providers, business partners or advisors including MasterCard in connection with the management, operation, administration or support of your Prepaid Card Account and/or the performance of the Services;
b. to any legal, regulatory, governmental, tax, law enforcement or other authorities as required pursuant to paragraph 3(f) above;
c. a counterparty to a transaction that is entered into on your behalf; and/or
d. any interested party that requests reasonable information, where you have defaulted in the performance of your obligations under an agreement with us or entered by us on your behalf.
The above mentioned third parties are under an obligation to us or relevant regulators to undertake to keep the information confidential.
5. If you have switched on your location services, information about your physical location sent from your Device (e.g. GPS signals) may be provided to and used by us. You will be asked to consent to the use of location services when you download the Neat App or, for iOS devices, the first time you use our functions which require access and use of your location data. You may withdraw your consent at any time by turning off the location services settings on your Device.
6. We would like to use your Personal Data (except your passport, HKID card or other identification document which bears your photograph) for direct marketing but we cannot do this without your consent (which includes an indication of no objection). In this regard, by using the Services, you consent to us using, from time to time, your Personal Data (for example, your address, telephone number, email address and/or account usage) to promote and market the following services:
We would also like to provide your Personal Data (except your passport, HKID card or other identification document which bears your photograph) to third parties for gain for direct marketing purposes but we cannot do this without your written consent.
By using the Services, you also consent to us sharing, from time to time, your Personal Data (for example, your address, telephone number, email address and/or account usage) with our co-branding partners including ePaylinks to market their services and products.
If you do not want Neat to use or share your Personal Data for direct marketing purposes as described above, please do not use the Services. If you later decide you no longer wish to receive any such direct marketing communications, you may opt out at any time by contacting our Data Protection Officer (see paragraph 15 below for contact details) and we will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving direct marketing communications from us, we may still send you important administrative messages that are required to provide you with our Services.
Where we store your Personal Data
Security and retention
9. Where Personal Data is stored, accessed or transmitted via the internet, it is not completely secure. We will take all reasonable steps to protect your Personal Data, but we do not have any control over, and cannot guarantee the security of your Personal Data transmitted via the internet outside the App. Therefore, any such storage, access or transmission is at your own risk.
10. Our App and website may, from time to time, contain links to and from the websites of ePaylinks and third parties. If you follow a link to any of these mobile apps or websites, please note that these mobile apps and websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these mobile apps and websites.
11. We will retain and procure our service providers to retain your Personal Data only for so long as is necessary in accordance with applicable laws and regulatory requirements.
12. In order to improve the quality of your experience when using our website or App services, and to distinguish you from other users of these services, we may use tracking technologies on our website and App, such as cookies for the collection and use of Personal Data or other information. A cookie is a small file of letters and numbers that our web servers send to your Device when you visit certain parts of our App or our website. The cookies we use are "analytical" cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the site when they are using it. Cookies may be disabled by changing the setting on your web browser or Device but this cannot be done while using our App. However, if cookies are disabled, you may not be able to use certain functionalities or login to secured pages on our App or website.
Information that may be recorded include, but are not limited to:
· IP address, device type, operating system and Internet browser type; and
· Usage data such as time spent on our website, websites visited, links clicked, and the pages that led or referred you to our website.
Your data privacy rights
13. Subject to PDPO, you may:
a. check whether we hold Personal Data about you and may request access to that information and to information about the ways in which we have used and disclosed that information;
b. require us to correct any inaccuracy in any of your Personal Data held by us;
c. request us to stop processing your Personal Data held by us; and/or
d. ascertain our policies and practices in relation to your Personal Data.
14. If you request access to or correction of Personal Data, we have the right under the PDPO to:
a. charge a reasonable fee for processing a data access request, in which case we will inform you of the fee amount and accepted payment methods; or
b. reject a request if there is a valid reason for such rejection, which we will tell you.
15. Requests for access or correction of Personal Data, or for us to stop processing your Personal Data, or for information regarding our data protection policies and practices, may be addressed to us as follows:
Personal Data Privacy Officer
10/F China Hong Kong Tower
8 Hennessy Road