This Privacy Statement sets out how we collect, use, manage and protect the personal data or information (“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 Vuclip Group ("Vuclip", "we", "us" or "our", being PCCW Vuclip (Singapore) Pte. Ltd, Vuclip Malaysia Sdn Bhd, Vuclip Inc., PT Vuclip Digital Indonesia, Vuclip (India) Private Limited and Vuclip Middle East FZ-LLC).
Protecting your privacy
We are committed to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, in particular and where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), 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, and all other applicable privacy and data protection laws and regulations in the country in which you receive our Service(s) (“your Country”).
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.
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:
In some instances, where required by law to do so, we may seek your consent to process the following types of “Special Data” so that we may further improve our Services and/or better tailor the type of information or content that we present to you:
gender and ethnicity;
salary range and employment details;
education and profession;
hobbies and leisure activities;
the Services that you have subscribed for; and
family and household demographics.
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.
Occasionally, you may need to provide Data about other individuals to us. If so, we may require you to confirm your compliance with Part VIA of the Ordinance and all other applicable privacy and data protection laws and regulations of your Country 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 (including their usage of our Services and loyalty programs) 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.
Data supplied by you will be held by one or more members of Vuclip, 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.
How we collect Data
We collect Data in a number of ways, including from:
(a) 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;
(b) third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;
(c) publicly available sources;
(d) our own records of how you use our Services;
(e) your visits on our websites, or mobile or TV apps (see “Privacy Data” section below); and/or
(f) your participation in surveys or marketing promotions organised by us or on our behalf.
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 and TV apps. This type of Data may include, but is not limited to:
(a) browser type, version and user agent;
(b) operating system;
(c) IP (Internet Protocol) address and/or domain name;
(d) connection data, statistics on page views and/or referral URLs;
(e) device ID, location and phone contacts;
(f) videos watched or searched for;
(g) links or images clicked on;
(h) cookies and/or browser, app or web server log data; and
(i) device and software characteristics and/or configuration.
How we use your Data
We may collect, retain and use your Data for the following purposes:
Our legal basis for using your Data including how we disclose your Data
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 Vuclip (which may be within or outside of your Country) (collectively, “Organisations”). Your Data is disclosed to these Organisations for the strict purpose of enabling us to supply our Services to you.
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.
These Organisations provide support services to our businesses and operations including without limitation:
(a) customer enquiries;
(b) courier, delivery, logistic and warehouse services;
(c) mailing operations;
(d) billing and debt-recovery functions;
(e) information technology services;
(f) installation, maintenance and repair services;
(g) marketing, advertising and telemarketing services;
(h) market research;
(i) customer usage and behavioural analysis;
(j) process management;
(k) after sale services;
(m) website usage analysis; and
(n) cloud storage services.
We take the required steps to ensure that these Organisations are bound by appropriate confidentiality and 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).
In addition, we may disclose your Data:
(a) to your authorised representatives and/or your legal advisers when requested by you to do so;
(b) for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties:
Direct Marketing (if applicable)
We may, in compliance with applicable laws, rules, regulations and licence requirements, 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, 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 programs, lifestyle, networking events, travelling, banking, alcohol and tobacco, sports, music, gaming, transportation, household products, food and beverages, finance, insurance, wealth management services and products, pensions, investments, brokering, financial advisory, credit and other financial services and products, betting, education, health and wellness, beauty products and services, fashion and accessories, electronics, social networking, technology, e-commerce, logistics, retail, home and décor, media and high-end consumer products and services. Marketing may be carried out in 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).
Before using and providing your Data for the purposes as set out in this Privacy Statement, where we are required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use and provide your Data for any promotional or marketing purpose.
We will honour each individual's request to not use his/her Data for the purposes of direct marketing. You may opt-out from receiving direct marketing material and/or communications from the relevant Service and/or loyalty program. 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 and/or loyalty program) by making a written request to our Privacy Compliance Officer together with your registered name and service account number, registered telephone number or login name (as applicable).
Transfer of Data outside your Country
At times it may be necessary and/or prudent for us to transfer your Data to places outside of your Country, 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 outside of your Country, we will do so in compliance with the prevailing requirements of the Ordinance, the GDPR where applicable and all other applicable privacy and data protection laws and regulations of your Country.
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.
Retention of your Data
We will retain your Data in accordance with our internal policies. Our policies are in compliance with the Ordinance and the GDPR where applicable, and cover the following principles:
Your right to access, correct and delete Data
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:
If you wish to access or amend any of your Data we hold , or request that we delete 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.
We may apply an administrative charge for providing you with access to your Data in response to such request.
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.
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.
How to contact us
For all issues and enquiries regarding our compliance with our obligations under the Ordinance, the GDPR where applicable and all other applicable privacy and data protection laws and regulations of your Country, and any request for access to, correction or deletion of your Data, please contact us in writing at:
Privacy Compliance Officer
PCCW Vuclip (Singapore) Pte. Ltd.
8 Temasek Boulevard #35-01
Suntec Tower Three Singapore 038988
or via email to: firstname.lastname@example.org
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 www.vuclip.com/privacy-statement.php. If there is any inconsistency between the English and the local language versions (if any) of the Privacy Statement, the English version will prevail.
Personal Information Collection Statement
The personal data and other information (collectively, "Data") that we, PCCW Vuclip (Singapore) Pte Ltd, receive about you as a result of or in connection with the VIU service(s) (the “Service(s)”) are collected, used and retained by one or more of the members of the Vuclip Group (being, PCCW Vuclip (Singapore) Pte Ltd, Vuclip Malaysia Sdn Bhd, Vuclip Inc., PT Vuclip Digital Indonesia, Vuclip (India) Private Limited and Vuclip Middle East FZ-LLC), in accordance with the requirements of the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), and all other applicable privacy and data protection laws and regulations in the country in which you receive our Service(s), privacy laws and the Privacy Statement of the Vuclip Group (www.vuclip.com/privacy-statement.php) (the “Privacy Statement”). The applicable terms and conditions of the Service(s), the Privacy Statement, and this Personal Information Collection Statement all apply to and govern our collection, use and disclosure of your Data.
For the purpose of processing of the Application, provision of the service(s) and managing the service account, the Data could be used by and/or disclosed to affiliates or related companies of the Vuclip Group and business partners.
Subject to your right indicated by checking the box below or leaving it unchecked (if the application process so provides), all the information in this application, including your contact information and account information, may be used to send you notice of gifts, discounts, privileged offers, benefits and any other promotions related either to this service being subscribed or to other kinds of goods and services including telecommunications network services, computer peripheral, accessories and software, secretarial services, personal assistance services, information services and the latest offers on various kinds of products or services including gaming, sports, music, beauty products, electronics, technology, e-commerce, cloud services, mobile payment, travelling, banking, investment, entertainment, transportation, household, fashion, food and beverages, alcohol and tobacco, insurance, education, health and wellness, social networking, media and high-end consumer products and services. Request for access to or correction of personal data can be made in writing via email email@example.com.
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