Terms and Conditions T&C 09 (Privacy Policy)

1. General

This privacy policy sets out the policies and practices of SmarTone Group (“SmarTone”) in the collection, use,

sharing and protection of customers’ personal information. SmarTone may update or change this policy and these

changes will be posted in SmarTone’s website.

2. Collection of Customer’s Personal Information

a) For the purpose of carrying on SmarTone’s business including sale, provision, registration and advertisements

of SmarTone’s telecommunications and related products and services, SmarTone will collect your personal

information when you:

﹣purchase a product from SmarTone through the telephone, online, in a SmarTone store or through

SmarTone’s authorized dealers or agents;

﹣subscribe or register a service of SmarTone (including registration or subscription of the service at a

SmarTone store, through the telephone or on-line or through SmarTone’s authorized dealers or agents);

﹣enquire about a product or service from SmarTone;

﹣contact SmarTone with an enquiry or complaint;

﹣enter any promotions, competitions or prize draws through SmarTone’s services;

﹣use SmarTone’s products or services;

﹣take part in market research; or

﹣visit or browse SmarTone’s websites.

b) SmarTone may also collect information about you from other organizations including general business

directories and credit information or reference bureaus necessary to establish and support the payment of

any services being requested by you.

c) SmarTone may also collect information indirectly from you when you use SmarTone’s services including but

not limited to when you:

﹣visit or browse SmarTone’s websites;

﹣browse or otherwise access the Internet, WAP sites and/or the mobile internet through SmarTone’s

services;

﹣use SmarTone’s networks (mobile / broadband or others).

SmarTone may be unable to sell products to you or provide you with services you may request, if you fail or refuse

to disclose to SmarTone the personal information we may reasonably require.

3. Types of Personal Data Collected

a) For the purpose of carrying on SmarTone’s business including the sale, provision, registration and

administration of SmarTone’s telecommunications and related products and services (including relevant

on-line services), the information that SmarTone collects includes but is not limited to the following:

﹣your name;

﹣service installation address, correspondence address and/or billing address;

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

﹣payment details including credit card information, bank account and other banking information;

﹣contact details, including contact name and xed and mobile telephone number and email address;

﹣your date of birth;

﹣information for the verication of your identity, including identication type and identication number;

﹣your preferences for particular products, services or your hobbies and leisure activities;

﹣a note or recording of a call that you made to SmarTone’s hotlines;

﹣an email or letter you send to SmarTone; and other records of any contact you have with SmarTone;

﹣your account information, such as dates of payment, top-up information, the service plans you have

subscribed; and any other information relating to your account.

b) In support of the telecommunications and other services provided by SmarTone, information may be

automatically collected by SmarTone on how you use SmarTone’s products and services, including but not

limited to:

﹣the telephone numbers and/or email addresses of calls, texts, MMS, emails and other communications

made and received by you and the date, duration, time and cost of such communications;

﹣your searching, browsing history (including websites you visit) and location data;

﹣internet PC location for broadband, address location for billing, delivery and installation.

4. Use of Customers’ Personal Information

SmarTone may use and analyze your information for the following purposes:

﹣daily operation of the SmarTone’s services provided to customers;

﹣conducting credit checks when required;

﹣designing services or products for customers' use;

﹣processing your order and providing the products and services that you have bought from SmarTone and

keeping you updated with the progress of your order;

﹣keeping you updated of SmarTone’s latest oers or promotions;

﹣marketing the following products and services (in respect of which SmarTone may or may not be

remunerated):

1. all products or services by SmarTone including mobile voice and data communications,

IDD/roaming, entertainment and information services, Internet connectivity and data

communications on the Internet;

2. reward, loyalty or privileges programmes and related products and services; and

3. products and services oered by SmarTone’s business partners including travel, dining,

entertainment, apparel, health & beauty, education, household, transportation, banking,

insurance and other consumer products and services;

﹣assisting you with any products or services enquiries, including investigating and resolving service

aecting issues and dealing with any billing queries you may have;

﹣billing you for using SmarTone’s products or services;

﹣protecting SmarTone’s network including managing the volume of calls, texts, data and other use of

SmarTone’s network;

﹣analyzing usage of SmarTone’s network, products and services by you and other customers so that

SmarTone can further improve SmarTone’s products and services and/or better tailor the type of

products and services presented to customers;

﹣carrying out research and statistical analysis and monitoring customer use of SmarTone’s network,

products and services on an anonymous or depersonalised basis;

﹣assisting SmarTone in fraud and crime prevention;

﹣debt tracing, debt recovery and credit management; and

﹣contact you if necessary.

5. Retention of Personal Data

SmarTone will destroy any personal data it may hold in accordance with its internal policy. Personal data will only

be retained for as long as SmarTone need it unless the personal data is also retained to satisfy any applicable

statutory or contractual obligations or for the purpose of investigation, detection and prosecution of crime.

6. Disclosure and Sharing of Personal Data

All personal data held by SmarTone will be kept strictly condential but you agree and consent that for the

purposes of providing and managing the products or services requested by you from time to time SmarTone may

disclose information about you to the following parties:

﹣companies in the SmarTone Group;

﹣contractors, agents or suppliers who are involved in delivering the products and services you have

ordered or used;

﹣any banking or nancial institutions, charge or credit card issuing companies;

﹣credit information or reference bureaux;

﹣debit-collection agencies or other debt-recovery organizations;

﹣emergency services (if you make an emergency call), including your approximate location;

﹣professional advisers (which shall include lawyers and auditors);

﹣any agent, contractor or third party service provider who provides administrative, telecommunications,

computer, payment or other services to SmarTone in connection with the operation of its business;

﹣law-enforcement or government bodies, regulatory bodies, courts or as required by law;

﹣any person to whom SmarTone is under an obligation to make disclosure under the requirements of any

law binding on SmarTone or under and for the purposes of any guidelines issued by regulatory or other

authorities with which SmarTone is expected to comply;

﹣third party reward, loyalty and privileges programme providers;

﹣external service providers (including but not limited to mailing houses, telemarketing and direct sales

agents, call centres, data processing companies and information technology companies) that SmarTone

engages for the purposes set out in paragraph 4.

7. Security of Personal Data

(a) SmarTone has adequate measures to protect your personal information from unauthorized access, accidental

loss or destruction.

(b) If SmarTone has a contract with another third party organization to provide a service on its behalf, SmarTone

will ensure they have appropriate security measures and only process your information as SmarTone has

authorized. Those organizations will not be entitled to use your personal information for their own purposes.

SmarTone will take reasonable steps to check these organizations to make sure that they are meeting the

security requirements set by SmarTone.

8. Transfer of Personal Data Outside of Macau

At times it may be necessary and/or prudent for SmarTone to transfer certain personal data to other group

companies or service providers outside of the Macau Special Administrative Region (“Macau”). This may happen

if SmarTone’s servers or suppliers and service providers are based outside of Macau or if you use SmarTone’s

services and products while visiting countries outside Macau. SmarTone will take steps to ensure that your

personal information is used by such third parties in accordance with this policy. By purchasing or subscribing to

any product or service from SmarTone you agree to and authorize such transfer.

9. Your Privacy Rights

(a) In accordance with the terms of the Personal Data Privacy Law (“the Law”) and subject to exemptions

specied in the Law, any customer:

﹣has the right to check whether SmarTone holds personal data about him or her and has a right to receive

copies of such data;

﹣has the right to require SmarTone to correct any personal data relating to him or her which is inaccurate;

and

﹣has the right to ascertain SmarTone’s policies and practices in relation to personal data and to be informed

of the kind of personal data held by SmarTone.

(b) In accordance with the terms of the Law, SmarTone has the right to charge a reasonable fee for processing a

data access request.

and to stop receiving or re-start receiving direct marketing, may be made in writing to:

The Data Protection Ocer

SmarTone-Mobile Communications (Macau), Limited

Avenida Xian Xing Hai, Centro Golden Dragon, 12 andar, Macau

Please identify yourself with your name and contact number when writing to the Data Protection Ocer.

10. Privacy Policy Published @smartone.com

This Privacy Policy is subject to change from time to time. Any changes will be posted on SmarTone’s website

smartone.com and will come into force on the rst day immediately after the date of posting.

For the purpose of this Privacy Policy “SmarTone Group” means SmarTone Telecommunications Holdings Limited, its

holding company and any company which is a subsidiary of SmarTone Telecommunications Holdings Limited. Companies

in the SmarTone Group shall include, without limitation, SmarTone Mobile Communications (Macau) Limited, with

registered oce at Avenida Xian Xing Hai, Centro Golden Dragon, 12 andar, Macau

20180401T&C 09

Terms & Conditions T&C 09 (Privacy Policy)

Copies of Terms and Conditions are available upon request at the Company Stores or by calling the Company hotline or retrieved from smartone.com