This Privacy Policy is designed to assist you in understanding how Truphone uses and safeguards your information. Truphone has prepared this document in compliance with its obligations under the Personal Data (Privacy) Ordinance and Telecommunications Ordinance. Nothing in this document seeks to alter Truphone's obligations under the credit reporting requirements of the Personal Data (Privacy) Ordinance and its related Code of Practice. 

1. What is a Privacy Policy?

1.1 This Privacy Policy sets out what Data we hold and the purposes for which it is used. You should read this Privacy Policy along with the terms and conditions relating to the services we provide to you. 

2. Purposes for which information is collected

2.1 Truphone and its related companies (Truphone Group Companies) are required by law to collect certain information from you (Data). Such Data, which includes your name, address and telephone number, is provided to the operator of the Emergency Service. That information is used to assist emergency services organisations.

2.2 In addition to clause 4 below, data is collected and may be used for five main purposes. Truphone collects, processes and uses, or has third party service providers who collect and process on Truphone's behalf, personal data relating to You, as permitted in order to:

(1) verify your credit status and perform on-going credit check;
(2) provide the Truphone Service, in particular to convey the communications you make by means of the Truphone Software and/or the Truphone Service and Truphone network;
(3) invoice you for your use of the Truphone Service;
(4) maintain your account including without limitation providing customer service to you; and
(5) carry out Truphone marketing activities.

In the event, the Company or its End User does not provide such personal data, Truphone may not be able to provide Truphone Services to the Company and its End Users.

2.3. This implies that we may from time to time send you information about services and products in which we believe you may be interested. You must actively give your consent for this at the time the information is collected. We will not use your information if this consent is not given. We will not provide your personal data to third parties for direct marketing or other unrelated purposes without your consent. In the event, the Company or its End User does not provide such Data, Truphone may not be able to provide Truphone Services to the Company and its End Users. 

3. What information do we hold about you?

3.1 When you sign up to the Truphone Service we will ask you, where appropriate, for your name, address, details relating to your method of payment, telephone number and email address. We also hold information about which services of ours you have used, and details relating to when you have used such services, including call times, routing and durations (which are known as "traffic data").

3.2 In order to provide the services in certain countries, national regulators may require Truphone to obtain copies of certain personal documents from you (passport, ID document, etc), which will be held by us and made available to such national regulators if they so request. 

4. What do we use it for?

We collect certain information so that we can confirm your identity and process your order when you first sign up for our Service. We may also use your Data for the following:

4.1 Regulatory Compliance

4.2 Marketing activities

If you have consented to the use of your Data for marketing purposes then we may use your Data to send you information about additional services that we provide.

4.3 Collecting traffic data

We may hold Data about the numbers and lengths of calls made in order to bill you for your services. We may also use it to identify some value added services we may offer you.

4.4 Processing your application and on-going credit management of your account

We may need to disclose to a credit reporting agency:

(a) personal identifying details, including your name, current and previous addresses, identity card number, passport number, date of birth and name of employer;
(b) the fact you have applied for a Truphone Service, and any credit limit on your account;
(c) the amount of any payments which are overdue for at least thirty (30) days, when steps have been taken by Truphone to recover those overdue payments;
(d) where an overdue payment has been previously reported, advice that the payment is no longer overdue;
(e) cheques or credit card payments which have been dishonoured;
(f) court judgments or bankruptcy orders made against you;
(g) that, in the opinion of Truphone, you have committed a serious credit infringement; and
(h) when Truphone ceases to provide products or services to you. 

You authorise Truphone to disclose the information described in this clause 4.4 to a credit reporting agency. You also authorise Truphone to seek from or give to any credit providers authorised by you or named in a credit report or to other telecommunications providers (carriers or carriage service providers), and Truphone's agents the same information and any other information on this form and any other information on your credit worthiness, credit history or credit capacity that credit providers are allowed to give under the Personal Data (Privacy) Ordinance.

You further authorise Truphone to obtain a credit reference for the purpose of considering an application by you for commercial credit. You authorise Truphone to obtain and use commercial information about your commercial credit worthiness or commercial history when considering an application for consumer credit.

You acknowledge Truphone may refuse or cancel the supply of products or services on the basis of its credit assessment of you. You are entitled to see, and to correct, any credit information which Truphone holds about you. 

5. Can I opt out?

5.1 You may request to receive communications that only relate to your account or which are legally required. That is, you may "opt out" of receiving other communications. If you wish to make such a request, you may do so at any time by contacting the Truphone customer services line on +852 5149 1907. Truphone will process such a request as soon as reasonably possible after receiving it. 

6. Who else will see my information?

For the purpose of processing your application and on-going credit management of your account, Truphone may need to disclose to a credit reporting agency certain of your Data.

6.1 Transactions for Billing

We may use third party banking facilities and billing agencies to process your information. Third party network operators may also need access to your Data for regulatory compliance purposes. We will ensure that such agencies conform to the same or similar guidelines as we do.

6.2 Compliance with Laws codes and procedures

Sometimes we may have to provide certain of your Data to third parties to comply with legal codes and procedures. For example, this may be for reasons relating to regulatory requirements, resolution of billing disputes, legal proceedings or national security. In all such cases Truphone will comply with applicable Hong Kong law.

6.3 Third Parties for Administrative Purposes

We may sometimes contact other companies to assist with our administration. In these cases we will make sure these parties have the same or similar guidelines to ours.

6.4 Providing a directory enquires service

Unless you and/or your company have asked us not to enter your details into a directory services, we will enter your Truphone number into Truphone and third party directories, and our network will allow the display of your number on receiving devices. You have the option to opt out of these services.

Note that where Truphone provides You with Access to Emergency Services, Your number and location of your device will be disclosed to the emergency services as part of the legal and regulatory requirements.

6.5 Information Storage

Information collected on the website or by using the Service may be stored and processed in any country in which Truphone maintains facilities. In this regard, or for purposes of sharing or disclosing data in accordance with this policy, Truphone reserves the right to transfer information outside of your designated home country. By using the Truphone Service You consent to any such transfer of information outside of your designated home country. Truphone may sell or buy subsidiary companies or business units. In such transactions as well as in the event Truphone or substantially all of its assets are acquired by a third party, personal information of Truphone users will generally be one of the business assets transferred. We reserve the right to include your personal information, collected as an asset, in any such transfer to a third party. 

7. Can I see the data you hold about me?

7.1 Yes. You may request access to the Data we hold on you, and you may request it be corrected if you think it is inaccurate. By sending a letter to the Data Privacy Officer, Truphone (Hong Kong) Limited, 16/F, 700 Nathan Road, Kowloon, Hong Kong. You can also email us at data@truphone.com. You may contact Truphone customer service on +852 5149 1707 for more information. Truphone reserves the right to charge an administrative fee of HK$200 for a copy of the personal data that Truphone holds. For the avoidance of doubt, no fee shall be charged for correcting any personal data that Truphone holds. 

8. What are cookies and how do we use them?

8.1 Cookies are pieces of information that Truphone will transfer to your computer's hard drive through your browser to enable Truphone's systems to recognise your browser. When you visit Truphone's website, Truphone will use cookies to gather information about the use of its website so as to manage and enhance the website accordingly to the preferences of the users and to provide Truphone Services to you.

8.2 The Help option on the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Truphone's cookies do not contain any identifying information. Please bear in mind that some personalised services may not be available if you choose to disable cookies. 

9. How does Truphone protect your personal information?

9.1 Truphone are committed to protecting the privacy, confidentiality and security of the Data we hold by complying the requirements of Personal Data (Privacy) Ordinance with respect to the management of Data. As such, Truphone takes appropriate organisational and technical measures to protect Data (including traffic data) provided to it or collected by it, and does not retain it any longer than permitted in order to perform its services or as required under relevant legislation. Your Data can only be accessed by authorised employees of Truphone who need access to such Data in order to be able to fulfil their given duties.

9.2 Truphone takes appropriate technical measures to protect the confidentiality of the communications content via its Truphone Services, and observes applicable obligations and exceptions under the relevant legislation. 

10. Will this policy change?

10.1 This privacy policy may change from time to time for either legal or business reasons. In particular, you should check this Policy regularly for compliance purposes. If any changes are made a revised privacy policy will be published at www.truphone.com.