Privacy Statement

HTT Holding Co., Ltd. Data Privacy and Security Policy

This policy (“Policy”) sets out how HTT Holding Co., Ltd. and its subsidiaries (collectively, “HTT”, “we”, “our” or “us”) collect, use, store and handle personal data.

A. Commitment to Personal Data Protection

We are committed to protecting the privacy of the personal data (“Personal Data”) we hold. To ensure that you can make informed decisions and feel confident about providing your Personal Data to us, we outline in this Policy our practices and the choices you have concerning the collection and use of your Personal Data.

B. The Personal Data We Collect

The types of Personal Data we collect from you will depend on the specific type of services and products as requested by, or provided to, you. The types of Personal Data may include (without limitation) the following:

Certain Personal Data (e.g. relating to your personal information and contact information) are required for specific services and if you fail to supply such Personal Data as requested from each specific service, we may not be able to deliver you the services or products. By providing your Personal Data to us, you acknowledge that such provision is fair and reasonable in the circumstances.

C. Purposes for which your Personal Data are Collected and Used

The purposes for which your Personal Data are collected and used may include (without limitation) one or more of the following purposes:

We will not knowingly or intentionally use, share or sell your Personal Data in ways which are unrelated to the above purposes (or purposes as specified in a personal information collection statement when we collect your Personal Data) without your prior consent.

D. Disclosure and Transfer of Personal Data

To facilitate the purposes mentioned under “C. Purposes for which your Personal Data are Collected and Used”, we may transfer, disclose, grant access to or share your Personal Data with third parties located within or outside Hong Kong, and your Personal Data may be transferred within or outside Hong Kong. These third parties may include the following:

F. Our Commitment to Children's Privacy

Protecting the privacy of children is our primary concern. Hence, we will not knowingly collect or maintain Personal Data in our database from persons who are under 16 years of age without prior consent from a parent or guardian.

G. Use of Cookies and Log Files

If you visit any of our websites, we may use cookie files to store and track information about you and your preferences. A cookie is a small text file that our website transfers to your computer's or device’s hard disk. We use cookies to better serve you and/or maintain your information across multiple pages within or across one or more sessions.

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. However, if you disable cookies or refuse to accept a request to place a cookie, certain functionalities on our websites may not be available.

Cookies contain information about you and your preferences. For example, if you inquire about rates and availability, the site might create a cookie that contains the details you entered. Or it might only contain a record of which pages within the site you visited, to help the site customise the view for you the next time you visit.

Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie. For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.

We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes. As it is not linked to any personal information, it is separate from your Personal Data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.

If you use the WiFi available at our properties, we may collect your location data (if you have consented to this on your device). We may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information we receive from third parties to provide you with better service and, where you have consented to receive direct marketing, we may provide you with targeted advertisements, content, features, deals and offers in relation to the classes of marketing subject as set out in the relevant personal information collection statement when your Personal Data is being collected.

If you interact with us on social media platforms (for example if you "Like" our Facebook Page or post on our timeline), we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform's rules but we are not responsible for how the platform operators collect and handle your Personal Data. We are not responsible for what third parties post on our social media accounts.

H. Data Retention

Subject to any legal, statutory, regulatory or accounting requirements, the Personal Data you provide to us will be kept by us in the appropriate form only for as long as is necessary to fulfil the purposes mentioned above after which it will be destroyed.

I. Data Security

In order to ensure the correct use and to maintain the accuracy of the Personal Data collected from you, as well as preventing unauthorised or accidental access, processing, erasure or other use of the Personal Data, we have implemented various internal policies (including physical, electronic and management measures) to safeguard and secure the Personal Data we collect.

For example, where we collect Personal Data online, we use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Personal Data.

Our websites have firewalls in place, which should protect the Personal Data collected from you against unauthorised or accidental access. However, complete confidentiality and security is not yet possible over the internet, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorised access to your password and credit card details. Make sure you sign out from your account when finished particularly when using a shared computer.

J. Other Websites

In order to anticipate your needs, our websites may contain links to third party sites that are operated under different privacy practices.

All such websites are independent from our websites. We have no control over the contents of such other websites or their privacy policies or compliance with the law. You should therefore be fully aware the provision of such links does not constitute an endorsement, approval, or any form of association by or with HTT. We have no control over Personal Data that is submitted to these other websites. You should remain alert when you leave our websites, and read the privacy statements of other websites.

K. How to Access or Correct Your Personal Data or Contact Us

You are entitled to access or correct any Personal Data relating to you held by us. If you wish to obtain a copy of any of your Personal Data or if you believe that the Personal Data relating to you which we collect and maintain is inaccurate, please write to us at the address below.

A request for access to Personal Data, correction of Personal Data, or for information regarding policies and practices and kinds of Personal Data held by SPL may be sent to us at the following address:

Data Protection Officer HTT Holding Co., Ltd.

L. Note

This Policy may be amended from time to time. You may access and obtain a copy of this Policy, as amended from time to time, at www.ht-telecom.com so that you are always informed of the way we collect and use Personal Data.

This Policy is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Policy, the English version shall prevail.