Pacnet Privacy Policy
GENERAL
This policy statement provides information on the obligations and policies of Pacnet Services Asia Pacific Commercial (HK) Limited and its subsidiaries (“Pacnet”) under the applicable personal data laws and regulations.
TYPES OF PERSONAL DATA COLLECTED
From time to time, it is necessary for customers and various other individuals (including, without limitation, applicants for Pacnet’s services, shareholders, directors, officers and managers of corporate customers or applicants) to supply Pacnet with data in connection with various matters such as provision of services or compliance with any laws or guidelines issued by regulator or other authorities.
Failure to supply such data may result in Pacnet being unable to approve the provision of services or related services or comply with any laws or guidelines issued by the regulator or other authorities.
Types of data held
We hold details of our customers including the names, addresses, identity numbers, telephone numbers, payment details, including credit card and banking information; account details, including account numbers, service numbers, or user accounts; or service installation address, correspondence address, and/or billing address.
The purposes for which data relating to data subjects may be used are as follows:
- the daily provision of our Services to our customers;
- conduct credit reference checks;
- processing of any payment instructions, direct debit facilities and/or credit facilities in relation to provisioning of our Services or requested by our customers;
- enabling the daily operation of our customers’ accounts and/or the collection of amounts outstanding in our customers’ accounts in relation to our Services;
- conduct market research, customer, product and service surveys;
- direct marketing of our Services;
- handling of complaints and enquiries from our customers;
- prevention or detection of crime;
- provisioning of emergency services;
- joint marketing programs with third parties;
- provisioning of our Services by third parties;
- observing any legal, governmental or regulatory requirements including any disclosure or notification requirements, to which we are subject; and
- any other purposes ancillary and relating thereto.
ACCURACY OF PERSONAL DATA
Where practicable, we will validate data provided using generally accepted practices and guidelines.
RETENTION OF PERSONAL DATA
Personal data will only be retained for as long as is necessary to fulfil the original or directly related purpose for which it was collected, unless the personal data is also retained to satisfy any applicable statutory or contractual obligations; and
DISCLOSURE OF PERSONAL DATA
All personal data held by Pacnet will be kept confidential but Pacnet may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the data was collected provide such information to the following parties:
- Any subsidiaries, holding companies, associated companies, or affiliates of, or companies controlled by, or under common control with Pacnet;
- Any person or company who is acting for or on behalf of Pacnet, or jointly with Pacnet, in respect of the purpose or a directly related purpose for which the data was provided;
- Any other person or company who is under a duty of confidentiality to Pacnet and has undertaken to keep such information confidential; and
- Any financial institutions, charge or credit card issuing companies, credit information or reference bureaus, or collection agencies necessary to establish and support the payment of any services being requested.
Personal data may also be disclosed to any person or persons that have a right under the applicable laws to gain access to such information provided they are able to prove their authority to access such information.
TRANSFER OF PERSONAL DATA OUTSIDE OF HONG KONG
At times it may be necessary and/or prudent for Pacnet to transfer certain personal data to places outside of the Hong Kong SAR in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the requirements of the applicable laws.
SECURITY OF PERSONAL DATA
Pacnet will adopt reasonable measures to protect the security of personal data.
ACCESS AND CORRECTION OF PERSONAL DATA
Individuals have the rights to:
- Check whether Pacnet holds any personal data relating to them and, if so, obtain copies of such data;
- Require Pacnet to correct any personal data relating to them which is inaccurate for the purpose for which it is being used; and
- Ascertain Pacnet’s policies and practices in relation to personal data, which are those policies and practices set out in their entirety herein.
An individual may exercise his or her right of access by:
- Completing the form “Pacnet Data Subject Access Request”; and
- Sending the completed form, along with appropriate proof of identity (a copy of the applicant’s Hong Kong Identity Card or Passport) and the prescribed fee to Pacnet Privacy Compliance Officer at the address listed below.
Pacnet will, upon satisfying itself of the authenticity and validity of the access request, use its reasonable endeavor to comply with and respond to the request within the period set by the applicable laws.
An individual may exercise their right of correction by:
- Writing to Pacnet Privacy Compliance Officer at the address listed below, specifying the data which they believe to be incorrect, the reason they believe it is incorrect, and the applicable corrections; and
- Providing “proof of identity” verifying that the individual making the request is authorized to request such corrections.
DIRECT MARKETING
Pacnet will honor an individual’s request not to use his or her personal data for the purposes of direct marketing. Should you wish not to receive direct marketing material from Pacnet, please write to Pacnet Privacy Compliance Officer at the address listed below.
Any such request should clearly state details of the personal data in respect of which the request is being made. Specifically, we request that you include the corresponding company assigned account numbers which are printed on Pacnet’s statements/invoices. Please also state clearly the authority under which you are authorized to make such a request.
Unless otherwise instructed as per the above, Pacnet may use any of the data collected in the normal course of its business for marketing purposes.
All enquiries regarding Pacnet’s compliance with its obligations under the applicable laws should be in writing to:
Pacnet Privacy Compliance Officer
site.feeback@pacnet.com