Privacy Policy Statement

AIRTALK ("We") respects customers’ privacy as it is very important to us. In complying with the Personal Data (Privacy) Ordinance, we pledge to meet fully the recognized standards of personal data privacy protection. This privacy policy statement ("Privacy Policy") covers how we collect, use, communicate and treat personal information that customer ("You") may provide through our website or Mobile App.

1. Agreement

a. Customers should read this Privacy Policy carefully, once you consent to this Policy's terms, it creates legal obligations on you and on AIRTALK. If you do not agree with any term in this Privacy Policy, please refrain from accessing or using this website or Mobile App.

b. This Privacy Policy has been set out in both Chinese and English. The English version shall prevail in the event of any discrepancies between the two versions.

2. Scope

a. This Privacy Policy applies (i) to anonymous information you provide to us while using our website or Mobile App, and (ii) to Personally Identifiable Information ("Personal Information") that you choose to provide to us via the website or Mobile App, or that provide to us as part of the process of registering online as AIRTALK Customer.

b. This Policy does not apply to other information we may collect through traditional, offline means.

3. The Information We Collect and Our Uses

"Personally identifiable information" is the information that identifies you, such as your full name, mailing address, email address, phone number or credit card details etc. AIRTALK will not share personally identifiable information you provided via our website or Mobile App with any third party, other than as expressly disclosed in this policy. We collect information from you at different points on our website or Mobile App, and use this information as follows:

3.1 Registration Information
Customer may provide personal information to us, in connection with requests for information, or for other reasons.

3.2 Processing Requests and Transactions
When you make a request to us via our website or Mobile App, we will use any personal information that you provided, for the purposes of processing and responding to that request. In each instance where you make a request under our website or Mobile App, we use the information you provide to us solely for the purpose of fulfilling your request, including but not limited to your buying orders, payment clearance and your enquiries.

3.3 Direct Marketing
AIRTALK may choose to send newsletters, bulletins, marketing materials, or other information to you periodically. We will use your personal information to send such communications by email, text, other mobile messages or printed materials. If we choose to undertake such communications, you will have the ability to opt-out of receiving these communications as provided in Section 5.

3.4 Anonymous Information
Anonymous Information is information that does not identify you, but include analyses concerning the number of transactions and most frequent visit pages on our website or Mobile App. We use this information to analyze the effectiveness of our website or Mobile App, to improve our services and our website or Mobile App, and for other similar purposes.
From time to time, we may undertake statistical and summary analyses of the general behavior and characteristics of our customers. We may share these analyses and anonymous Information with third parties. We assured that anonymous Information provided to third parties will not allow anyone to identify you, or determine anything personal about you.

3.5 Computer Configuration and Information
We may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC/handset), your computer/handset name, the type and version of your web browser, and other generally-accepted log information.
We may also record page views (hit counts) and other general statistical information, which will be aggregated with that of other customers in order to understand how our website is being used. None of this data contains personal information of the customers.
In order to determine whether your computer/handset is supported by our system, we may collect certain anonymous information. This information includes, but may not be limited to, your operating system and browser. This information is kept strictly confidential and is not shared with third parties, except as provided for in this Privacy Policy.

3.6 Cookies
A cookie is a small amount of data, which often includes an anonymous unique identifier, which is sent to your browser from a website's computers and stored on your computer's hard drive or handset. Cookies are used to identify users, store shopping cart information, and customize pages for you based on your browser type.
We may include cookies on our website or Mobile App, and use them to recognize you when you return to our website or Mobile App. You may set your browser so that it does not accept cookies. Cookies must be enabled on your web browser, however, if you wish to access certain personalized features of our website or Mobile App.

3.7 Extent of Information Collected
We do not collect any more personal information than necessary to operate the website or Mobile App and respond to your requests.

4. Information Disclosure

Besides the exceptions as detailed in above section 3, we will not disclose your personally identifiable information to unaffiliated third parties without your express consent, except in the following limited circumstances:

4.1 AIRTALK Website / Mobile App Vendors
We may employ other companies to perform functions on our behalf, such as (i) maintaining our website / Mobile App, (ii) maintaining the server centers that allow us to host your data, (iii) collecting information, (iv) responding to and sending electronic mail, or (v) other functions necessary to our business. We may need to share your personal information with these website / Mobile App vendors. We will provide the vendors with only that information necessary to perform their functions, and we will not allow them to use your personal information for any other purpose.

4.2 Imminent Harm
We may reveal your personal information to attorneys, private investigator organizations or law enforcement agencies if we believe (a) that you are in risk of harm from another, or (b) that you are harming or interfering (or will imminently harm or interfere) with others, or (c) that you are violating (either intentionally or unintentionally) our Terms and Conditions, or (d) that you are violating legal rights.
Please note, however, that by specifying this exception from our privacy and data protection practices, we assume no duty to monitor safety concerns on your behalf.

4.3 Legal
We will reveal your personal information when we are required to do so by law, or in the unlikely event we become involved in a dispute with you, and such information is necessary to support or defend our position.
In addition, if we receive legal process calling for the disclosure of your personal information, we will attempt to notify you via the email address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.

4.4 Transfer of website or Mobile App
AIRTALK may transfer information collected (including any personal information) to a third party, in connection with a sale or transfer of all (or substantially all) of the assets of the business entity, provided the acquiring third party has agreed to safeguard your personal information with protections that in all material respects are the same as or more protective than those set out in this Privacy Policy.

5. Changing or Removing Information; Opting Out

5.1 Account Information
To allow appropriate control over personal information, you can access your personal information you have provided to us via the website or Mobile App, to change or update the information that you have previously submitted.

5.2 Opt-Out
If we choose to send you our direct marketing materials, we will provide you with the ability to decline or "opt-out of" receiving such communications. Instructions for opting-out will be provided if and when we determine to send you such a communication. The "opt-out" does not prevent you from receiving formal notices concerning operation of our website or Mobile App, and legal, and other related notices concerning your relationship to AIRTALK.

5.3 Deleting Information
We will remove all your personal information from our databases compiled from the website or Mobile App if you request. Please understand that it may be impossible to remove this information completely, due to backups and records of deletions. You may not remove anonymous information from our databases.
In addition, please understand that, if you request deletion of your information, you will be unable to utilize associated features of the website or Mobile App, and any associated services or information.

6. Security

We have security systems designed to prevent unauthorized access to or disclosure of information you provide to us, and we take reasonable steps to secure and safeguard this information.
Please understand that we do not warrant fail-proof security of information provided by or submitted to AIRTALK. Due to the nature of Internet communications and evolving technologies, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who obtain unauthorized access despite our efforts.

7. Notification of Changes

From time to time, AIRTALK may change the Privacy Policy. If we make any changes regarding disclosure of personal information to third parties, we will attempt to contact you prior to the date the modified policy is scheduled to take effect. We will post notice of the new Privacy Policy on our website and Mobile App.
With respect to your use of our website or Mobile App following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed.

8. Relationship to Terms and Conditions and Other Contracts

This Privacy Policy must be read in conjunction with our Terms and Conditions, to the extent the Terms and Conditions conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.

9. Effective Date

The effective date of these Terms is September 1st, 2017.