Version Effective Date: [*]
About Us
This website, [www.chinatelecomglobal.com] (the "Website"), is created and operated by China Telecom Global Limited and its affiliated companies in relevant jurisdictions (collectively referred to as the "Service Provider", hereinafter collectively referred to as "the Company", "our", or "we").
About This Privacy Policy
This privacy policy describes how we collect, use, disclose, transfer, store, and share (collectively referred to as "process") your personal information in relation to the services, activities, and experiences of the Website (collectively referred to as the "Services"). We will comply with this privacy policy in accordance with the applicable laws of the regions where we operate. In some cases, we may provide additional applicable privacy policies for certain services, practices, or regions. These terms should be read in conjunction with this privacy policy.
What This Privacy Policy Does Not Cover
This privacy policy does not apply to the content uploaded by customers themselves that is processed, stored, or hosted through the Website's services (collectively referred to as "Customer Information"). In such cases, we provide you with a platform for storing and managing information, and any information processed is on your behalf. The services provided by the Website for activities such as uploading, downloading, transferring, publishing, distributing, and storing personal information and other data do not fall under this policy. If you use the services provided by the Website for data processing, you should ensure the legality of the data-processing activities. You should ensure that the processing of the above-mentioned personal information complies with applicable laws and regulations. Before processing personal information, you should have legally informed the relevant individuals of the types, purposes, methods, and other matters of personal information processing, and have obtained the individuals' consent in accordance with the law.
This privacy policy also does not apply to any services, websites, or content provided by third parties. When you provide personal data to us on a third-party website or platform, the personal data you provide may be collected separately by the third party and is subject to the privacy policy of the third-party website or platform. Therefore, we will not be responsible for the privacy measures of such websites or platforms.
"Personal information" used in this privacy policy refers to information related to an identified or identifiable individual under applicable laws. For example, such information may include your name, address, email address, detailed business contact information, or information collected when you interact with us through our website or activities.
If there is any conflict or inconsistency between the Chinese version and other available language versions of this policy, the Chinese version shall prevail to the extent permitted by applicable laws.
Table of Contents
· How We Collect Your Personal Information
· Personal Information We Collect
· How We Use Your Personal Information
· How We Share and Transfer Your Personal Information
· How We Protect Your Personal Information
· Retention of Personal Information
· Cookies
· Your Control Rights and Choices
· Personal Information of Children
· Revision of the Privacy Policy
· Contact Information
· Supplementary Privacy Policy for the European Economic Area and the United Kingdom
· Supplementary Privacy Policy for Hong Kong
How We Collect Your Personal Information
Information You Provide to Us: We will collect the information you provide to us when you inquire about or use our services, contact us by phone, email, or other means, when you register, subscribe to, or purchase our services (including linking your personal profile on a third-party website or platform to your registered account), and when you undergo real-name authentication.
Information About You Collected When Using Our Services: We will automatically collect information related to you through various technologies: when you visit this website or our services, when you download content from the relevant platforms we provide, when you open the emails we send or click on the links in the emails, and when you interact or communicate with us.
Information Obtained from Third Parties: We will collect your information from third parties when you make payments through a third-party payment service, when applicable laws may require you to authorize a third party to share your information with us, and when it is necessary for the normal and stable operation of our services and to protect your or other users' legitimate interests.
Personal Information We Collect
We collect and use personal information (collectively referred to as "Service Information") collected or generated in the process of providing and managing services and related technologies, excluding any Customer Information.
Service Information includes:
Account Information: Your name, email address, address, phone number, contact information, basic company information (such as company name, industry type, designated contact information), information about your organization and contacts (such as information about your colleagues or personnel in your organization), username and aliases, password, and network technology information such as IP address.
Settings and Configuration Information: Configuration and setting records, including resource identifiers and attributes, as well as service and security settings for data and other resources.
Technical and Operational Information: Usage and device data (such as service indicator information, Internet Protocol ("IP") address, device type, operating system and platform, service usage, log information, and network and connection information), activity data (such as browsing data, the time you use the electronic surfing cloud, the frequency of your use of our services, and your preferences), identifiers and information contained in cookies, and access data.
Direct Communication Information: Feedback, certificates, inquiries, support tickets, and information from any form of communication with us (including phone calls, chat sessions, emails, activities, or images (still images, videos, and in some cases, three-dimensional images), sounds, and other personal identifiers involved when using specific recommended services).
You have the right to choose not to provide or disclose your personal information to us. However, if you refuse to provide or do not allow us to collect your personal information, we may not be able to provide you with certain information or services, or you may not be able to access certain parts of this website. We will retain your personal information only to the extent necessary to achieve the following purposes.
How We Use Your Personal Information
Your personal information is used to provide and improve services. We will use your personal information for the following purposes:
Providing Services: To provide and deliver services and handle service-related activities, including registration, subscription, purchase, and payment, including sharing your information with service providers for payment and transaction fulfillment services to process your orders.
Providing Services in Mainland China: If you choose to use services provided by servers located in Mainland China (excluding Hong Kong, Macao, and Taiwan), based on the requirements of applicable laws, we will use your government-issued ID with photo (or, if you are a corporate customer, corporate user identity documents) to ensure that your account has been legally verified in accordance with local laws. You can refuse to undergo real-name authentication, but you may not be able to use functions or related services that require real-name authentication. Failure to use such functions or services does not affect your use of other functions and services.
Operating, Evaluating, Optimizing, and Developing Services: To evaluate service usage, analyze performance, fix errors, conduct tests, provide product support, conduct research, statistics, surveys, improve and develop services, and solicit your feedback.
Communicating with You: To communicate with you about services through different channels (such as phone, SMS, email, and in-app messages) and respond to your requests.
Recommendation: To recommend suitable services to you and understand your preferences.
Marketing: To market and promote services to you. We may display promotional information related to services.
Fulfilling Legal Obligations: To comply with applicable laws, legal procedures, or legitimate government requests, or in response to any claims or potential claims against us or our parent company, shareholders, subsidiaries, and affiliated companies. For example, we collect your bank account information from a third-party payment service receiving institution for identity verification.
Preventing Fraud, Abuse, and Credit Risks: To detect, investigate, and prevent activities that may violate our policies and identify activities that cause security problems, fraud, abuse, or illegal acts to protect the security of our customers, the website, and other parties. We may use scoring methods to evaluate and manage credit risks.
Other Purposes: We also need to obtain your consent when necessary to use your personal information for other specific purposes communicated to you.
How We Share and Transfer Your Personal Information
Customer privacy is one of the most important parts of our business. We will not disclose or transfer your personal information to third parties casually, except in the following situations:
Sharing Personal Information with Our Affiliated Companies: Affiliated companies are bound by this privacy policy or follow equivalent protection as this privacy policy.
Third-Party Service Providers: We may hire other companies to carry out related activities, such as delivering hardware, sending communications, processing payments, conducting real-name authentication, evaluating credit and compliance risks, analyzing data, providing marketing and sales assistance (including advertising and event management), managing customer relationships, and providing training. If you choose to purchase services in Mainland China, we need a third-party service provider that provides authentication services to verify your real identity information.
Business Transfer: As our business continues to develop, we may sell or acquire businesses or services. In such transactions, personal information usually becomes part of the transferred business assets but is still subject to the privacy policy before the transfer. In addition, although it is unlikely to happen, in the event that we or most of our assets are acquired, your information will also be transferred. When this happens, we will give you prior notice and ask for your appropriate consent or refusal to transfer.
Protection of Ourselves and Others: To comply with applicable laws, enforce or apply our terms and other agreements, or protect our or others' rights, property, or security, we will disclose account and other personal information when we deem it appropriate, including exchanging information with other companies and organizations to prevent and identify fraud and reduce credit risks.
Sharing with Your Consent: In addition to the above situations, when your personal information will be shared with a third party, you will be notified and have the opportunity to choose not to share the information with the third party.
Whenever we transfer, store, or process your personal information, we will take appropriate measures to protect your personal data. These measures may include adopting standard contractual clauses of applicable laws, obtaining your consent, or using other legal means to transfer your personal information.
How We Protect Your Personal Information
The security, integrity, and confidentiality of your personal information are among the most important aspects of the website. We consider your security and privacy when designing our systems. We will process your personal information for necessary purposes and take reasonable and feasible measures to avoid processing irrelevant personal information. Due to technological limitations and various possible malicious means, in the Internet environment, even if we try our best to strengthen security measures, there may still be vulnerabilities. We have formulated and implemented technical and organizational data security measures to prevent unauthorized access, disclosure, use, modification, damage, or loss of your information, including:
We use encryption technology to protect the security of your information during transmission to the service or from the service.
We regularly review our service data collection, storage, and processing operations, including our technical and physical data security measures, to prevent unauthorized access to our systems.
We only allow authorized employees and agents to process personal data.
We have implemented physical, electronic, and procedural safeguards related to the collection, storage, and disclosure of personal information. To ensure the security of your information, we may require you to provide identification before disclosing personal information to you.
Retention of Personal Information
We retain your personal information to enable you to continue using the services and only for the relevant purposes described in this privacy policy, to meet legal requirements (including but not limited to tax and accounting purposes), or to notify you otherwise. The length of time we retain specific personal information depends on its purpose of use or legal requirements to retain the information for a longer period. We will delete your personal information in accordance with applicable laws.
Cookies
We collect and use your information through cookies and similar technologies. Our policy on the use of cookies is as follows:
To ensure the normal operation of the website, we will store, set, or retrieve cookies on your computer or mobile device. Cookies are small data files stored on your hard drive or device memory. With the help of cookies, we can store your preferences (such as the language of your computer or mobile device, font size, and other browsing preferences) or data on the items in your shopping cart.
You can refuse or manage cookies by modifying your browser settings. If you disable the use of cookies or delete the stored cookies, you will need to change your user settings every time you use the website.
When you access third-party services through our client, view web pages created by third parties, or use applications developed by third parties, you will be prompted that these third parties may place their own cookies. These cookies are not under our control, and their use is not subject to this policy. You should pay attention to this. We cannot guarantee that these third - party entities will take protective measures for your personal data in accordance with our requirements. If you find risks in these third - party services, it is recommended that you terminate the relevant operations to protect your legitimate rights and interests. The service providers should have their own independent privacy protection policies. The third-party services you use are subject to their privacy policies. It is recommended that you read their policy content carefully.
Your Control Rights and Choices
You can view, change, correct, and delete your personal information. Under certain applicable laws, you may have other rights. Please refer to the applicable supplementary privacy policy for details. If you cannot manage your personal information by yourself, you can also contact us at any time for help. Please note that we will require you to verify your identity before you exercise your rights.
You can choose how your personal information is collected and used. We provide options on how to use your information. You can choose not to provide certain information, but you may not be able to use certain services as a result.
Account Information: If you need to view, change, correct, or delete information related to your account, we usually keep the previous version for archiving.
Message Notifications: If you do not want to receive promotional information from us, please unsubscribe or adjust the notification options in the management center. If you do not want to receive in - app notifications from us, please adjust the notification settings in the application or on your device.
Browsers and Devices: The "Help" function on most browsers and devices will tell you how to prevent your browser or device from accepting new cookies, how to make your browser notify you when it receives new cookies, or how to completely disable cookies.
Personal Information of Children
We do not provide relevant services to children. This service is only provided to individuals who have reached the legal age of adulthood under applicable laws. If a minor, that is, an individual who has not reached the legal age of adulthood under applicable laws, provides personal data to us, their parents or guardians can contact us on behalf of the minor, requesting us to stop further collecting, using, and/or disclosing the personal data and deleting the personal information we may hold about the relevant minor.
Revision of the Privacy Policy
As our business changes, our privacy policy may also change. You should regularly visit our website to check for the latest changes. You can see the release date of the latest version of this privacy policy. Unless otherwise stated, our current privacy policy applies to all personal information we have about you and your account. However, we are committed to always notifying affected customers and providing appropriate choices in the event of significant changes to our privacy policy.
Contact Information
If you have any privacy concerns or need to view, modify, or delete your personal information, please contact us and provide detailed descriptions. We will do our best to solve the problem for you:
Contact Person: Privacy Officer of China Telecom Global Limited
Email: dataprotection@chinatelecomglobal.com
If you represent your organization or interact through your organization, your personal information may also be subject to your organization's privacy policy. Please direct your privacy questions to your organization.
Supplementary Privacy Policy for the European Economic Area and the United Kingdom
This supplementary privacy policy applies to residents of the European Economic Area and the United Kingdom or the collection, processing, and use of personal data in the European Economic Area and the United Kingdom and should be read in conjunction with our privacy policy.
This policy covers the personal information collected or processed by China Telecom (Europe) Co., Ltd. as the data controller when providing services through the website and determines the methods and purposes of its data processing.
Personal Information Controller:
China Telecom (Europe) Co., Ltd. is the controller of the personal information collected for account registration, payment services, providing customer support, marketing and advertising, and operating, understanding, optimizing, developing, or improving our website, applications, products, and services. For more information on the purposes of personal information collection, please visit our privacy policy.
Personal Information Processing:
We process your personal information based on one or more of the following legal bases:
Obtaining your consent;
When necessary, entering into a contract with you or the legal entity you represent, fulfilling our contractual obligations, providing our services, responding to your requests, or providing customer support;
As stated in the China Telecom International Privacy Policy, we have legitimate interests; or
When necessary, complying with relevant laws and legal obligations, including responding to legitimate requests and orders.
Information We Retain After Your Account Is Closed:
If you decide to terminate the agreement and close your account, we will delete your personal information in accordance with applicable laws. After the account is closed, for legitimate and proper business purposes, we may need to retain certain information for a period of time. For example, for tax and accounting purposes, we may retain personal information such as your contact information (e.g., name, email address, physical address) and any invoices sent to you by China Telecom (Europe) Co., Ltd. If applicable, China Telecom (Europe) Co., Ltd. may also retain communication records with you and relevant logs (e.g., your account closure log) for dispute resolution. In addition, we may keep records to prevent fraud and ensure security, such as in the case of abuse of our services or violation of our terms.
Your Rights:
Under applicable laws, you have the right to:
Request access to the personal information we hold about you;
Request correction of inaccurate personal information;
Request deletion of personal information that is no longer needed for processing purposes, processed based on withdrawn consent, or processed in non - compliance with applicable legal requirements;
Request us to restrict the processing of personal information in case of improper processing;
Object to the processing of personal information; and
Request to take with you the personal information you provided to us (excluding information obtained from the collected data), where the processing of such personal information is based on your consent or a contract with you and is carried out in an automated manner.
Transfers Outside the European Economic Area
China Telecom (Europe) Co., Ltd. aims to limit the transfer of personal information outside the EU.
This section only concerns the information processed by China Telecom (Europe) Co., Ltd. as the controller under this policy and does not include the personal information you entrust to China Telecom (Europe) Co., Ltd., which the company processes as a data processor according to your instructions.
When we transfer your personal information outside the European Economic Area, we will operate in accordance with the terms of this privacy policy, our privacy policy, and the applicable data protection laws.
Cookies
Please refer to the Cookie statement in our privacy policy.
Contact Us and Inquiries
If you have any questions about this privacy policy, you can contact the Data Protection Officer at dataprotection@chinatelecomglobal.com. You also have the right to complain to the local data protection regulatory authority or the UK Information Commissioner's Office: ico.org.uk/for-the-public.
When you consent to our processing of your personal information for a specific purpose, you can withdraw your consent at any time, and we will stop further processing your information for that purpose.
Supplementary Privacy Policy for Hong Kong
This privacy policy applies to Hong Kong residents or the collection, processing, and use of personal information in Hong Kong and should be read in conjunction with our general privacy policy.
Sharing Your Personal Information with Affiliates and Service Providers
We collect your personal information where necessary for providing services. Your personal information may be transferred to the following categories of recipients for the purposes stipulated in our privacy policy:
Affiliates of China Telecom Global Limited.
Governments, law - enforcement agencies, courts, and tribunals.
Legal and other professional advisors.
Any third party authorized by you to obtain your personal information from China Telecom Global Limited and its affiliates.
Third - party providers offering the following services to China Telecom Global Limited:
-Payment services
-Digital services
-Other related services
Your Rights
You have the right to request the Data Protection Officer to access, correct, and delete the personal information we have collected from you.
Email of the Data Protection Officer: dataprotection@chinatelecomglobal.com
Address: Everbright Centre, 108 Gloucester Road, Wanchai, Hong Kong, China
Contact Us
If you have any comments or questions about this privacy policy, please email dataprotection@chinatelecomglobal.com.