PRIVACY POLICY

1. Introduction

1.1 ADT Alarm Monitoring Hong Kong Limited, including its subsidiaries and affiliated companies of the same group (referred to hereinafter as “we”, “us”, “ours” or “ADT”), respects your Personal Data and is committed to ensuring that your Personal Data will be handled by us in a manner in compliance with the Personal Data (Privacy) Ordinance (Cap.486 of Laws of Hong Kong).

1.2 Personal data referred to in this Privacy Policy means information that can identify you in a form which access to or processing of it is practicable. This Privacy Policy sets out the terms and conditions on how we may collect, use, process, store and handle your Personal Data when you visit our website, (https://www.adt.com.hk/) (“Website”), and/or use any of our products and/or services (“Products and/or Services”).

1.3 Please review this Privacy policy carefully. By accessing and using our Website and/or our Products and/or Services, you shall be regarded as having agreed and accepted our Privacy Policy with respect to the collection and handling of your Personal Data.

1.4 We reserve the right to modify this Privacy Policy from time to time and the updated Privacy Policy shall become effective at the time of its publication on our Website. If we make material changes to this Privacy Policy, we will notify you by email or other written notices. Your continued access and use of the Website or our Products and/or Services shall constitute your acceptance to all the amendments made to the Privacy Policy. We recommend you visiting our Privacy Policy on a regular basis to understand our latest Privacy Policy. IF YOU DO NOT ACCEPT ANY TERM OF THIS PRIVACY POLICY, PLEASE REFRAIN FROM ACCESSING OR USING THE WEBSITE or our PRODUCTS AND/OR SERVICES IMMEDIATELY.

2. INFORMATION COLLECTED BY US

2.1 We may collect the following Personal Data from you which are reasonably necessary for the Purposes set out in Clause 3 hereunder:

2.1.1 Identification and contact data, including but not limited to your full name, e-mail address, contact phone number, home or business address, account numbers, other information relevant to purchasing/subscribing to our Products and/or Services and other data you choose to provide to us voluntarily in connection with our Website or Products and/or Services;

2.1.2 Payment-related data, including but not limited to your preferred payment method, bank account numbers, credit card credentials, billing address or other payment-related information;

2.1.3 Usage and technical data, including but not limited to your IP address, mobile device identifier, operating system, browser type, configurations, language preferences, the referring website, click-activities on the Website, duration of the visit and data which we collect automatically using cookies and similar technologies (see below);

2.1.4 job application data, including but not limited to your past work experience, qualifications or other information that you provide us voluntarily in connection with a job application; and

2.1.5 any other information or data that we collect from you with your consent for specific purposes made known to you at the time of data collection.

2.2 For all the information provided by you to us (such as by filling in our forms online or offline), you represent and warrant that all information you provided to us is complete, true and accurate in all aspects and is not false, misleading or deceptive in any respect.

2.3 We may collect your Personal Data by asking you to fill in forms or by corresponding or interacting with us. Some of your Personal Data will be collected by automated means using cookies and similar technologies (see below).

2.4 When we request Personal Data from you, we will notify you at the time whether the collection is mandatory for us allow access to our Website and/or provide our Products and/or Services. While you can choose not to provide some or all of the Personal Data we ask for, you may be prevented from using some of our Website’s services and/or our Products and/or Services if such data is mandatory for the Purposes or is otherwise for our legitimate interests.

3. PURPOSES FOR COLLECTION OF PERSONAL DATA

We shall use your Personal Data for the purposes set forth below in accordance with other terms and conditions of this Privacy Policy (collectively, the “Purposes”):

to maintain, operate, manage and provide our Website and/or Products and/or Services to you;
to verify your identity and to administer and manage your account with us;
to evaluate, customise and improve the content and functionality of our Website and to enhance overall users’ experience;
to send confirmation notices, updates, and security alerts to you or to communicate with you in response to your requests and enquires;
to administer and enroll users in contests, lucky draws or other promotional events;
to handle any payment instructions, process payment or financial-related matters;
to prepare contents or features that suit your interests and purposes;
to conduct survey and research for us to market and develop Products and/or Services;
to detect and/or protect users against error, fraud, infringement and/or other malicious or criminal activities;
to review, administer and process job applications; and
for other purposes made known to you at the time of collection.

4.DIRECT MARKETING

4.1 Subject to your separate consent, we may use your Personal Data to send marketing and promotional information to you regarding our Website, Products and/or Services or news and events of ADT. You may choose to (i) opt-out of our use of your Personal Data for direct marketing or (ii) withdraw any consent previously given to us if you do not want wish to receive any direct marketing materials from us.

5. DISCLOSURE AND TRANSFER OF PERSONAL DATA

5.1 We are not in the business of Personal Data trading. We consider keeping your Personal Data confidential and secured to be a vital part of our relationship with our customers and we treat it with great care and respect. There are, however, certain circumstances under which we may share your Personal Data with certain third parties, which may locate outside the jurisdiction. You hereby consent to us disclosing and transferring your Personal Data to the following recipients (“Recipients”):

5.1.1 Our affiliates. We may disclose your Personal Data to any parent company, subsidiaries or affiliates of ADT for the Purposes;

5.1.2 Our service providers and subcontractors. We may disclose your Personal Data to our service providers, agents and subcontractors for them to process your Personal Data for the Purposes on our behalf. Service providers include but without limitation, payment gateways or other payment processors, website hosting companies and severs, cloud services providers, data storage and management services providers, communication and public relation specialists, market research and profiling services providers, couriers, technicians, contests/surveys sponsors etc.;

5.1.3 Our business partners. We work closely with certain businesses to provide you with high quality products and services. On occasion, these companies make special offers available to our customers. You will have an opportunity to receive information about these offers if you so elect and we will share your Personal Data with these companies so that they can send you the details about their special offers directly. Each of these companies has its own policies with regard to the collection and use of Personal Data and we shall not be responsible for their use of your Personal Data;

5.1.4 Assignees. If ADT undergoes restructuring or is sold to another organisation, we may disclose Personal Data in connection with the sale, assignment, or other transfer of the business to which the data relates.

5.1.5 Law enforcement bodies. We may release account information and other Personal Data when required by applicable laws and regulations or pursuant to a valid court order of any jurisdiction, or as requested by any government or law enforcement authorities or administrative bodies.

5.1.6 Others. We may disclose your Personal Data in order to enforce or exercise our rights and obligations under this Privacy Policy or other applicable terms and conditions or contracts made between ADT and you and to protect the rights, property or safety of our users, ADT or others. In addition, we may exchange information with other organisations for fraud protection and risk reduction.

5.2 Your Personal Data may be disclosed to the Recipients engaged by us from time to time and they may locate in other countries/jurisdictions that may not have the same level of data protection as in the Hong Kong Special Administrative Region (“Hong Kong”). We shall take reasonable contractual measures to ensure that these Recipients only process your Personal Data for the Purposes set forth in this Privacy Policy but no other purposes and they should adequately protect your Personal Data from any unauthorised use, access, disclosure deletion or alteration.

6. USER-GENERATED CONTENT

6.1 We may offer features that allow you to post comments, photos, videos and other user-generated content on the public areas of the Website (“User-generated Content”). You acknowledge that your account name and photo may be associated with such User-generated Content which will be accessible by the public. You are strongly advised not to disclose (and we will never require you to provide publicly), your Personal Data on the public areas of the Website.

6.2 We do not control and are not responsible for, the actions of other users of the Website with respect to any information you post publicly on our Website. We may share any user-generated content that you submitted to the Website regarding ADT or any of our Products and/or Services to third-party sites and advertising or marketing services providers.

6.3 You agree that all User-generated Content that you, or individual(s) acting on your behalf, provide to us will not be considered confidential or treated as proprietary materials except specifically stated otherwise on this Website. By providing any such User-generated Content to us, you irrevocably grant us an unrestricted, worldwide, royalty-free license to use, reproduce, display, transmit, distribute and create derivative works from such User-generated Content, and you further agree that we are free to use any of the underlying ideas, concepts or know-how of such User-generated Content, that you or the individuals acting on your behalf provide to us.

7. SECURITY AND RETENTION

7.1 By having in place appropriate administrative, technical and physical safeguards, we use reasonable efforts to protect your Personal Data from any unauthorised use, access, disclosure, deletion or alteration. However, you acknowledge that no security measure is completely secure when it comes to data protection. To the extent permitted by applicable laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of data breach.

7.2 You are solely responsible for maintaining the security and confidentiality of your account login credentials and passwords that you may create or receive. You are responsible for all the activities in your account, whether or not such activities or instructions come directly from you or are otherwise authorised by you. You agree to notify us immediately of any unauthorised use of your login credentials or passwords. We may collect Personal Data from you for authenticating your identity to recover any lost or compromised accounts or passwords.

7.3 Personal data will only be retained by us or our service providers for as long as is necessary to fulfil the Purposes of their collection.

7.4 In some cases, we may aggregate and process Personal Data in a manner where such data can no longer be used, whether directly or indirectly with other data points, to identify any individual. Any such anonymised data ceases to be personal and will not be subject to this Privacy Policy.

8. THIRD-PARTIES’ LINKS

8.1 There may be external links that will cause you to leave our Website and lead you to websites of other third-parties. Unless otherwise indicated in writing, all external websites are not under our control and we shall not be responsible for the content of such external websites or any link contained therein. You acknowledge that the existence of external links to websites do not constitute and is not an endorsement by us in favour of such external websites or the products or services provided by such external websites. We do not give any warranty and disclaim all the responsibilities whatsoever for any aspect of such external websites.

8.2 We advise you to read and review the terms of use and privacy policy of such external websites to understand your rights and obligations in accessing and using those external websites and the associated products and services.

9. ACCESS TO PERSONAL DATA

9.1 You may contact us and request to access, correct or to have a copy of your Personal Data that is in our possession or under our control by sending a written request to us at email:adthk-cs@adt.com.hk

9.2 We shall process your request within a reasonable time unless otherwise prohibited to do so by any applicable laws or regulations. To the extent permitted by applicable laws, we may charge reasonable administration fees for processing and handling your request.

9.3 You may contact us to withdraw any consent given to us for our collection, use and/or disclosure of any of your Personal Data in our possession or under our control. However, you may not be able to enjoy all our features on our Website or use some or all of our Products and/or Services, depending on the nature of the consent being withdrawn. In any events, whilst we may cease using your Personal Data in response to your consent withdrawal, we may retain and disclose your Personal Data strictly for compliance, regulatory or other legal purposes.

10. COOKIES AND WEB ANALYTICS

10.1 To help us better manage the content of our Website and to improve our Products and/or Services, various technologies are used on our Website which may lead to data being collected automatically by us or by our contractors, such as our advertising partner(s). Examples of such technologies are cookies and web analytics.

10.2 Cookies are used to track the online activities of web users in relation to their access and use of the Website. When you visit our Website, data (which alone may not identify any individual) may be sent to your browser and then stored on your device. We do not link the information we store in cookies to any personally identifiable information you submitted to us while visiting our Website.

10.3 We use cookies to enhance navigation and functionality of the Website, to securely verify your identity, and to personalise aspects of your experience on this Website. You may change your cookies settings on your browser and may block cookies on our Website. However, doing so may affect your ability to log in to certain areas of our Website, use certain tools and view certain content on this Website. We recommend that you enable cookies on our Website so that you may enjoy the full advantage of our Website’s best features.

10.4 We or our contractors may also collect statistical data about your browsing activities and patterns. This data does not reveal your identity and will be used for us to improve your experience on our Website and for our internal analysis purposes.

11. SEVERANCE

11.1 If any part or provision of this Privacy Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

12. LANGUAGE

12.1This Privacy Policy is written in the English language and may be translated into any other languages. If there is any inconsistency between the English version and any translated version of this Privacy Policy the English version shall prevail.

13. GOVERNING LAW

13.1 This Privacy Policy shall be governed by, and construed in accordance with, the laws of Hong Kong. Any dispute, difference or claim arising out of or in connection with this Privacy Policy may be heard by the Courts of Hong Kong and the parties hereto irrevocably submit to the exclusive jurisdiction of such court in connection with any such dispute, difference or claim.

1 December, 2021 Revised