Protecting your privacy
We are dedicated to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the "Ordinance"), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the "GDPR") and other relevant regulations where applicable.
We may collect, use and hold a range of different Data about you. For the purposes of carrying on our business (including the verification of your identity to detect, prevent and address fraud, security or technical issues, the registration, activation and management of your account with us, developing and providing various financial and consultation services and the billing and charging of our products and services (if applicable) (collectively, "Service(s)")) and complying with laws, rules, guidelines, regulations and/or requests issued by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies, you may be requested to provide Data such as, but not limited to:
(a) the name, birth month and other details documented on your passport or other legal identity card and/or travel document;
(b) the nationality/place of residence/location/personal information declared by you and other relevant documents;
(c) contact details including but not limited to name, address, phone number, mobile telephone number and/or email address, etc.;
(d) Data that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details), etc.;
(e) payment details including but not limited to credit card, debit card and other electronic banking Data;
(f) account details or Data relating to Services registered with us including but not limited to the relevant PIN, username or password, account numbers and/or service numbers;
(g) device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
(h) information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
(i) your credit and service history to enable us to assess your eligibility to our offers of Services or to accommodate your request for transfer of Services or your account with us;
(j) all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
(k) any other Data as may be required by any members of us and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Services.
(l) In some instances, where required by law to do so, we may seek your consent to process the following types of "Special Data" to us so that we may further improve our Services and/or better tailor the type of information or content that we present to you:
(ii) gender and ethnicity;
(iii) marital status;
(iv) Month of birth;
(v) education and profession;
(vi) monthly income range;
(vii) hobbies and leisure activities;
(viii) the Services that you have subscribed for; and
(ix) contact details, etc.
Provision of the Special Data mentioned immediately above is optional although, where the requested Service is a personalised Service or provision of a product is dependent upon your provision of all requested Data, failure to provide the requested Data may prevent us from providing those particular Services to you.
How we collect Data
We collect Data in a number of ways, including from:
(a) you directly, for example, when you provide Data by phone or via email, attend our functions, complete an application form or agreement for one of our Services, or when you submit your Data through our websites, mobile apps, or online chat sessions; or when you contact us with a query or request; or during the ordinary course of the continuation of our business relationship with you; or when we are legally required to do so;
(b) third parties such as related entities, business partners, or other customers, or your representatives with appropriate consent from you;
(c) publicly available sources;
(d) our own records of how you use our Services;
(e) your visits on our websites, or mobile apps (see "Privacy Data" section below); and/or
(f) your participation in surveys or marketing promotions organised by us or on our behalf, etc.
Participation in Voting Activities or Activities with Prize Incentives
When participating in promotional activities organized by our online media or co-organized by our business parties, users may not be required to be registered as our member but will be required to provide personal data for registration.
To better serve your needs and preferences, our web servers may collect Data relating to your website, device or app activity. We may also collect aggregated, anonymous, statistical data on the server's usage so that we may better cater to the behavior of users of our websites and mobile apps. This type of Data may include, but is not limited to:
(a) browser type, version and user agent;
(b) operating system;
(c) IP (Internet Protocol) address and/or domain name;
(d) connection data, statistics on page views and/or referral URLs;
(e) device ID, location and phone contacts;
(f) videos watched or searched for;
(g) links or images clicked on;
(h) cookies and/or browser, app or web server log data; and
(i) device and software characteristics and/or configuration.
Cookies are small text files that can be stored on a user's computer, tablet or mobile device ("your Device") when you visit a website. A cookie will typically contain the name of the originating domain, the lifetime of the cookie, and a randomly generated unique number or other value. The cookie itself is anonymous and does not contain any personal data, except when such data is supplied by you, for instance, when you provide your name and email address when completing a registration form.
How we use your Data
We may collect, retain and use your Data for the following purposes:
(a) to verify your identity;
(b) to submit your information (including but not limited to the application for the transfer of the account (if applicable)) and related documents to the designated third party institution according to your declared nationality/place of residence/location/personal information;
(c) to facilitate daily operations of services provided to you;
(d) to tailor-make services or related products in relation to your transactions;
(e) meeting the requirements to make disclosure under the requirements of any rule, regulation or law binding on ECG;
(f) to provide any Services in relation to your account held with us;
(g) to process your application to subscribe to our Services;
(h) to carry out matching procedures, as defined under the Ordinance;
(i) to verify your eligibility to our offers of Services, games and/or promotions or other events;
(j) to provide, activate and/or renew Services, membership program and/or relevant services or plans that you may have subscribed for;
(k) to provide you with promotional benefits, updates, offers and invitation to events;
(l) to promote and market our Services to you;
(m) to provide suitable advertisement and website contents to you;
(n) to provide suitable products or services to you;
(o) to provide anonymous report and to send member notice to us or our clients;
(p) to conduct credit checks and detect fraudulent activities in compliance with the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Chapter 615 of the Laws of Hong Kong) or any other relevant regulations and in relation to other compliance purposes;
(q) to perform statistical analyses or research or analyses so that we may improve and optimise the Services that can be made available to you;
(r) to conduct surveys and marketing, promotional, behavioral scoring for business operations and/or planning purposes;
(s) to carry out market and product analyses in order to generate statistical or actuarial reports (containing aggregated data that does not relate to any identified or identifiable individual);
(t) to process any payment instructions, direct debit facilities and/or credit facilities in relation to our supply of Services to you;
(u) to maintain and develop our business systems and infrastructure, including testing and upgrading of these systems;
(v) to maintain, enhance and develop our products and service offerings;
(w) to determine the amount of debt owed by you or your default; (if any)
(x) to charge you arrears, interest and handling fees; (if any)
(y) to assist in daily lending matters; (if any)
(z) to assist in the required review of the loan; (if any)
(aa) to evaluate the level of indebtedness owed to or by you from time to time; (if any)
(bb) to determine the amount of indebtedness owed to or by you;
(cc) to collect amounts outstanding from you and those providing security for your obligation;
(dd) to assist other financial institutions to conduct credit checks and collect debts;
(ee) to perform any acts in relation to any of the aforesaid;
(ff) to comply with applicable laws in or outside Hong Kong as may be required by applicable government authorities, courts, law enforcement, or regulatory or investigation bodies, in relation to the supply of Services and/or loyalty programs to you, including to assist in the prevention, detection of crime or possible criminal activities; and
(gg) to distribute our publications and research materials as well as those of our business partners and counterparties.
Our legal basis for using your Data including how we disclose your Data
We have a legitimate interest in properly administering the Services. In addition, our use of your personal data may be necessary for the performance of the Services that you have requested. In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organisations or parties outside of ECG (which may be within or outside of Hong Kong) (collectively, "Organisations"). Your Data is disclosed to these Organisations for the strict purpose of enabling us to supply our Services to you but is not applicable to any Organisations which are not owned by ECG or of which its company policies are not controlled by ECG as well as any persons employed or managed by ECG.
In some circumstances as mentioned above, we may need to ask for your consent to use your Special Data where required by law to do so.
These Organisations provide support services to our businesses and operations including without limitation:
(a) customer enquiries;
(b) mailing operations;
(c) billing and debt-recovery functions;
(d) information technology services;
(e) installation, maintenance and repair services;
(f) marketing, advertising and telemarketing services;
(g) market research;
(h) customer usage and behavioral analysis;
(i) process management;
(j) surveys; and
(k) website usage analysis, etc.
We take the required steps to ensure that these Organisations are bound by appropriate confidentiality and privacy obligations in relation to the protection of your Data and that they use your Data for the sole purpose of carrying out the services for which they have been engaged, and not for their own or other purposes (including direct marketing).
In addition, we may disclose your Data:
(a) to us and the designated company for the purpose of providing services or product promotion;
(b) to any director, officer, employee or representative of the company (when performing the business of the company);
(c) to any person authorized by us to handle confidential information;
(d) to your authorised representatives and/or your legal advisers when requested by you to do so;
(e) for the purposes of providing administrative, payment, collection, business, legal and/or operational support, to the following parties:
(i) telecommunications network operators;
(ii) administrative, telecommunications, computer, data processing contractors;
(iii) online network maintenance contractors;
(iv) securities settlement, agent, custodian;
(v) our affiliates, overseas offices, assignees, transferees and representatives;
(vi) our professional advisers, including but not limited to our accountants, auditors, lawyers, valuers and insurers;
(f) to third party financial institutions, banks, hotels, insurance companies, insurance brokers, underwriters, securities and investment service providers, billing agents and various business collaborators for reward redemption purposes and benefits applicable to members of our loyalty programs, including without limitation for the purpose of registering members for loyalty program related events;
(g) to any financial institution and its affiliates with whom you wish to establish or have a business relationship with;
(h) to a credit reference agency and (if there is a default) financial company;
(i) to government and regulatory authorities and other organisations, as required or authorised by law;
(j) to any proposed or actual participant, assignee or transferee of all or any part of the relevant member of our operations or business; and/or
(k) to charities or non-profit organisations, etc.
Direct Marketing (if applicable)
We will provide you with relevant magazines and online media information, promotional campaigns and client advertising information. We may, in compliance with applicable laws, rules, regulations and licence requirements, use your Data (including without limitation name, contact information, phone number, residential/office address, email address, product and services combination information, transaction pattern, financial background and population statistics), for us (including NMG and its respective subsidiaries, affiliates and associated companies) and our respective dealers, suppliers, licensors, providers, advertising clients and/or business partners (collectively, "Service Providers")) to provide you with direct marketing content (pursuant to which we may or may not receive remuneration in return), including sending to you notices and/or updates about gifts, discounts, privileged offers, benefits and promotions related to Services offered by us, financial and investment advice, any use related to the transaction, business promotion and promotion activities of the company for the aforementioned products or services and/or the Service Providers, including without limitation: entertainment, information services (such as weather, finance and news information), device accessories, mobile applications and software, lifestyle, networking events, travelling, alcohol and tobacco, sports, music, gaming, transportation, household products, food and beverages, hotel, banking, finance, loan, insurance, wealth management services, investments, education, health and wellness, beauty and cosmetics products and services, entertainment, films, cinemas, fashion and accessories, computers and electronics, social networking, technology, e-commerce, logistics, retail, real estates and shopping malls, home and décor, media and high-end consumer products and services. Marketing may be carried out in a variety of ways (such as in the form of a letter, bill insert/message, email, digital SMS, MMS, instant message, app push notification, by telephone, social media or advertisements on websites or other means).
We will honour each individual's request to not use his/her Data for the purposes of direct marketing. You may opt-out from receiving direct marketing material and/or communications from the relevant Service and/or any notices from us. At the same time, you may resume receiving the same (if you have previously opted-out of receiving such material and/or communications from the relevant Service) by making a written request to our Data Protection Officer together with your registered name and service account number, registered telephone number or login name (as applicable).
Transfer of Data outside Hong Kong
At times it may be necessary and/or prudent for us to transfer your Data to places outside of Hong Kong, for instance, for the prevention, detection or investigation of crime or for storage, processing and other purposes for which the Data were collected. In the event that we do transfer your Data to places outside of Hong Kong, we will do so in compliance with the prevailing requirements of the Ordinance, other relevant regulations and the GDPR where applicablth ee.
The safety of your Data is important to us
When we pass your Data to third party Organisations for them to process, we seek to ensure that they have appropriate security measures in place to keep your Data safe and to comply with applicable principles in relation to data protection. Some of the people we share your Data with may process it overseas. You can contact us for more information about the safeguards we use to ensure that your Data is adequately protected in these circumstances.
Retention of your Data
We will retain your Data in accordance with our internal policies. Our policies are in compliance with the Ordinance and the GDPR where applicable, and cover the following principles:
(a) Data will only be retained for as long as is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
(b) Data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.
Your right to access, correct and delete Data
We take all reasonable precautions to ensure that the Data we collect, use and disclose is accurate, complete and up-to-date. However, the accuracy of that Data depends to a large extent on the Data you provide. You have a right to request access to, and correction of, your Data and we recommend that you:
(a) let us know if there are any errors in your Data; and
(b) keep us up-to-date with changes to your Data.
If you wish to access or amend any of your Data we hold, or request that we delete any of your information that is no longer necessary for the provision of our Services, you may contact us in the manner as set forth under the "How to Contact Us" section.
You may exercise your right of access and correction by writing to our Data Protection Officer at the details stated in the "How to contact us" section below.
You may decline to share Data with us and/or withdraw any consents which you may have provided, in which case, we may not be able to provide you with some of our Services.
At any time, you may object to us holding or processing your Data, on legitimate grounds, save and except as otherwise permitted by the applicable law.
Unless specially required or requested by us, please do not send or publish any personal sensitive data (e.g. contents in relations to race, political views, religious or other beliefs, health record, criminal record or chamber membership, etc.) to us or through our websites or social media platforms. If we specially required or requested your provision of sensitive data, we must obtain your prior express consent.
How to contact us
For all issues and enquiries regarding our compliance with our obligations under the Ordinance and the GDPR where applicable, and any request for access to, correction or deletion of your Data, please contact our Data Protection Officer together with your signed proof of identity documents via email to email@example.com, fax to 2699 9495 or telephone at 2919 2919.
To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.