Privacy Notice

CK Hutchison Group Telecom Holdings Limited, incorporated in the Cayman Islands with limited liability (“CK Hutchison Group Telecom”) takes your privacy very seriously. This is our privacy policy for the website (www.ckhutchisontelecom.com) (the “Site”). We have created this privacy notice to ensure that you understand how your personal data will be used if you use this Site and that you understand your rights under data protection legislation.

This notice applies only to the Site, and not to any other website or service. If you do not agree with this notice, then you should not use the Site. It is important that you read this privacy notice together with any other fair processing notices we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements other notices and policies and is not intended to override them.

WHO WE ARE

CK Hutchison Group Telecom Holdings Limited is the controller and responsible for your personal data (collectively referred to as “company”, “we”, “us” or “our” in this privacy policy).

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact us as follows:

Full name of legal entity: CK Hutchison Group Telecom Holdings Limited

Email address: ir@ckhutchisontelecom.com

You have the right to make a complaint at any time to a relevant supervisory authority for data protection issues (see here). We would, however, appreciate the chance to deal with your concerns before you do so, so please contact us in the first instance.

PERSONAL DATA WE COLLECT ABOUT YOU

We are responsible for your personal data that we collect via this Site. We collect and store personal data about you if you voluntarily submit it to us. In particular, we collect the following information should you choose to (i) complete an investor registration form in order to receive notifications of the release dates of the company’s financial information, email alerts (and links to) company announcements, invitations to company webcasts and certain other information and/or (ii) register to participate in a company webcast:

  • Your name
  • Your email address
  • Your company name
  • Your job title
  • Your telephone
  • Your address
  • Investor category

We will also collect technical data such as your internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website (including a company webcast). If you email the address provided on the ‘Investor Contact’ page and request for us to contact you, we will also collect any other information you provide in your email to us.

As you interact with our website, we will automatically collect data about your browsing actions and patterns for the purposes of maintaining the functionality of the website (and company webcasts), and to inform us on how to enhance your experience. We collect this personal data by using cookies and similar technology. Please see the section ‘COOKIES AND SIMILAR TECHNOLOGY’ below for further details.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data in compliance with the legal bases for processing personal data under Article 6 of the General Data Protection Regulation (GDPR), including in particular:

  • Where you have given your consent for your personal data to be processed for the purposes of receiving information about the company.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

You have a right to withdraw consent at any time by contacting us. If you withdraw your consent, this does not affect the lawfulness of any processing that we carried out prior to that withdrawal.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

If you choose to submit an investor registration form, we will use the personal data that you submit in that registration form to send you emails from time to time relating to the release dates of the company’s financial information, email alerts (and links to) company announcements, invitations to company webcasts and certain other information which investors may find useful.

If you choose to register to participate in a company webcast, we will use the personal data that you submit in the registration form to enable you to participate company webcasts from time to time.

If you email the address provided on the ‘Investor Contact’ page and request for us to contact you, we will use the personal data you provide in that email to contact you as requested. We may also store that information together with the personal data you provided when you submitted the registration form through our Site. We may use that information (in whole or in part) when fulfilling the purposes described herein.

We will use data (including your personal data) where it is necessary for our legitimate interests, including in order to administer and protect our business and this Site (including troubleshooting, data analysis, system maintenance) and to deliver relevant website content to you and measure or understand the effectiveness of the content we serve to you.

We do not sell your personal data or share it with third parties (and will only share personal data with certain members of the CK Hutchison Holdings Limited group (the “CKHH Group”) for the purpose of carrying out functions that support us in fulfilling the purposes set out in this notice). However, we reserve the right to transfer any information to our successors in business and purchasers of a particular division or line of our business (subject to our compliance with all applicable legal and regulatory obligations).

We also reserve the right to access and/or disclose any information as required by courts or administrative agencies and to the extent necessary to permit us to investigate suspected fraud, harassment or other violations of any law, rule or regulation, the Site rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper, where such processing is required by law or where it is in our legitimate interests.

DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of contacting you where you requested it, for providing you with further information from time to time where you request it, and for satisfying any legal, regulatory, tax, accounting or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

YOUR RIGHTS

You have rights under data protection laws in relation to your personal data. If you wish to exercise those rights, for example to access, correct, object to, erase, restrict or transfer your personal data in our database, or to withdraw your consent to us using it, please contact us at <ir@ckhutchisontelecom.com>. You will not have to pay a fee to access your personal data (or to exercise any other rights under data protection laws). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

It is important to make sure your personal data is kept up to date. If you wish to change or modify your information previously provided, please contact us using the contact details provided above.

DATA TRANSFERS AND SECURITY

We may share your personal data with other members of the CKHH Group that carry out functions that support us in fulfilling the purposes set out in this notice. This may involve transferring your data outside the European Economic Area. Whenever we transfer your personal data out of the EEA, we will ensure appropriate safeguards are afforded to your personal data by ensuring at least one of the following safeguards is implemented:

  • We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • We may use specific contracts or contractual clauses approved by the European Commission which give personal data the same protection it has in Europe.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information about the specific mechanism we use when transferring your personal data out of the EEA.

We are committed to taking reasonable steps to ensure the security of your information in line with our legal and regulatory obligations. To prevent unauthorised access, maintain data accuracy, and ensure the appropriate use of information, we have put into place appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account the nature, scope, context and purposes of the processing we undertake. However, due to the inherent open nature of the Internet, we cannot guarantee that communications between you and us or information stored on this Site or our servers, will be completely free from unauthorized access by third parties such as hackers.

We may transfer your personal data to third party data processors to process personal data for the purposes set out in this notice. The data processors may carry out instructions related to the distribution of emails, the facilitation of participation in company webcasts and other IT system support and maintenance, and will be subject to contractual obligations to implement appropriate technical and organisational security measures to safeguard the personal data, and to process the personal data only as instructed by us.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. However, if we plan to materially change the way in which we use or disclose your personally identifiable information, we will provide you with prior notice and a chance to opt-out of such differing uses.

We may amend our privacy notice at any time and will post those changes on this page, so you are always aware of what information we collect, how we use it and under what circumstances we may disclose it.

COOKIES AND SIMILAR TECHNOLOGY

A cookie is a small data file that is stored on your device when you visit certain websites. We use cookies for basic website functionality and to determine if you have previously visited this website and have already accepted our cookie notice. A cookie file can contain various types of information, including a user ID that the Site uses to track the pages you have visited.

Most browsers are initially set up to accept cookies; however, you can reset your browser to refuse all cookies or indicate when a cookie is being sent, or you can erase cookies from your browser from time to time. (Note: you may need to consult the help area of your browser application for instructions, or visit www.allaboutcookies.org for further information.) If you choose to disable cookies or refuse to accept a cookie, you may not be able to utilise all features of the Site.

Effective Date

This privacy notice was last updated on 18 March 2020.

We use cookies to help us personalise and improve your experience. By continuing to use the website, you are agreeing to this.
Please read the section ‘COOKIES AND SIMILAR TECHNOLOGY’ in our Privacy Notice.