Privacy Policy

 

Privacy Policy Statement

 

Effective Date: 21 January 2019

 

1. Introduction

When Joint Electronic Teller Services Ltd. (JETCO) (the "JETCO") collects any of customer personal data or information, it is our policy to comply fully with the applicable laws and regulations concerning the collection and use of personal data and information. Personal data is any information relating to any living individual from which it is possible to identify that individual. In dealing with personal data, we will ensure compliance by our staff with the strictest standards of security and confidentiality. We are equally committed to ensuring that all our agents and third parties we disclose Personal Data to, uphold these obligations.

 

 

2. Privacy Commitment

Our commitment to comply with the said applicable laws and regulations is premised on the following principles:

      1. We collect only necessary personal data from customers for the provision of services and products.
      2. Personal data will only be used for the purposes specified and not for other purposes except with the consent of our customers.  
      3. We will not disclose personal data to any external organization unless we (i) have the consent of our customers or (ii) are required by law, but we will only do so under proper authority.
      4. All practicable steps will be taken to ensure customers’ personal data are kept secure, confidential and accurate. Such data will not be retained longer than it is necessary.
      5. Only authorized personnel can access or process the personal data of customers.
      6. Customers have the right to access or correct their personal data 

 

3. Types of Personal Data Held by JETCO

    3.1 Personal data held by JETCO for the purpose of carrying on JETCO’s businesses include, but not limited to, the following:

      1. Your full name as registered for your bank account;
      2. Bank account details, including bank account numbers; 
      3. Contact details, including smartphone number, email address, job title and employer’s name;
      4. Payment details, including credit card, debit card and banking information;
      5. Any other information obtained by JETCO in the ordinary course of continuation of the business relationship;
      6. f. Information which is in the public domain

 

    3.2 Personal data relating to employment held by JETCO may include the following:

      1. Name and address, contact details, date of birth and nationality of employees and potential employees and their spouses and their family members and their identity card and/or passport numbers and place and date of issue thereof;
      2. Additional information complied about potential employees to assess their suitability for a job in the course of the recruitment selection process which may include references obtained from their current or former employers or other sources; 
      3. Additional information complied about employees which may include records of remuneration and benefits paid to the employees, records of job postings, transfer and training, records of medical checks, sick leave, attendance, emergency contact and other medical claims and performance appraisal reports of the employees;
      4. Relevant personal data pertaining to former employees may be required by JETCO to fulfil its obligations to the former employees and its legal obligations under certain legal requirements; and
      5. Any other information obtained by JETCO in the ordinary course of continuation of the business relationship;
      6. Information which is in the public domain

   

    3.3 JETCO may gather the personal data through the "cookies". Cookies are small bits of information automatically stored by a website on a user's computer web browser retrievable by that website. JETCO may use cookies to collect some server address, browser and OS information. However, customers may stop those cookies from doing so simply by changing the settings on customers’ browser. However, such a change may affect some of the displays on the Website or no displays at all.

   

    3.4 JETCO shall make a record of all visits to the Website. The record will only show the server address, browser and OS information and details of the visited pages. JETCO only collects aggregate information of the numbers and types of visitors by reference to their server address, browser and OS information. Such information will be used by JETCO for preparing general statistics on the frequency of using the Website. JETCO also has the right to disclose any or all of the person data if there is any illegal use of the Website.

 

 

4. Purposes of Keeping Personal

    4.1 The purposes for which the personal data of a customer may be used are as follows:

      1. Processing of your application or registration to access or use our services;
      2. The daily operation of the services;
      3. Marketing services and products to you by JETCO;
      4. Processing of any payment instructions in relation to supply of goods and services to the customers; and
      5. Analyzing, verifying, enforcing contractual rights, and/or checking of your payment status in relation to supply of goods and services to the customers.

 

    4.2 The purposes for which the personal data relating to employees may be used are as follows:

      1. processing employment applications;
      2. determining and reviewing salaries, bonuses and other benefits;
      3. consideration for promotion, training or transfer;
      4. providing employee references;
      5. monitoring compliance with internal rules of JETCO;
      6. any other purposes directly or indirectly relating to the compliance by JETCO or any of the employment or statutory obligations; and
      7. meeting the requirements to make disclosure under the requirements of any law binding on JETCO or under and for the purposes of any guidelines issued by regulatory or other authorities with which JETCO are expected to comply.

 

5. Disclosing Personal Data

Personal Data held by us will be kept confidential by us, but we may transfer or disclose Personal Data to the following parties within Hong Kong or outside Hong Kong, on a need-to-know basis for any of the Purposes:

      1. our agents or contractors (including their respective sub-contractors) under a duty of confidentiality to us who provide administrative, telecommunications, computer, anti-money laundering and counter terrorist financing intelligence, data processing or other services to us in connection with the operation of our business (such as professional advisors, debt collection agencies (when you owe us any money), courier or data entry companies);
      2. our subsidiaries and/or affiliates under a duty of confidentiality to us;
      3. any law enforcement agencies and/or regulatory bodies for compliance with applicable laws, rules, regulations, codes, and/or guidelines; and
      4. d. any persons or entity to whom we, our subsidiaries and/or our affiliates are under a binding obligation to satisfy a legally enforceable demand for disclosure under the requirements of any law, rule, regulation, code and/or guideline and/or order of any competent court of law, law enforcement agencies and/or regulatory bodies.

 

6. Security of Personal Data

JETCO will ensure an appropriate level of protection for personal data in order to prevent unauthorised or accidental access, processing, erasure or other use of that data, commensurate with the sensitivity of the data and the harm that would be caused by occurrence of any of the aforesaid events. It is the practice of JETCO to achieve appropriate levels of security protection by implementing appropriate physical, electronic and managerial measures to safeguard and secure customer personal data. It is also the practice of JETCO to use secured encryption systems appropriate for the collection of the personal data.

 

 

7. Accuracy of Personal Data

JETCO will ensure accuracy of all personal data using generally accepted practices and guidelines. Appropriate procedures are implemented to provide for all personal data to be regularly checked and updated to ensure that it is reasonably accurate having regard to the purposes for which that data is used. In some cases JETCO is required to see original documentation before the personal data may be used, such as with Personal Identifiers and/or proof of address.

 

 

8. Retention of Personal Data

Personal data will only be retained for as long as is necessary to fulfil the original or directly related purpose for which it was collected. After the termination of service, JETCO shall continue to hold data relating to the customer(s) for a period of 7 years or such other period as prescribed by applicable laws and regulations. If a data user engages a data processor (whether within or outside the home jurisdiction of the data subject) to process personal data on data user’s behalf, the data user must adopt contractual or other means to prevent any personal data transferred to the data processor from being kept longer than is necessary for processing of the data.

 

 

9. Access and Correction of Personal Data

Any customer has the right: - 

      1. To check whether JETCO holds data about him and of access to such data;
      2. To require JETCO to correct any data relating to him which is in accurate;
      3. To ascertain JETCO’s policies and practices in relation to data and to be informed of the kind of personnel data held by JETCO;

JETCO may charge a reasonable fee for the processing of any data access request.

 

 

10. Privacy related enquiries or requests

All enquiries and request regarding JETCO’s compliance with its obligations under the said applicable laws and regulations should be in writing to the following contact detail:

 

Telephone: 2862-9999

Address: 35/F., Sunlight Tower, 248 Queen's Road East, Wan Chai, Hong Kong.

Email: enquiry@jetco.com.hk

URL: www.jetco.com.hk

 

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APIX Personal Information Collection Statement

 

Effective Date: 1 January 2019

 

This APIX Personal Information Collection Statement (“PICS”) is made by Joint Electronic Teller Services Limited (hereinafter referred to as “JETCO”, “we”, “our” or “us”). We are the service provider of the API exchange platform known as “APIX” (“APIX”). This PICS is designed to help you understand what information we will gather from you and what we will do with such information in terms of your access of use of APIX and/or related services.

 

1. Definitions

For the purposes of this PICS, the term “Ordinance” means the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong Special Administrative Region), and the term “Personal Data” means any personal data held by us, including: (a) all information provided by you in any application or registration process to access or use APIX and related services; (b) all information provided by you to us in the ordinary course of business in relation to the provision of APIX and related services; and (c) all information collected by means of cookies on this website about your use of APIX and related services, to the extent that such transactional records are “personal data” within the meaning of the Ordinance.

 

2. Our Company Policy

We are committed to protecting the privacy, confidentiality and security of the Personal Data collected and held by us by complying with the requirements of the Ordinance with respect to the management of Personal Data. We are equally committed to ensuring that all our employees and agents, and third parties we disclose Personal Data to, uphold these obligations.

 

3. Collection of Personal Data

For the Purposes (defined below), we may, from time to time, collect from you and hold some or all Personal Data, such as, but not limited to, the following:

      1. Your first name.
      2. Your surname.  
      3. Your photographs.
      4. Your job title.
      5. Your contact details, including contact name, telephone number, email address.
      6. Your employer’s name.

 

In the event that you do not provide Personal Data to us, we may not be able to provide you with access or use of APIX or any of the related services.

 

4. Cookies

We use cookies on our websites to help us collect information about visitors’ interactions on APIX. Most web browsers are initially set up to accept cookies. You can choose to “not accept” cookies by changing the settings but if you do so you will find that you will not be able to access or use any of the features on APIX or other related services.

 

5.Purposes of Keeping Personal Data

Personal Data held by us may be used for the following purposes (“Purposes”):

      1. processing your application or registration to access or use APIX from time to time and managing your user account on APIX;
      2. conducting due diligence as required by law, rules, regulations, codes or guidelines or by providers of APIs on APIX;
      3. managing, operating and maintaining APIX, and related support facilities and systems;
      4. exercising our rights under any terms of use of APIX or terms of use of any of the development portal in APIX; 
      5. verifying any information and records provided by you;
      6. designing new or improving APIX and related services provided by us, our subsidiaries or our affiliates;
      7. compiling aggregate statistics on visitors’ interactions on APIX;
      8. communicating with you;
      9. investigating of any complaints and/or suspected suspicious transactions;
      10. preventing or detecting crime; and/or
      11. complying with the laws, rules, regulations, codes or guidelines.

 

We will not use any Personal Data for direct marketing purposes or provide Personal Data to third parties for use in direct marketing or for any other unrelated purposes without obtaining your prior consent, or without you providing us with an indication of no objection.

 

6. Disclosing Personal Data

Personal Data held by us will be kept confidential by us, but we may transfer or disclose Personal Data to the following parties within Hong Kong or outside Hong Kong, on a need-to-know basis for any of the Purposes:

      1. providers of APIs on APIX;
      2. our agents or contractors (including their respective sub-contractors) under a duty of confidentiality to us who provide administrative, telecommunications, computer, anti-money laundering and counter terrorist financing intelligence, data processing or other services to us in connection with the operation of our business (such as professional advisors, debt collection agencies (when you owe us any money), courier or data entry companies);
      3. our subsidiaries and/or affiliates under a duty of confidentiality to us;
      4. any law enforcement agencies and/or regulatory bodies for compliance with applicable laws, rules, regulations, codes, and/or guidelines; and
      5. any persons or entity to whom we, our subsidiaries and/or our affiliates are under a binding obligation to satisfy a legally enforceable demand for disclosure under the requirements of any law, rule, regulation, code and/or guideline and/or order of any competent court of law, law enforcement agencies and/or regulatory bodies.  

 

7. Security of Personal Data

We treat security of Personal Data seriously and have implemented appropriate controls to safeguard Personal Data against unauthorised, accidental, or malicious access, processing, deletion or loss. However, JETCO has no control over the acts of any person, and accordingly, assume no responsibility to anyone for any unauthorised, accidental, or malicious access, processing, deletion or loss of Personal Data.

 

8. Access and Correction of Personal Data

You have the right to ask us if we hold any Personal Data about you and if so, to request a copy of the same. If you would like to make such a request, please submit your request by email or by post to our Data Protection Officer at the addresses shown below.  We may charge you a fee at a level permitted by the Ordinance for this service.

 

You may also have the right to ask us to correct your Personal Data which you consider as inaccurate by emailing or posting your correction request to our Data Protection Officer at the addresses shown below.

 

The address of our Data Protection Officer is:

Email: support@jetco.com.hk

Address: Data Protection Officer, JETCO, 35/F, Sunlight Tower, 248 Queen’s Road East, Wan Chai, Hong Kong

 

9. Retention of Personal Data

We will not keep Personal Data for longer than is necessary for the fulfillment of the Purposes, subject to legal, statutory and regulatory requirements mandating the retention of data. Unnecessary Personal Data will be deleted from our system in accordance with our internal procedures, except we will retain copies of the Personal Data for archiving/backup purposes.

 

10. Links to Other Websites

Our website may, from time to time, contain link to other websites. This PICS only applies to this website so when you link to other websites, you should read the privacy policies posted on those websites.

 

11. Changes of the PICS

JETCO reserves the exclusive right to change and amend this PICS. Unless otherwise required by law, we will notify you before we make any changes to this PICS. Once any updated PICS is in effect, you will be bound by them if you continue to use APIX or other related services.

 

12. Language

In the event of any inconsistency between the English and Chinese versions of this PICS, the English version shall prevail.

 

13. Enquiries about Privacy Policy and Practices

You may contact our Data Protection Officer if you have any enquiries regarding this PICS and our practices regarding Personal Data:

 

The address of our Data Protection Officer is:

Email: support@jetco.com.hk

Address: Data Protection Officer, JETCO, 35/F, Sunlight Tower, 248 Queen’s Road East, Wan Chai, Hong Kong

 

 

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Version 1.03.2019