Privacy Policy
China Telecom (Asia Pacific) Pte. Ltd.
Privacy Policy Statement (“Statement”)
Our website located at https://www.chinatelecomasiapacific.com (“Website”) is owned and operated by China Telecom (Asia Pacific) Pte. Ltd. (referred to as “CTAP”, “we”, “our” or “us”). This Statement explains our policies and practices with respect to the collection, use and/or disclosure of your Personal Data (defined below) in operating the Website.
“Affiliates” means an entity which is related to CTAP (i) either by reason of CTAP directly or indirectly Controlling the entity; (ii) by reason of the entity directly or indirectly Controlling CTAP; or (iii) by reason of both CTAP and the entity being, directly or indirectly, Controlled by or under the common Control of a third party. “Control” means the ownership of more than fifty per cent of the voting stock of such entity or the possession of the power, directly or indirectly, to direct or cause the direction of the management and policies of such entity.
1. Information collection
“Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
(a) Personal Data you give us: We may collect certain Personal Data about you (such as your name, company, phone number, photographs, video images, residential address and personal e-mail address) when you use this Website or our services, attend our functions, or otherwise in your interaction and communications with us.
(b) Personal Data we collect about you:
1. With regard to each of your visits to this Website, we may automatically collect the following information:
- Technical information, including the Internet protocol (“IP”) address (a unique identifier for your computer or other access device used to connect your computer to the Internet), your browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- Information about your visit, including the full Uniform Resource Location (“URL”) clickstream to, through and from this Website (including data and time); products and services you viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page.
2. We collect information and maintain a database about Singapore and overseas companies. In the process, we also collect Personal Data about individual contact persons of the companies or their employees.
- Together the Personal Data you give us as described above in paragraph 1(a) and any Personal Data we collect about you as described above in paragraph 1(b), are hereinafter referred to as “Personal Information”.
- You can choose not to give or make your Personal Information available to us. However, if you do not provide your Personal Information, or allow us to collect it, we may be unable to provide you with certain information or services (such as our newsletters) or you may be unable to access certain parts of this Website.
- We only retain your Personal Information for so long as it is necessary for the purposes set out in Paragraphs 2 and 3 below.
2. Use of Personal Information
The purposes for which your Personal Information may be used by us in and outside Singapore include:
- Our operations, e.g., incorporation into our database, analysis, research, troubleshooting, testing, auditing, statistical and survey purposes;
- Distribution of CTAP publications and research materials relating to our services and products (and those of our business partners who operate in the telecommunications sector);
- Improving this Website to ensure that content is presented in the most effective manner for you and for your computer, and to keep this Website safe and secure;
- Complying with laws in or outside Singapore including complying with any guidelines, directives or orders given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self- regulatory or industry bodies in or outside Singapore;
- Legal proceedings, including collecting overdue amounts; and
- Direct marketing purposes as set out below.
3. Use of Personal Information for Direct Marketing
We also intend to use your Personal Information to conduct direct marketing activities and provide you with marketing materials relating to our or our Affiliates’ telecommunications products and services via (i) email and/or direct mail, and (ii) if so consented by you, via telephone, fax and SMS/MMS to your telephone number(s). We will not use or provide your Personal Information to any third party for direct marketing purposes without your written consent.
4. Transfer of Your Personal Information
(a) We will keep your Personal Information we hold confidential. In this regard, we will not disclose your Personal Information to third parties (whether within or outside Singapore) without first obtaining your consent permitting us to do so unless an exception under the Singapore Personal Data Protection Act 2012 (“PDPA”) or law applies.
(b) We may disclose your Personal Information to the following parties for the abovementioned purposes set out in Paragraphs 2 and 3 above:
• Our Affiliates’ offices in Australia, Belarus, Brazil, Cambodia, Canada, Czech Republic, Denmark, Egypt, France, Germany, Hong Kong SAR of China, Hungary, India, Indonesia, Italy, Japan, Kazakhstan, Kenya, Luxembourg, Macau SAR of China, Malaysia, Mauritius, Myanmar, Netherlands, Pakistan, Russia, Serbia, Singapore, South Africa, South Korea, Spain, Sri Lanka, Sweden, Switzerland, Thailand, the European Union the People’s Republic of China, the United States of America, Turkey, United Arab Emirates and Vietnam, which include, but are not limited to, China Telecommunications Corporation, China Telecom Corporation Limited, China Telecom (Europe) Limited, China Telecom (Americas) Corporation, China Telecom Global Limited, and China Telecom (Africa and Middle East) Limited; and
• Persons to whom we are required to make disclosure under applicable laws in or outside Singapore; and
• Our third party service providers, including third party service providers which process Personal Data on our behalf, support our business operations and/or provide services to you on our behalf.
(c) We will hold your data on our servers in Hong Kong. However, we may transfer it to our overseas offices elsewhere in the world or to any of the parties listed in Paragraph 4(b) above, who may be located outside of Singapore. Where such a transfer is performed, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the PDPA. This may include us entering into an appropriate contract or in the case of intra-corporate transfers, binding corporate rules, with the foreign recipient organisation dealing with the Personal Data transfer or permitting the Personal Data transfer without such a contract if the PDPA or law permits us to do so.
5. Cookies
(a) Your visit to this Website may be recorded for analysis on the number of visitors to the Website and general usage patterns. Some of this information will be gathered through the use of “cookies”. Cookies are small bits of information that are automatically stored on a person’s web browser in their computer that can be retrieved by this Website. Cookies can make a website more useful by storing information about your preferences on particular sites, enabling website owners to provide more useful features for their users.
(b) The information collected by “cookies” is anonymous aggregated research data, and contain no name or address information or any information that will enable anyone to contact you via telephone, e-mail or any other means.
(c) Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or inform you when they are set. Cookies are necessary for some features of the Website to work, e.g., to maintain continuity during a session. If they are not accepted, those features may not work properly.
(d) We use an email delivery company to send emails that you have agreed to receive. Pixels tags and cookies are used in those emails and at our Website to help us measure the effectiveness of our advertising and how visitors use our web site.
6. Security
We implement reasonable computer, physical and procedural safeguards to protect the security and confidentiality of the Personal Information we collect. Personal Information stored electronically is password-protected and we use encryption technology on our Website. Our computer systems are placed in restricted areas. We only permit authorized employees and agents to access Personal Information.
7. Links to Third Party Websites
Hyperlinks to other websites are provided for your convenience. This Statement does not apply to other websites that are not controlled by us. Please refer to the privacy policies of such other websites.
8. Changes to this Statement
We may update this Statement from time to time. When we do, the changes will be posted on https://www.chinatelecomasiapacific.com. Your continued use of our Website and services shall constitute your acknowledgement and acceptance of the updated Statement. You should frequently check the aforementioned website to be apprised of any updates or changes to this Statement.
9. Language
If this Statement is available in any other language, the English version of the Statement shall prevail in the event of any conflict between the versions.
10. Your Consent and Rights
(a) You have the right to:
• Check whether we hold Personal Information about you and to access such data;
• Require us to correct inaccurate Personal Information relating to you; and
• Know about our policies and practices relating to Personal Data protection and the kind of Personal Information that we collect, use and/or disclose.
(b) By using or visiting our Website or any of our products and services and/or providing your Personal Information to us, you consent to our collection, use and/or disclosure of your Personal Information for the specified purposes as outlined in this Statement. If you:
• Do not consent to the collection, use and/or disclosure of your Personal Information for the specified purposes as outlined in this Statement;
• Do not consent to the collection, use and disclosure of your Personal Information for direct marketing purposes as set out in Paragraph 3 above; and/or
• Would like to request access to or correction of your Personal Information, to withdraw your consent for the collection, use and/or disclosure of your Personal Information or send any questions or complaints regarding how we are handling your Personal Information in our possession or under our control, please contact:
Zhang Yi Fei, Data Privacy Officer
China Telecom (Asia Pacific) Pte. Ltd.
One Marina Boulevard #19-01 Singapore 018989
Tel: +65 6339 0080
E-mail: zhangyf@chinatelecomglobal.com
We may charge a reasonable fee for processing a data access request.
GDPR Privacy Policy Statement (“Statement”)
Where your personal data is covered by the General Data Protection Regulation (GDPR), please refer to the following GDPR Privacy Policy Statement on the data processing activities of China Telecom (Asia Pacific) Pte. Ltd. being the controller of this website or the relevant China Telecom group company responsible for processing your data (the relevant China Telecom group company can be found here) (“China Telecom“, “our“, ” we” or ” us“) with respect to individually identifiable information about users of our products and services (the relevant China Telecom’s products and services can be found here) (“Products and Services“).
This Statement also applies to the www.chinatelecomasiapacific.com/website (the ” Website“) and governs data collection, processing and usage. By using the Website, you consent to China Telecom data practices described in this statement. If you do not agree to any part of this Statement of Privacy, then you should stop accessing the Website.
Definitions
- “Customer” means a prospective, current or former customer of China Telecom. The term shall also include any individual agent, employee, representative, customer or client of China Telecom where China Telecom has obtained his or her Personal Data from such Customer as part of its business relationship with the Customer.
- “Data Subject” means an identified or identifiable natural living person about whom Personal Data is being processed.
- “Employee” means an employee (whether temporary, permanent, part-time or contract) of China Telecom. An employee may be a resident of a country within the European Economic area.
- “Europe” or “European” refers to a country in the European Economic Area.
- “Personal Data” means the any personal data as defined and covered by the General Data Protection Regulation (EU 2016/679).
- “Sensitive Data” means any sensitive data relating to you, including data concerning race, ethnic origin, politics, religion, trade union membership, genetics, biometrics (where used for ID purposes), health, sex life or sexual orientation.
- “Third Party” means any individual or entity that is neither China Telecom nor a China Telecom employee, agent, contractor or representative.
Collection of your Personal Data
Any and all personal information that we may collect will be collected, used and held in accordance with the provisions of General Data Protection Regulation (EU 2016/679) (“GDPR” or “Act”) and your rights and our obligations under that Act. China Telecom may collect and process Personal Data, such as your e-mail address, name, home or work address or telephone number. If you purchase China Telecom Products and Services, we may collect and store billing and credit card information. China Telecom may also collect anonymous demographic information which is not unique to you, such as your postal code, age, gender, preferences, interests and favourites.
Information about your computer hardware and software also may be automatically collected by the Website. This information can include your IP address, browser type, domain names, access times and referring website addresses. This information is used by China Telecom for the operation of the service, to maintain quality of the service and to provide general statistics regarding use of the Website.
Please keep in mind that if you directly disclose Personal Data or Sensitive Data through the Website’s public message boards, this information may be collected and used by others.
China Telecom encourages you to review the privacy statements of websites you choose to link to from the Website, so that you can understand how those websites collect, use and share your information. China Telecom is not responsible for the privacy statements or other content on websites outside of the China Telecom family of websites.
Use of your Personal Data
China Telecom collects and uses your Personal Data to operate the Website and deliver the services. China Telecom will send one welcome email following registration to all registered users. We will also periodically send service updates to registered users.
China Telecom may also use your Personal Data to inform you of other Products and Services available from China Telecom and its affiliates, where you have consented to be contacted for such purposes. China Telecom may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered, although you do not have to respond to such surveys.
We may also use your personal information to:
(a) Provide and personalise our services, for example to understand how you use our network, so that we may develop more interesting and relevant services as well as personalising the products we offer you.
(b) Deal with your enquiries and requests.
(c) Comply with legal obligations to which we are subject and cooperate with regulators and law enforcement bodies.
(d) Prevent and detect fraud or recover debts.
(e) Contact you with marketing and offers relating to products and services offered by us and/or other members of the China Telecom group (unless you have opted out of marketing, or we are otherwise prevented by law from doing so).
(f) Personalise the marketing messages we send you to make them more relevant and interesting.
(g) Protect our network and manage use of the network.
(h) Carry out research and statistical analysis including to monitor how customers use our network, products and services.
We must have a legal basis to process your personal information. In most cases the legal basis will be one of the following:
(a) To fulfil our contractual obligations to you, for example to provide our Products and Services, to ensure that invoices are paid correctly, and to ensure you are able to access our services when required. Failure to provide this information may prevent or delay the fulfilment of these contractual obligations.
(b) To comply with our legal obligations and enable our affiliates to comply with their legal obligations (which may apply under the laws of other countries around the world), for example, obligations relating to financial reporting and court orders.
(c) To meet our legitimate interests, for example to understand how you use our services, to enable us to recover debt, and to enable us to derive knowledge from that to enable us to develop new services. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. For more information about the balancing test that we carry out to process your information to meet our legitimate interests, please contact us.
We may obtain your consent to collect and use certain types of personal information when we are required to do so by law. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us.
Storage of Personal Data
We will keep your personal information for a reasonable period of time that enables us to:
- Provide the services
- Maintain business records for reporting, analysis and/or audit purposes
- Comply with record retention requirements under the law
- Defend or bring any existing or potential legal claims
- Deal with any complaints regarding the services.
We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
As part of the services offered to you through the Website, the information you provide to us may be transferred to and stored in countries outside of the European Economic Area (EEA). It may also be processed by Employees operating outside the EEA who work for us or one of our suppliers. By way of example, a transfer of your information may happen if any of our servers are located in a country outside of the EEA or one of our service providers is located in a country outside of the EEA.
If we transfer or store your information outside the EEA in this way, we will take all steps reasonably necessary to ensure that your privacy rights continue to be protected and treated securely as outlined in this Statement. If you use our service while you are outside the EEA, your information may be transferred outside the EEA in order to provide you with these services. By submitting your Personal Data, you agree to this transfer, storing or processing by us.
By way of entering into appropriate data transfer agreements based on Standard Contractual Clauses approved by the European Commission or other adequate means, we have established that all recipients located outside the EEA will provide an adequate level of data protection for your Personal Data and that appropriate technical and organizational security measures are in place to protect your Personal Data against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. Any onward transfer is subject to appropriate onward transfer requirements as required by applicable law.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
China Telecom keeps track of the websites and pages our customers visit within the Website, in order to determine what website services are the most popular. This data is used to deliver customised content and advertising within the Website to customers whose behaviour indicates that they are interested in a particular subject area.
China Telecom will disclose or share your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:
(a) Comply with any legal requirements or comply with legal process served on the Website;
(b) Protect and defend the rights or property of China Telecom; and,
(c) Act under exigent circumstances to protect the personal safety of users of the Website, or the general public.
China Telecom may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
Disclosures/Onward Transfers of Personal Data
We may share your personal information with third parties under the following circumstances:
- Service providers and business partners. We may share your personal information with our service providers and business partners that perform marketing services and other business operations for us. For example, we may partner with other companies to provide network services, store data, help optimize our services and analyse information.
- China Telecom group companies. China Telecom works closely with other businesses and companies that fall under the China Telecom Group. We may share your personal information with other China Telecom companies for administrative and internal reporting purposes. A list of companies within the China Telecom Group can be found here
- Any law enforcement agency, court, regulator, government authority or other Third Party. We may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any Third Party.
- Asset purchasers. We may share your personal information with any Third Party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this privacy notice.
Because we operate as part of a global business, the recipients referred to above may be located outside the jurisdiction in which you are located (or in which we provide the services). See the section on “Storage of Personal Data” above for more information.
Sensitive Data
China Telecom will not process Sensitive Data about you unless you voluntarily supply us with such data. If you supply us with any special category data, we will process such data in accordance with the law and only for the specific purpose for which you have supplied it (for example, if you tell us that you have a disability which means we need to make adjustments to the way in which we communicate with you).
Use of Cookies
The Website uses “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you
One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the server that you have returned to a specific page. For example, if you personalise the Website pages, or register with the Website site or services, a cookie helps the Website to recall your specific information on subsequent visits.
This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same the Website, the information you previously provided can be retrieved, so you can easily use the Website features that you customised.
We may use any of the following cookies:
Strictly necessary cookies. These are cookies that are required for the operation of the Website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of our site or to fully experience the interactive features of the China Telecom services or websites you visit.
Data Security & Integrity
The Website secures your Personal Data from unauthorised access, use or disclosure. The Website secures the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use or disclosure. When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
We implement technical and organisational measures to ensure a level of security appropriate to the risk to the personal information we process. These measures are aimed at ensuring the on-going integrity and confidentiality of personal information. We evaluate these measures on a regular basis to ensure the security of the processing.
Your Rights
You have certain rights regarding your personal information, subject to local law. These include the following rights to:
- Access your personal information
- Rectify the information we hold about you
- Erase your personal information
- Restrict our use of your personal information
- Object to our use of your personal information
- Receive your personal information in a usable electronic format and transmit it to a Third Party (right to data portability)
- Lodge a complaint with your local data protection authority.
You have the right to ask us not to process your Personal Data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any Third Party for such purposes.
You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us.
Right to access: the Act gives Data Subjects the right to access information held about them, to ensure that such Personal Data is accurate and relevant for the purposes for which the Website collected the data. You may review your Personal Data stored in the Website databases and correct, erase or block any data that is incorrect, as permitted by applicable law. Your right of access can be exercised in accordance with the Act.
You may edit your Personal Data by logging into your account or by contacting us by phone or email. In making modifications to your Personal Data, you must provide only truthful, complete and accurate information.
Satisfying Requests for Access, Modifications, and Corrections: we will endeavor to respond in a timely manner to all reasonable written requests to view, modify, or inactivate Personal Data.
Employees: China Telecom Employees may access and use Personal Data only if they are authorised to do so and only for the purpose for which they are authorised.
If you would like to discuss or exercise such rights, please contact us. We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to the data protection authority of the country in which you are a resident using their website.
Changes to this Statement
China Telecom will occasionally update this Statement of Privacy to reflect company and customer feedback. China Telecom encourages you to periodically review this Statement to be informed of how China Telecom is protecting your Personal Data.
Contact Information
China Telecom welcomes your comments regarding this Statement of Privacy. If you believe that the Website has not adhered to this Statement of Privacy, please contact us at Tel: +65 6339 0080 E-mail: sales_sg@chinatelecomglobal.com. For any other questions regarding your rights over your Personal Data, please feel free to contact our Data Protection Officer at dataprotection@chinatelecomglobal.com.
