GENERA

  1. 1. This Statement is made by China Mobile Hong Kong Company Limited (collectively “CMHK”, “we” or “us”) in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong Special Administrative Region (the “PDPO”).
  2. 2. This Statement explains what personal data we collect, how it will be used, and to whom the personal data will be transferred and to whom data access requests are to be addressed. For the purpose of this Statement, personal data shall carry the meaning as defined in PDPO.

WHAT PERSONAL INFORMATION DO WE COLLECT AND WHY WE COLLECT IT?

  1. 3. From time to time, it is necessary for us to collect your personal data in order for us to provide you with the goods or services required, which may include:
  2. 4. In order to enhance your customer experience, further personal data may also be collected on a voluntary basis such as your age, date of birth, gender, education, profession, salary range, hobbies, interests and leisure activities, other related products and services subscribed, family and household demographics, and etc. We will indicate in the relevant forms or application whether the provision of the required personal data is on a voluntary basis.
  3. 5. In addition, your online session data may also be collected indirectly on an aggregated and anonymous basis.
  4. 6. If you are under the age of 13, you are required to ask your parent or guardian before providing any personal data to us.

HOW DO WE USE YOUR PERSONAL DATA?

  1. 7. Your personal data may be used for one or more of the following purposes depending on the context:

DISCLOSURE & TRANSFER OF PERSONAL DATA

  1. 8. To facilitate the purposes set out in paragraph 7 above, we may transfer, disclose, grant access to or share your personal data with the following parties (whether within or outside Hong Kong), and your personal data may be transferred within or outside Hong Kong:

SECURITY & RETENTION OF PERSONAL DATA

  1. 9. We strived at all times to ensure that your personal data will be protected against unauthorized or accidental access, processing, erasure or other use. We maintain this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure your personal data. Personal 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 personal data is also retained to satisfy any applicable statutory or contractual obligations.
  2. 10. Your personal data saved at MyLink system or related system will only be stored on servers in Hong Kong. The data retention period for your personal data is 3 years, which is calculated on a yearly basis. If your personal data has been collected through MyLink’s single event or special events, (such as lucky draw registration, gift redemption, event participation, online shopping, handset order, etc.), the data will only be stored till the end of the event or its data retention period subjected to the related events’ terms & conditions.
  3. 11. We also take the following actions to ensure your personal data safety, such as using HTTPS ("HyperText Transfer Protocol Secure") for conducting data transfer through MyLink App, using CAPTCHAs ("Completely Automated Public Turing test to tell Computers and Humans Apart") on MyLink App, conducting regular penetration tests, and using encryption algorithms to ensure sensitive data well protected.

USE OF PERSONAL DATA IN DIRECT MARKETING

  1. 12. Subject to your consent and in strict accordance with the provisions of PDPO, we intend to use your personal data including but not limited to the personal data set forth in Paragraphs 3 to 5 hereof to deliver to you information about any goods and services, loyalty programs, activities (including joint collaboration with third parties), newsletters, contests, lucky draws and etc of us and our business partners. The said information may include various classes of marketing subjects including but not limited to mobile devices and accessories, network services such as TV, mobile voice, SMS and data communications, IDD/roaming, Internet connectivity, mobile applications, entertainment and data communications on Internet, other value-added services, as well as computer peripheral, accessories and software (including notebooks, handsets, keyboards, security installations and mobile applications), secretarial services, personal assistance services and information services, gaming, sports, music, beauty products, electronics, technology, ecommerce, mobile payment, travelling, banking, investment, entertainment, transportation, household, fashion, food and beverages, alcohol and tobacco, insurance, education, health and wellness, social networking, charity activities, media and high-end consumer products and services. The said information may be delivered to you by mail, phone, email, fax or other means.
  2. 13. We may not use your personal data for direct marketing unless we received your consent or indication of no objection. If you wish to stop receiving direct marketing materials from us, you may write to us in the manner set forth in Paragraph 14 hereof at any time. In any such request, please state clearly your personal information and contact details for identification purposes.

USE OF COOKIES & LOCATION DATA

  1. 14. If you visit any of our websites, we may use cookie files to store and track information about you and your preferences. A cookie is a small text file that our website transfers to your device. The use of cookies means we can better serve you and/or maintain your information across multiple pages within or across one or more sessions. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future. Cookies contain information about you and your preferences. For example, if you inquire about rates and availability, the site might create a cookie that contains the details you entered. Or it might only contain a record of which pages within the site you visited to help the site customize the view for you the next time you visit. Only the information that you provide or the choices you make while visiting a website can be stored in a cookie. For example, the site cannot determine your email address unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your device, and only the site that created the cookie can read it.
  2. 15. We may use your location data to keep track of your activity patterns and preferences in order to improve the level of service you receive. Your location data may be combined with other information we receive from third parties to provide you with better service and, where you have consented to receive direct marketing, we may provide you with targeted advertisements, content, features, deals and offers in the manner set forth in Paragraph 10 hereof.

PERMISSIONS AND FUNCTIONS

16. In order to ensure the stable operation of the service or realize the functions, MyLink would ask the user for authorization before the user log in for the first time or the user uses the following functions. If the user needs to cancel the following authorization, you can go to "Settings" → "System Authority Management" to operate and manage , or to withdraw the consent granted reference to Paragraph 20 hereof.

iOS system

Permission Access Permission Function Description
Camera
User Avatar
QR Code Scanner
Video Customer Service
  • Taking Photos
  • Scan QR code
  • Video Call Functions
Contacts
Invite Friends
My Friends
  • Invitation to participate in activities/ share
  • Match qualified friends’ phone numbers
Microphone
Video customer service
AI Assistant
  • Video Call Functions
  • Speech recognition
Face ID Biometric Authentication
  • Login
Health WeWalk
  • Obtain user steps
Location Location
  • Weather information
  • WeWalk function to draw map tracks
Album
Read Photos
  • Update users’avatar
  • Update users’avatar

Android system

Permission Access Permission Function Description
Camera
User Avatar
QR Code Scanner
Video Customer Service
  • Taking Photos
  • Scan QR code
  • Video Call Functions
Contacts
Invite Friends
My Friends
  • Invitation to participate in activities/ share
  • Match qualified friends’ phone numbers
Microphone
Video customer service
AI Assistant
  • Video Call Functions
  • Speech recognition
Biometric Authentication Biometric Authentication
  • Login
Physical Activity WeWalk
  • Obtain user steps
Location
Coarse Location
Precise Location
  • Weather information
  • WeWalk function to draw map tracks
Phone Network
Network Quality Analysis
  • Enhance Network
Access and change files on internal storage
Read SD card
Write in SD card
  • Update users’avatar
  • Save the opening page picture

DATA SHARING AND DISCLOSURE

  1. 17. To ensure the operational stability of our services or implement related functions, we may insert third-party Software Development Kits (SDKs) to achieve the aforementioned purpose. You can visit the third-party Software Development Kits (SDKs) privacy policy website, which is disclosed by our company, for more details about the specific situation of collecting your personal data. If the third party does not provide specific privacy policy related to its SDKs, we may provide its related official website link for helping you to understand its specific information. Currently, the details of inserting third-party SDKs are as follows:

iOS system

SDK Name
Purpose
Personal Information Collected
Official Websites
AsiaPay
UnionPay, Credit Card Payment Services
AsiaPay is the sole owner of the information voluntarily given to us by the users of this site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. AsiaPay collects information from our users at several different points on our website. The data we collect from cookies and other places is used in the aggregate to give us demographic information about the entire AsiaPay audience in order to improve the AsiaPay service. The personal information you provide - name, email address, etc. -- allows us to inform you about updates to the service and to notify you of products and services of AsiaPay, its affiliates and third parties that we believe may be of interest to you. We also share aggregate information -- not individual data -- with our advertisers to help them better understand our services and to monitor the reach of their advertising on the service.
https://www.asiapay.com/privacy.html
SDK Provider: AsiaPay Limited
Google Firebase
Crashlytics, Performance, Cloud messaging
The default import settings for Google Analytics for Firebase collect several types of data:
- Number of users and session
- Session duration
- Operating system
- The device model
- geographic area
- The number of initial boots
- The number of times the application was opened
- The number of application updates
- In-app purchase
- Android id
- Access Clipboard permission
https://firebase.google.com/
SDK Provider: Google LLC
Google Map
Using maps service
The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.
https://policies.google.com/privacy
SDK Provider: Google LLC
TGS
Hiking Pedometers
Collect steps and positioning
Apple HealthKit
Before using WeWalk function, users need to access the Apple HealthKit authorization. Utilized to count users' daily steps through the WeWalk module. This authorization can be later revoked by users at any time via the path: MyLink -> Settings -> System Access Management -> Health.
SDK Provider: Apple Inc.
Umeng SDK
Data Analysis, Closed-loop management for business growth, Integrated Sharing Services
Types of personal information collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI/geographic location, etc.)
https://www.umeng.com/page/policy
SDK Provider: 友盟同欣(北京)科技有限公司、北京銳訊靈通科技有限公司
UTV
Live Streaming Service
Provided by CMHK Internally
WeChat
WeChat Payment Service
The Weixin Pay service is provided by Tenpay. When you enable the Weixin Pay feature, Tenpay will collect your name, ID number or the numbers of other legal ID documents, the type, number and validity period of your bank card, and the mobile number you registered with your bank. When you use Weixin Pay, Tenpay will also collect your transaction orders and payment records to allow you to search for and review the payments you have made. Such information is sensitive information. Refusing to provide such information will only result in your inability to use the Weixin Pay service, and will not affect your use of other features of Weixin. Please refer to the Tenpay Privacy Policy for more information on the Weixin Pay privacy policy.
https://www.tenpay.com/v3/helpcenter/low/privacy.shtml
SDK Provider: 財付通支付科技有限公司
xCurrency
Providing Foreign Exchange Services
https://www.xe.com/zh-HK/xecurrencydata/
SDK Provider: XE.com Inc.
Alipay
Alipay Payment Services
Information obtained by us or provided by you during your use of the AlipayHK Wallet, including your name, date of birth, address, bank account numbers, billing and delivery information, transaction data, credit/debit card numbers (including safety codes) and card holder names, expiration dates and bank statements (“Account Information”).
https://opendocs.alipay.com/open/54
SDK Provider: 支付寶(中國)網絡技術有限公司
Amap
Providing maps service
Personal information: location information, device information (including IDFV, OAID, IMEI, MEID, IMSI and other terminal device unique identifiers, mac address, operating system version, device make and model, device configuration, carrier type, application information)
https://lbs.amap.com/pages/privacy/
Tencent Cloud User Generated Short Video (UGSV)
Playing User Generated Short Videos
Device manufacturer, device model, system version, network type, screen resolution, CPU information, IP address
https://cloud.tencent.com/document/product/584/38857
SDK Provider: 深圳市騰訊電腦系統有限公司
Openinstall
App uploading and installing, H5 channel statistics, application statistics, key pull-up, advertising platform monitoring
Device information: device brand, device model, operating system version; device identifier: Android ID, SerialNumber; network information: IP address; device identifier: IMEI, IDFA, OAID, Mac address
Access Clipboard permission
https://www.openinstall.io/doc/rules.html
SDK Provider: 深圳市分秒網路科技有限公司
Video customer service
Provide home broadband video troubleshooting consulting service
Access microphone permissions
Access camera permissions
Provided by CMHK Internally
XiaoIce
Provide a 3D virtual model that can talk, touch and interact
Speech Recognition
Access microphone permissions
SDK Provider: 北京紅棉小冰科技有限公司
NetEase
Provide a 3D virtual model that can talk, touch and interact
Speech Recognition
Access microphone permissions
SDK Provider: 杭州網易智企科技有限公司
Getui SDK
Provide app push service, will collect personal information include: mac, brand model, system version, wifi, ip, device token, allowNotification.https://docs.getui.com/privacy
SDK Provider: 每日互動股份有限公司
ZXID
will collect personal information include:Weak characteristics of devices (features that do not possess uniqueness and stability): device backup information (device manufacturer, device model, device system information), device network Information (device networking channels and status information), device environment information (screen brightness, battery status and country, device application information (versions of common device applications). Purpose of use: To provide equipment identification and safety risk control services. Partner entity: China Institute of Information and Communication Technology, collection pipeline: SDK collection.Partner's official website link: https://zxid.caict.ac.cn Partner Privacy Policy Link: https://zxid.caict.ac.cn/privacy
SDK Provider: 中國資訊通信研究院
AsiainfoPaySDK.xcframework SDK for MyLink App payment

Android system

SDK Name
Purpose
Personal Information Collected
Official Websites
AsiaPay
UnionPay, Credit Card Payment Services
AsiaPay is the sole owner of the information voluntarily given to us by the users of this site. We will not sell, share, or rent this information to others in ways different from what is disclosed in this statement. AsiaPay collects information from our users at several different points on our website. The data we collect from cookies and other places is used in the aggregate to give us demographic information about the entire AsiaPay audience in order to improve the AsiaPay service. The personal information you provide - name, email address, etc. -- allows us to inform you about updates to the service and to notify you of products and services of AsiaPay, its affiliates and third parties that we believe may be of interest to you. We also share aggregate information -- not individual data -- with our advertisers to help them better understand our services and to monitor the reach of their advertising on the service.
https://www.asiapay.com/privacy.html
SDK Provider: AsiaPay Limited
Google Firebase
Crashlytics, Performance, Cloud messaging
The default import settings for Google Analytics for Firebase collect several types of data:
- Number of users and session
- Session duration
- Operating system
- The device model
- geographic area
- The number of initial boots
- The number of times the application was opened
- The number of application updates
- In-app purchase
- Android id
- Access Clipboard permission
https://firebase.google.com/
SDK Provider: Google LLC
Google Map
Using maps service
The information we collect includes unique identifiers, browser type and settings, device type and settings, operating system, mobile network information including carrier name and phone number, and application version number. We also collect information about the interaction of your apps, browsers, and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.
https://policies.google.com/privacy
SDK Provider: Google LLC
TGS
Hiking Pedometers
Collect steps and positioning
SDK Provider: 深圳微品致遠信息科技有限公司
Umeng SDK
Data Analysis, Closed-loop management for business growth, Integrated Sharing Services
Types of personal information collected: device information (IMEI/MAC/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI/geographic location, etc.)
https://www.umeng.com/page/policy
SDK Provider: 友盟同欣(北京)科技有限公司、北京銳訊靈通科技有限公司
UTV
Live Streaming Service
Provided by CMHK Internally
WeChat
WeChat Payment Service
The Weixin Pay service is provided by Tenpay. When you enable the Weixin Pay feature, Tenpay will collect your name, ID number or the numbers of other legal ID documents, the type, number and validity period of your bank card, and the mobile number you registered with your bank. When you use Weixin Pay, Tenpay will also collect your transaction orders and payment records to allow you to search for and review the payments you have made. Such information is sensitive information. Refusing to provide such information will only result in your inability to use the Weixin Pay service, and will not affect your use of other features of Weixin. Please refer to the Tenpay Privacy Policy for more information on the Weixin Pay privacy policy.
https://www.tenpay.com/v3/helpcenter/low/privacy.shtml
SDK Provider: 財付通支付科技有限公司
xCurrency
Providing Foreign Exchange Services
https://www.xe.com/zh-HK/xecurrencydata/
SDK Provider: XE.com Inc.
Alipay
Alipay Payment Services
Information obtained by us or provided by you during your use of the AlipayHK Wallet, including your name, date of birth, address, bank account numbers, billing and delivery information, transaction data, credit/debit card numbers (including safety codes) and card holder names, expiration dates and bank statements (“Account Information”).
https://opendocs.alipay.com/open/54
SDK Provider: 支付寶(中國)網絡技術有限公司
Tencent Cloud User Generated Short Video (UGSV)
Playing User Generated Short Videos
Device manufacturer, device model, system version, network type, screen resolution, CPU information, IP address
https://cloud.tencent.com/document/product/584/38857
SDK Provider: 深圳市騰訊電腦系統有限公司
Amap
Providing maps service
Personal information: location information, device information (including IDFV, OAID, IMEI, MEID, IMSI and other terminal device unique identifiers, mac address, operating system version, device make and model, device configuration, carrier type, application information)
https://lbs.amap.com/pages/privacy/
Openinstall
App uploading and installing, H5 channel statistics, application statistics, key pull-up, advertising platform monitoring
Device information: device brand, device model, operating system version; device identifier: Android ID, SerialNumber; network information: IP address; device identifier: IMEI, IDFA, OAID, Mac address
Access Clipboard permission
https://www.openinstall.io/doc/rules.html
SDK Provider: 深圳市分秒網路科技有限公司
Video customer service
Provide home broadband video troubleshooting consulting service
Access microphone permissions
Access camera permissions
Provided by CMHK Internally
XiaoIce
Provide a 3D virtual model that can talk, touch and interact
Speech Recognition
Access microphone permissions
SDK Provider: 北京紅棉小冰科技有限公司
NetEase
Provide a 3D virtual model that can talk, touch and interact
Speech Recognition
Access microphone permissions
SDK Provider: 杭州網易智企科技有限公司
Getui SDK
Provide app push service, will collect personal information include: imei, mac, oaid, iccid, android id, os, brand, model, rom, system version, notification status, wifi, cell, ip.https://docs.getui.com/privacy
SDK Provider: 每日互動股份有限公司
ZXID
will collect personal information include:Weak characteristics of devices (features that do not possess uniqueness and stability): device backup information (device manufacturer, device model, device system information), device network Information (device networking channels and status information), device environment information (screen brightness, battery status and country, device application information (versions of common device applications). Purpose of use: To provide equipment identification and safety risk control services. Partner entity: China Institute of Information and Communication Technology, collection pipeline: SDK collection.Partner's official website link: https://zxid.caict.ac.cn Partner Privacy Policy Link: https://zxid.caict.ac.cn/privacy
SDK Provider: 中國資訊通信研究院
mylinksdk SDK for MyLink App payment

Internet Information Collection

18. In order to ensure the operational stability of our services or implement related functions, our own Software Development kit SDK will also collect users' personal information, and the information obtained from your network is as follows:
SDK Name
Purpose
Personal Information Collected
NetworkCollect
Network Monitoring function
1. Access Fine Location & Coarse Location need to be collected to obtain user location
2. Access the user's device status

DATA ACCESS OR CORRECTION

  1. 19. You are entitled to access or correct your personal data held by us. If you wish to obtain a copy of any of your personal data or if you believe that any of your Personal Data which we collect and maintain is inaccurate, please write to us at the address below:

    Data Privacy Officer
    China Mobile Hong Kong Company Limited
    L20, Tower 1, Kowloon Commerce Centre, No. 51, Kwai Cheong Road, Kwai Chung, New Territories, Hong Kong

    A request for access to or correction of your personal data, or for information regarding policies and practices and kinds of personal data held by us may be sent to us at the following address. In accordance with the PDPO, we have the right to charge a reasonable fee for the processing of any data access request.

  2. 20. You may log in to MyLink app to inquire about your personal information, and the method of inquiry is as follows.
    - Telecom → My Account → Personal information (or the top left-hand corner of the front page→ My Account→ Personal information )。
    NOTICE: If you would like to correct your name as shown, Please bring your valid certificate to China Mobile Hong Kong for registration or enquiry 12580 .
    To ensure the security of your information, we may ask you to authenticate yourself before processing your request .

Withdraw Consent

  1. 21. You could withdraw the authorization you have agreed, and MyLink will not be able to process your corresponding personal information after withdrawing your consent.
    You can revoke the authorization in "Phone Settings → Permissions". The method to turn off authorization is as follows:
    Android: Settings→Privacy→Permissions→MyLink (due to Android devices may be different, please set according to the actual situation)
    iPhone: Settings → Privacy → Permissions → MyLink

DELETE ACCOUNT

  1. 22. Your login user name is your China Mobile Hong Kong mobile phone number. You could delete your current account through 「Settings→ Account Security→ Delete Account」. We will cancel your login status and delete avatar information, message reception settings, and. simplified version switch status information and all MyLink points linked to the account, e-coupon records. If you need to handle the change and deletion of personal information provided during mobile phone number network registration and the cancellation of mobile phone number, please contact us through 12580.

OTHERS

  1. 23. We reserve the right to amend this Statement from time to time.
  2. 24. In order for you to receive push messages from MyLink in a timely manner, systems prior to Android 8.0 will send broadcasts to wake up MyLink auto-start or associated startup behaviors. If you do not need this service, you can turn off notifications in the system settings
  3. 25. If there is any modification to this Terms and Conditions, after the user opens the MyLink App, the page will prompt that this Terms and Conditions has been updated. Please read carefully and click “Agree and Continue”to agree.
  4. 26. If there is any discrepancy between the English version and Chinese version of this Statement, the Chinese version shall always prevail.

Effective Date: 04/04/2024

Version update date: 04/04/2024