VTech Telecommunications Limited Online Privacy Statement

VTech Telecommunications Limited and its affiliates ("VTech", "us" or "we") values the privacy of our website visitors. Our online privacy statement ("Privacy Statement") describes the types of information we gather from those persons visiting the various Internet web sites owned or operated by VTech (individually referred to as the "Site") and how we use that information.

By accessing this Site, you agree to be bound by the Privacy Statement and our Terms of Use. If you do not agree to the terms of this Privacy Statement, please do not use this Site. Each time you use the Site, the current version of the Privacy Statement will apply. Accordingly, when you use the Site, you should check the date of this Privacy Statement which appears at the bottom and review any changes since the last version.

1. Collection and Types of Your Personal Information Collected

   For the purpose of carrying on VTech's business including sale, provision, registration and advertisements of VTech's related products and services,

   1. We will collect your personal information when you, such as (i) order a product from us online or through our authorized dealers or agents; (ii) contact us with an enquiry or complaint; (iii) use VTech's products or services; or (iv) visit or browse VTech's websites.
   2. The information that VTech collects include but is not limited to (i) your name; (ii) correspondence address and/or billing address; (iii) account details, including account numbers, service numbers or user accounts; (iv) payment details including credit card information, bank account and other banking information; (v) contact details, including contact name and fixed and mobile telephone number and email address; (vi) your date of birth; (vii) information for the verification of your identity, including identification type and identification number; or (viii) your preferences for particular products, services or your hobbies and leisure activities.

2. Information Collected on this Site will be Used According to the Following Guidelines:

   1. VTech may use and analyse your information for the following purposes including but not limited to: (a) processing your order and providing the products and services that you have bought from us and keeping you updated with the progress of your order; (b) billing you for ordering VTech's products or services or contacting you if necessary; (c) for the daily operation of our provision of VTech products and services (including relevant online services) to customers; (d) designing products or services for customers' use; (e) analyze and monitor consumer and customer activity; (f) promote and support VTech products; (g) develop a knowledge base regarding its Site users and customers; and/or (h) marketing the following products and services (in respect of which VTech may or may not be remunerated):

      1. all products or services by VTech including electronics products, entertainment, education, household and other consumer products and services;
      2. reward, loyalty or privileges programmes and related products and services; and
      3. products and services offered by VTech's business partners including electronics products, entertainment, education, household and other consumer products and services.
   2. Your personal information will be kept confidential but VTech may disclose information about you to (a) companies in the VTech Group; (b) contractors, agents or suppliers who are involved in delivering the products and services you have ordered or used; (c) any banking or financial institutions, charge or credit card issuing companies, or credit information or reference bureaux; (d) any agent, contractor or third party service provider who provides administrative, telecommunications, computer, payment or other services to VTech in connection with the operation of its business; (e) law-enforcement or government bodies, regulatory bodies, courts or as required by law; (f) third party reward, loyalty and privileges programme providers; (g) external service providers (including but not limited to mailing houses, telemarketing and direct sales agents, call centres, data processing companies and information technology companies) that VTech engages for the purposes set out in paragraph 2.a.

3. Security of Personal Information and Transfer Outside Hong Kong

   1. VTech has adequate measures to protect your personal information from unauthorized access, accidental loss or destruction.
   2. If VTech uses third-party advertising companies to serve ads on our behalf, these companies may employ cookies and action tags (also known as single pixel gifs or web beacons) to measure advertising effectiveness. Any information that these third parties collect via cookies and action tags is completely anonymous. In that regard, VTech will ensure they have appropriate security measures and only process your information as VTech has authorized.
   3. When VTech's servers, suppliers or service providers are based outside Hong Kong or if you order our products or use our services while visiting countries outside Hong Kong, your personal data will be transferred to other group companies or service providers outside Hong Kong. In that regard, VTech shall take the appropriate steps to protect the security of your personal information.

4. General Provisions

   1. The security of your personal information is important to us and VTech is committed to handling customer information carefully. We make reasonable efforts to follow generally accepted industry standards to protect the personally identifiable information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personally identifiable information, we cannot guarantee its absolute security. IN NO EVENT WILL VTECH OR ITS AFFILIATES OR ANY PARTY INVOLVED IN CREATING, PRODUCING OR DELIVERING THIS SITE BE LIABLE IN ANY MANNER WHATSOEVER FOR ANY INCIDENTAL, CONSEQUENTIAL, INDIRECT, SPECIAL OR PUNITIVE DAMAGES ARISING OUT OF YOUR ACCESS, USE OR INABILITY TO USE THIS SITE, OR IN CONNECTION WITH ANY FAILURE OF PERFORMANCE, ERROR, OMISSION, INTERRUPTION, DEFECT, DELAY IN OPERATION OR TRANSMISSION, COMPUTER VIRUS OR LINE OR SYSTEM FAILURE (INCLUDING LOSS PROFITS, LOSS OF BUSINESS OR DATA, BUSINESS INTERRUPTION, AND DAMAGES THAT RESULT FROM INACCURACY OF THE INFORMATION OR INCONVENIENCE, DELAY, OR LOSS OF THE USE OF THE SITE). THE FOREGOING LIMITATIONS APPLY EVEN IF VTECH OR ITS AFFILIATES OR ANY OTHER PARTY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
   2. In the event that VTech sells substantially all of its assets, or one of its units are acquired, personally identifiable information of visitors to the Site and aggregate information will likely be one of the transferred assets.
   3. VTech is concerned about the safety of children when they use the Internet, and understands that children may not understand all the provisions of our Privacy Statement or make informed decisions about the choices that are made available to adult users of the Site. We encourage parents and guardians to spend time with their children online and to be familiar with the sites their children visit. Our Site is not directed to children under the age of 18. If you do not qualify to submit information via our Site and do so anyway, your data will be deleted and your ordered products will not be processed.
   4. Cookies are pieces of information which websites transfer to your computer's web browser for storage on your computer's hard drive. VTech uses cookies to measure activity on our Site, which allows us to improve navigation throughout our Site. In addition, cookies on the Site may contain information (such as a unique user ID), which tracks the pages of the Site you have visited. This information allows us to make updates to enhance your experience. Parts of the Site will not function if you do not have cookies enabled. You can set your browser to refuse cookies, or to alert you when cookies are being sent. If you turn off cookies or refuse them, though, you may not be able to use every portion of our Site. A pixel tag, also known as a clear GIF or web beacon, is an invisible tag that may be placed on certain pages of our Site but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, registering when a particular computer visits a particular page. If you turn off cookies the pixel tag will simply detect an anonymous website visit.
   5. VTech reserves the right to change this Privacy Statement. If we do change this Privacy Statement, we will post the revised version on this site and will also post the date it was last updated at the bottom of this Privacy Statement. Any information that we collect now will be used consistently with the Privacy Statement in effect at the time of use.
   6. The Site may contain images of and links to third party web sites ("Linked Sites"). VTech is not responsible for the contents of any Linked Site nor the privacy practices of the Linked Sites.
   7. All information provided by you at any chat room, forum, message board and/or news groups in the Site may open to public. Please consider carefully when you provide your personal information in the aforesaid manner.

5. Request For Access To Personal Information

   1. Please be reminded of your statutory rights under the Personal Data (Privacy) Ordinance, you as customer are entitled to, including but not limited to, check whether VTech holds personal data about you and receive copies of such data, or request VTech to correct the relevant information relating to you which is inaccurate. In that regard, VTech shall be entitled to charge you a reasonable fee for processing a data access request.
   2. For any requests for access to personal data, correction of personal data, information relating to the kind of data held and to stop receiving or re-start receiving direct marketing, please inform us in writing by (a) sending us an e-mail to [vtechphones_hk@vtech.com]; or (b) sending us such request by post to our postal address at [Unit 1805, Stelux House, 698 Prince Edward Road East, San Po Kong, Kowloon, attn: VTech Telecommunications Limited, Customer Services]. Please be sure to include in any e-mail or postal mail, your full name, e-mail address, postal address, and any message. Please note that such requests may take up to fourteen (14) days to become effective.
   3. For any complaint in respect of our use of your personal information, please inform us in writing by sending us an email to our Legal & Compliance Department at privacy@vtech.com.

6. Miscellaneous

   Should there being any inconsistency between the English version and the Chinese version of this Privacy Statement, the English version shall prevail.

For the purpose of this Privacy Statement, "VTech" or "VTech Group" means VTech Holdings Limited and its affiliated companies. Companies in the VTech Group shall include, without limitation, VTech Communications Limited, VTech Electronics Limited and VTech Telecommunications Limited.

The information contained in the Site is subject to change without notice. Updated by VTech on [13rd Nov 2013].