Privacy Notice
PRIVACY NOTICE SECTIONS
THE SKYNET PRIVACY NOTICE
Effective Date: April 21, 2022
1. INTRODUCTIONS
This Privacy Statement sets out how we collect, use, manage and protect the personal data or information (“Data”) that we may collect from or about you. It applies to all individuals whose Data may be handled, whether as controller or processor, by the Skynet Inno-Tech Limited (“Skynet“, “we“, “us” or “our“, being its subsidiaries, affiliates and associated companies), including without limitation, users of SN KYC Total Screening Compliance System, users of SNAML Money Exchange System, clients of Money Service Operator’s license consulting service, students of Anti-Money Laundering & Counter-Financing of Terrorism Course.
This Privacy Notice applies to information we collect from all sources, including in connection with our websites, mobile sites, applications (“apps”), widgets, conferences, events, and electronic newsletters or communications (collectively the “Skynet Services”) that link to this Privacy Notice. If there is a conflict between this Notice and a Skynet Services corporate subscription agreement, the Skynet’s Master Service Agreement, the Skynet Master Service Agreement will take precedence.
This Notice describes the types of Personal Data we collect, how we use it, and with whom we share it. It also describes generally Skynet’s practices for handling Other Information (e.g., interests, demographics and services usage) collected through our Skynet Services or from a third party to the extent such information is associated with a particular device, user or user account. We also describe the measures we take to protect the information, your options for choice and access, and how you can contact us about privacy practices. As described more fully below, we share information with our subsidiaries, and affiliated companies (“Skynet Affiliates”), for the purposes described in this Privacy Notice. By using the Skynet Services, you acknowledge you have read and accept this Privacy Notice.
Your decision to use the Skynet Services and provide your Personal Data is voluntary. We indicate on our online, mobile, and other registration forms what types of Personal Data are requested. You may choose not to submit requested information online, or may choose to restrict the use of cookies (see Other Information below, or our Cookie Notice, for more information), but that may limit the services Skynet is able to provide to you.
The Skynet Services are a network of general audience sites, and are not targeted to, and do not knowingly collect Personal Data from, minors under 16 years of age. We request that these individuals do not provide Personal Data through the Skynet Services.
2. PROTECTING YOUR PRIVACY
We are committed to processing your Data in accordance with the required standards. This includes protecting your privacy and ensuring the security of your Data in compliance with, in particular and where applicable, the requirements of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) (the “Ordinance”), Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (the “GDPR”) where applicable.
Before using and providing your Data for the purposes as set out in this Privacy Statement, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use your Data in the manner as specified.
3. WHAT WE COLLECT
Skynet and our service providers collect Personal Data to offer services you have requested or that we have a legitimate interest to believe are of interest to our customers, to manage the relationships we have with our customers and partners, and to perform activities based on your consent. Skynet and our service providers may collect the following information from and about you:
3.1 Personal Data
“Personal Data” for purposes of this Privacy Notice is the information that identifies you as an individual or relates to an identifiable person.
3.1.1 Personal Data You Submit
We collect Personal Data when you submit it to us, such as when you register for or subscribe to certain products or services; create a profile; participate in a sweepstakes, contest or game; take a survey; visit our website; use an interactive feature (such as chat, chat bot or article sharing options); scan or use our QR codes; participate in a community forum; register for an event or conference; or contact customer service. The Personal Data you may be requested to provide such as, but not limited to:
- the name, date of birth and other details documented on your Hong Kong Identity Card or other legal identity card, travel document, student card and/or driver’s licence;
- company name, company registration number, business registration number, related license number;
- contact details including name, address, phone number, mobile telephone number and/or email address;
- Data that you have shared with third party social media platform operators (e.g. account login name, profile picture, contact details);
- payment details including credit card, debit card and other electronic banking Data;
- account details or Data relating to Services registered with us including the relevant PIN, username or password, account numbers and/or service numbers;
- device specific information such as hardware model, operating system, version, unique device identifier, serial numbers, setting configurations and software and mobile network configuration;
- information about how you use our Services such as your network usage, how you use our network, and your location when you are using our Services;
- your credit and service history to enable us to assess your eligibility to our offers of Services or to accommodate your request for transfer of Services or your account with us;
- all Data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable us to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong); and
- any other Data as may be required by any members of Skynet and/or their respective contractors, sub-contractors, intermediaries, agents, business partners or representatives, brokers, underwriters from time to time and which is necessary for the provision of the Services.
3.1.2 Personal Data We Receive From Third Parties
To the extent permitted by applicable law, we may receive Personal Data about you from third parties, such as social media services, commercially available sources, Skynet Affiliates, business partners, and, if applicable to you, the third party provider of your subscription. The Personal Data we receive from third parties may include your name, contact information, information about your transactions, purchase history, or relationships with various product and service providers, and your use of certain applications. For example, if you access a Skynet Service through a social media service or connect a Skynet Service to a social media service, the information we collect may also include your user ID and/or user name associated with that social media service, any information or content the social media service will share with us, such as your profile picture, or email address. The information we obtain depends on your privacy settings on the applicable social media service. When you access the Skynet Services through social media services or when you connect a Skynet Service to social media services, you are authorizing Skynet to collect, store, and use such information and content in accordance with this Privacy Notice.
3.2 Other Information
“Other Information” is any information that is not intended to reveal your specific identity to us, such as browser information, usage data, information collected through cookies and other technologies, demographic information, geolocation data obtained with your consent where required by applicable law, and aggregated information.
3.2.1 Other Information You Submit
We collect Other Information when you submit it to us. This may include your password, birthday, education or graduation year, occupation, financial information (such as your income, portfolio transactions and value, and other information), live event accommodations, and interests.
3.2.2 Other Information We Receive From Third Parties
We may receive Other Information about you from third parties, including, for example, demographic data, social media account number, information about your interests, and information about your activities on other websites.
3.2.3 Other Information Collected Automatically
Our services use cookies and other tracking technologies to function effectively and deliver certain features. For more information about how we use cookies and tracking technologies, please refer to our Cookie Notice.
The Skynet Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third party Linked Services may use automated means to collect information about you and your use of these features. Some of these third party sites may be co-branded with a Skynet logo, even though they are not operated or maintained by us.
Skynet is not responsible for the privacy practices of such third parties, and once you leave the Skynet Services or click an advertisement, or sign up for a special offer, you should check the applicable third party privacy notice.
4. HOW WE USE YOUR PERSONAL DATA AND OTHER INFORMATION
We may use the Personal Data we collect from and about you for the purposes set forth below. We may use and disclose Other Information for any purpose, except if it is considered Personal Data under applicable law. If we combine Other Information with your Personal Data, we treat the combined information as Personal Data.
To improve the quality of our products and services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other Skynet products, services and websites. In addition, we may supplement the Personal Data and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources, and information from Skynet Affiliates or business partners.
Through third party analytics providers, ad networks, and advertisers, we can track your online activities over time and across third party websites, apps and devices, by obtaining information through automated means.
This information, along with information we gather when you log in, can be used to understand use across sites and devices to help improve our products, remember your preferences, provide content recommendations, and show you advertisements on the Skynet Services or other third party websites and apps that may be tailored to your individual interests. For more information, including how to manage cookies, please refer to our Cookie Notice.
4.1 To Provide, Measure And Improve Our Products And Services
4.2 To Deliver Relevant Content And Recommendations
To make your experience more interesting and personalized, we may use any of the Personal Data and Other Information we collect to assist us in delivering content on any of our Skynet Services. For example, if you use sn-kyc.com and skynet-snaml.com, we may use your skynet-snaml.com reading history to personalize the content delivered to you on sn-kyc.com.
4.3 To Deliver Advertising And Interest-Based Advertising
The Skynet Services and our service providers may use any of the information we collect from and about you (in certain cases, such as with respect to financial information, only with your express permission) to assist us in delivering ads about products and services tailored to your individual interests to you when you use the Skynet Services or another service provided by Skynet, Skynet Affiliates, or unaffiliated third parties. (See What We Collect, above, for details on the types of information we may use.) We may work with third party online advertising companies, advertisers and ad networks who help deliver these ads to you. These third parties may collect and use information about your activities on our Skynet Services and on other websites, and Other Information about you which may include offline purchases, to limit the online ads you encounter to those we believe are consistent with your interests.
To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising, please follow the instructions in the Your Rights and Choices section below.
If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.
4.4 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Skynet Service, we may use Personal Data and Other Information to facilitate your sharing of information between the Skynet Services and your social media service.
4.5 To Contact You
Skynet and Skynet Affiliates may periodically send promotional materials, with your permission where required, surveys, market research, contest or promotional awards, or notifications related to our products and services. To help make these materials more relevant to you, we may use and combine any of the Personal Data and Other Information we collect to assist us in sending you these materials. We may also use your information (including a telephone or mobile number you may have provided for this purpose) to contact you, including to respond to your comments, inquiries or requests. If you want to stop receiving these materials, please follow the instructions in the Your Rights and Choices section below .
4.6 To Protect The Rights Of Skynet And Others
Skynet may use your Personal Data as we believe to be necessary or appropriate in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Skynet, our Skynet Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
5. HOW WE SHARE YOUR PERSONAL DATA AND OTHER INFORMATION
5.1 Our Disclosure of Personal Data and Other Information
Skynet and its subsidiaries may share your Personal Data with one another, as well as with Skynet Affiliates for the purposes described in this Privacy Notice, including for each company’s marketing purposes if you have consented to such use. Users who visit Skynet Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Notice. Skynet is the party responsible for the management of the jointly-used Personal Data.
In addition, we may share your Personal Data with non-affiliated third parties when sharing is permitted by you or authorized by this Privacy Notice, including:
5.1.1 To Manage Corporate, Third Party
If your subscription is provided in whole or in part by your employer, school or other third party, we may share with them information about your access to and use of your subscription.
5.1.2 To Allow Third-Party Service Providers To Assist Us In Providing and Managing Our Services
We may make your Personal Data available to third party service providers, such as contractors, agents or sponsors, or Skynet Affiliates, who help us manage or provide our products and services by, for example: developing or supporting products and features; sending email messages on our behalf; processing payments; fulfilling orders; delivering subscriptions; auditing; processing data or statistics; and serving, customizing or delivering marketing. These third party service providers are required to protect Personal Data entrusted to them and not use it for any other purpose than the specific service they are providing on our behalf.
5.1.3 To Provide Co-Branded Services And Features
We may offer co-branded services or features, such as conferences, events, contests, sweepstakes or other promotions together with a third party (“Co-Branded Services”). These Co-Branded Services may be hosted by the Skynet Services or on the third party’s service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. The third party’s use of your information will be governed by the third party’s privacy notice.
5.1.4 To Allow Social Sharing Functionality
If you log in with or connect a social media service account with a Skynet Service, you are authorizing us to share information we collect from and about you with the social media service provider and other Skynet Services, and you understand that the social media service’s use of the shared information will be governed by the social media service’s privacy notice. If you do not want your Personal Data shared in this way, please do not connect your social media service account with your Skynet Services account, and do not participate in social sharing on the Skynet Services.
5.1.5 To Protect The Rights Of Skynet And Others
There may be instances when Skynet may disclose your Personal Data, including situations where we have a good faith belief that such disclosure is necessary in order to: protect, enforce, or defend the legal rights, privacy, safety, or property of Skynet, our Skynet Affiliates or their employees, agents and contractors (including enforcement of our agreements and our terms of use); protect the safety, privacy, and security of users of our products and services or members of the public; protect against fraud and other unlawful activity or for risk management purposes; comply with and enforce the law or legal process, including laws outside your country of residence, contractual obligations, and our policies; or respond to requests from public and government authorities, including public and government authorities outside your country of residence, to the extent permitted by applicable law.
5.1.6 To Complete A Merger, Sale Of Assets, Or Bankruptcy
If Skynet sells all or part of its business or assets, or is otherwise involved in a merger, reorganization, dissolution, liquidation, or transfer of all or part of its business, as part of that transaction Skynet may transfer your information to the party or parties and their advisors involved in the transaction.
5.2 Information Made Public Through Use of Our Services and User Privacy Settings
Certain features on the Skynet Services give you an opportunity to interact with us and others. These may include the collaboration tools, chats, and rating etc. When you use these features, you should be aware that any information you choose to submit, including your name, user name, location, email address, profile information, likes, status, and comments, including any political or religious or other beliefs you express, may be publicly available to anyone, including other users, search engines, advertisers, third party application developers, and anyone else with access to the Skynet Services. We are not responsible for any information you choose to submit and make public through these interactive features.
6. OUR LEGAL BASIS FOR USING YOUR DATA INCLUDING HOW WE DISCLOSE YOUR DATA
We have a legitimate interest in properly administering the Services. In addition, our use of your personal data may be necessary for the performance of the Services that you have requested. In order to provide the Services that you have requested, we may, to the extent permissible under applicable laws and regulations, disclose your Data to organisations or parties outside of Skynet (which may be within or outside of Hong Kong) (collectively, “Organisations”). Your Data is disclosed to these Organisations for the strict purpose of enabling us to supply our Services to you.
In some circumstances as mentioned above, we may need to ask for your consent to use your Special Data where required by law to do so.
7. HOW WE PROTECT AND RETAIN PERSONAL DATA
Skynet uses a combination of administrative, technical, personnel and physical measures to safeguard Personal Data in its possession against accidental, unlawful or unauthorized loss, use, access, disclosure or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service in accordance with the instructions below.
We will retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or allowed by law.
8. YOUR RIGHTS AND CHOICES
8.1 Your Choices Regarding Our Use and Disclosure of Your Personal Data
We give you many choices regarding our use and disclosure of your Personal Data for marketing purposes.
8.1.1 To Opt Out Of Direct Marketing From Skynet And Skynet Affiliates
You may opt out of receiving electronic communications from us (including surveys, notifications, or promotions from us on behalf of third parties), or our sharing of your Personal Data with Skynet Affiliates for their direct marketing purposes, by changing your account settings through the appropriate link on the website account services page or following the unsubscribe instructions at the bottom of each email. You can opt out of direct marketing from Skynet Affiliates by using the unsubscribe links they provide or following the steps in their applicable policies.
Please note that there are certain service notifications that you may not opt out of, such as renewal notices and notifications of changes to Skynet products and services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app.
8.1.2 To Opt Out Of Direct Marketing From Unaffiliated Third Parties
You may also opt out from our sharing of your contact information with unaffiliated third parties for their marketing by contacting Customer Service.
8.1.3 To Opt Out Of Online Interest-Based Or Text Advertising
You may also opt out of online interest-based advertising by taking the steps detailed in our Cookie Notice.
If you consented to receiving promotions or advertising via Text Message, you can unsubscribe from receiving Text Messages at any time by replying “STOP” to one of our Text Messages.
8.2 How To Access, Correct or Update Your Personal Data
You can access, review, correct, update, delete or modify your registration or subscription profile information and modify your marketing preferences by contacting Customer Service, as indicated below.
For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions you began prior to requesting such change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Data provided until after the completion of such purchase or promotion).Y
9. OTHER IMPORTANT INFORMATION
9.1 Updates to Privacy Notice
Skynet may periodically update this Privacy Notice without prior notice to reflect changes in our practices. Please look at the Effective Date at the top of this Privacy Notice to see when this Privacy Notice was last revised. Any changes to this Privacy Notice will become effective when we post the revised Privacy Notice on the Skynet Services. We will notify you by posting a prominent notice on the Skynet Services indicating we have updated this Privacy Notice. Your use of the Skynet Services or your provision of Personal Data to us following these changes means you acknowledge you have read and accept the revised Privacy Notice.
9.2 Do Not Track Disclosure
Some browsers or other tools include “Do Not Track” (DNT) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Skynet does not currently respond to DNT signals.
9.4 Collection of Personal Financial Information by a Payment Service
In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.
10. CONTACT US
If you have questions about this Privacy Notice or how we or our service providers handle your Personal Data, please contact us at privacy@skynet-inno.com.
Or you in writing at:
Attention: Privacy Compliance Officer
Skynet Inno-Tech Limited
Flat 11, 17/F, International Trade Centre,
11-19 Sha Tsui Road, Tsuen Wan, N.T.
To raise an issue regarding our handling of your Data, please contact us in order that we can attempt to resolve your issue.Please do not disclose any sensitive Personal Data (e.g. ID card number, passport no., etc.) when contacting us.