Privacy Statement

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

Walesi ("Walesi", "we", "us" or "our", being Walesi Limited, its subsidiaries,

affiliates and associated companies but excluding members of the Walesi (being

Walesi* and its subsidiaries) and the Vuclip Group (being Walesi)

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 (Laws of Walesi) (the “Ordinance”),

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.

 

Your Data

We may collect, use and hold a range of different Data about you. For the purposes of

carrying on our business (including the verification of your identity to detect, prevent and

address fraud, security or technical issues, the registration, activation and management

of your account with us, and the billing and charging of our products and services

(collectively, “Service(s)”)) and complying with laws, rules, guidelines, regulations and/or

requests issued by applicable government authorities, courts, law enforcement or other

authorities or regulatory bodies, you may be requested to provide Data such as, but not

limited to: 

(a) 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;

(b) contact details including name, address, phone number, mobile telephone number

and/or email address;

(c) Data that you have shared with third party social media platform operators (e.g.

account login name, profile picture, contact details);

(d) payment details including credit card, debit card and other electronic banking Data;

(e) account details or Data relating to Services registered with us including the relevant

PIN, username or password, account numbers and/or service numbers;

(f) device specific information such as hardware model, operating system, version,

unique device identifier, serial numbers, setting configurations and software and mobile

network configuration;

(g) 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;

(h) information that allows us to identify you for verification purpose including biometric

information like your fingerprints and voice pattern;

(i) 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;

(j) 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

(k) any other Data as may be required by any members of Walesi 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.

 

In some instances, where required by law to do so, we may seek your consent to

process the following types of “Special Data” so that we may further improve our

Services and/or better tailor the type of information or content that we present to you:

(a) age;

(b) gender and ethnicity;

(c) marital status; 

(d) salary range and employment details;

(e) education and profession;

(f) hobbies and leisure activities;

(g) the Services that you have subscribed for; and

(h) family and household demographics.

 

Provision of the Special Data mentioned immediately above is optional although, where

the requested Service is a personalised Service or provision of a product is dependent

upon your provision of all requested Data, failure to provide the requested Data may

prevent us from providing those particular Services to you.

 

Occasionally, you may need to provide Data about other individuals to us. If so, we may

require you to confirm your compliance with Part VIA of the Ordinance including

confirming that you have informed those individuals of the use, disclosure and transfer of

Data from you to us and from us to third parties and possible disclosure of the

individual’s details (including their usage of our Services, loyalty programs and Walesi)

by us to you; and that you have obtained those individuals’ authorisation and/or consent

to such use, disclosure and transfer (or the extent to which such authorisation and/or

consent was obtained). You should also advise them that we can be contacted for

further information at the details stated under the “How to contact us” section below.

Data supplied by you will be held by one or more members of Walesi, and will be

accessible by employees of such member(s) and authorised third parties (consistent

with the situations or for the purposes set out in this Privacy Statement) or as otherwise

indicated by prior notice to you or, where required, by obtaining your consent.

 

How we collect Data

We collect Data in a number of ways, including from:

(a) you directly, for example, when you provide Data by phone or via email, attend our

functions, complete an application form or agreement for one of our Services, or when

you submit your Data through our websites, mobile or TV apps, or over any customer

service hotlines or online chat sessions; or when you contact us with a query or request;

or during the ordinary course of the continuation of our business relationship with you; or

when we are legally required to do so;

(b) third parties such as related entities, business partners, or other customers, or your

representatives with appropriate consent from you;

(c) publicly available sources; 

(d) our own records of how you use our Services;

(e) your visits on our websites, or mobile or TV apps (see “Privacy Data” section below);

and/or

(f) your participation in surveys or marketing promotions organised by us or on our

behalf.

 

Privacy Data

To better serve your needs and preferences, our web servers may collect Data relating

to your website, device or app activity. We may also collect aggregated, anonymous,

statistical data on the server's usage so that we may better cater to the behaviour of

users of our websites and mobile and TV apps. This type of Data may include, but is not

limited to:

(a) browser type, version and user agent;

(b) operating system;

(c) IP (Internet Protocol) address and/or domain name;

(d) connection data, statistics on page views and/or referral URLs;

(e) device ID, location and phone contacts;

(f) videos watched or searched for;

(g) songs listened to or searched for;

(h) links or images clicked on;

(i) cookies and/or browser, app or web server log data; and

(j) device and software characteristics and/or configuration.

 

Some of our websites use cookies or similar tracking tools on your machine or device in

order for us to, for example, personalise your user experience and/or maintain your

identity across multiple webpages and/or Internet sessions. This Data may include, but

is not limited to, relevant login and authentication details as well as Data relating to your

activities and the preference configurations on your device and across our websites and

mobile and TV apps. Our websites are initially set up to accept cookies. You can opt-out

of or delete historical cookies by changing the settings on your web browsers; however,

if you do so, you may find that certain features on our website and/or our app do not

work properly.

 

How we use your Data 

We may collect, retain and use your Data for the following purposes:

(a) to verify your identity;

(b) to process your application to subscribe to our Services and loyalty programs

operated by us and/or any members of the Walesi;

(c) to carry out matching procedures, as defined under the Ordinance;

(d) to verify your eligibility to our offers of Services, games and/or promotions or other

events;

(e) to provide, activate and/or renew Services, loyalty programs operated by us and/or

any members of the Walesi, and Walesi that you may have subscribed for;

(f) to provide you with rewards, promotional benefits, updates, offers and invitation to

events;

(g) to promote and market our Services to you;

(h) to conduct credit checks and detect fraudulent activities in compliance with the AntiMoney Laundering and Counter-Terrorist Financing (Financial Institutions) Ordinance

(Cap. 615) and in relation to other compliance purposes;

(i) to perform research or analyses so that we may improve and optimise the Services

and/or loyalty programs that can be made available to you;

(j) to conduct surveys and marketing, promotional, behavioural scoring for business

operations and/or planning purposes;

(k) to carry out market and product analyses in order to generate statistical or actuarial

reports (containing aggregated data that does not relate to any identified or identifiable

individual);

(l) to enforce our contractual rights;

(m) to process any payment instructions, direct debit facilities and/or credit facilities in

relation to our supply of Services to you;

(n) to maintain and develop our business systems and infrastructure, including testing

and upgrading of these systems;

(o) to maintain, enhance and develop our products and service offerings;

(p) to develop financial services and products;

(q) to evaluate your financial needs and insurance claims made by or against you, and to

process claims involving you (including but not limited to making, defending, analysing, 

investigating, processing, assessing, determining, responding to, resolving or settling

such claims);

(r) to comply with our telecommunications licence obligations in respect of

interconnection arrangements with other telecommunications operators and related

industry practices;

(s) to comply with applicable laws in or outside Fiji as may be required by

applicable government authorities, courts, law enforcement, or regulatory or

investigation bodies, in relation to the supply of Services and/or loyalty programs to you,

including to assist in the prevention, detection of crime or possible criminal activities; and

(t) to distribute our publications and research materials as well as those of our business

partners and counterparties.

 

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 Walesi (which may be within or outside of Fiji)

(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.

These Organisations provide support services to our businesses and operations

including without limitation:

(a) customer enquiries;

(b) courier, delivery, logistic and warehouse services;

(c) mailing operations;

(d) billing and debt-recovery functions;

(e) information technology services;

(f) installation, maintenance and repair services;

(g) marketing, advertising and telemarketing services;

(h) market research; 

(i) customer usage and behavioural analysis;

(j) process management;

(k) after sale services;

(l) surveys;

(m) website usage analysis; and

(n) cloud storage services.

 

We take the required steps to ensure that these Organisations are bound by appropriate

confidentiality and privacy obligations in relation to the protection of your Data and that

they use your Data for the sole purpose of carrying out the services for which they have

been engaged, and not for their own or other purposes (including direct marketing).

In addition, we may disclose your Data:

(a) to your authorised representatives and/or your legal advisers when requested by you

to do so;

(b) for the purposes of providing administrative, payment, collection, business, legal

and/or operational support, to the following parties:

(i) credit-reporting and fraud-checking agencies;

(ii) to financial institutions, charge or credit card issuing companies, credit providers,

credit bureau, collection agencies or security agencies;

(iii) telecommunications network operators;

(iv) our affiliates, overseas offices, assignees, transferees and representatives;

(v) our professional advisers, including our accountants, auditors, lawyers and

insurers;

(c) to banks, hotels, insurance companies, insurance brokers, underwriters, billing

agents and various business partners for reward redemption purposes and benefits

applicable to members of the loyalty programs operated by us and/or any members of

the Walesi, including without limitation for the purpose of registering members for

loyalty program related events;

(d) to government and regulatory authorities and other organisations, as required or

authorised by law;

(e) to organisations who manage our business and corporate strategies, including those

involved in a transfer or sale of all or part of our assets or business (including accounts 

and trade receivables) and those involved in managing our corporate risk and funding

functions (e.g. securitisation);

(f) to any proposed or actual participant, assignee or transferee of all or any part of the

relevant member of our operations or business; and/or

(g) to charities or non-profit organisations.

Direct Marketing (if applicable)

We may, in compliance with applicable laws, rules, regulations and licence requirements,

use your Data (including without limitation name, contact information, phone number,

residential/office address and email address and information about the Services you

have purchased), for us (including Walesi and its respective subsidiaries, affiliates

and associated companies) and our respective dealers, suppliers, licensors, providers

and/or business partners (collectively, “Service Providers”)) to provide you with direct

marketing content (pursuant to which we may or may not receive remuneration in return),

including sending to you notices and/or updates about gifts, discounts, privileged offers,

benefits and promotions related to Services offered by us and/or the Service Providers,

including without limitation: TV, telecommunications, over-the-top (OTT) services,

content services, mobile voice, SMS and data communications, IDD/roaming, Internet

connectivity, cloud services, mobile payment, entertainment, secretarial services,

personal assistant services and information services (such as weather, finance and

news information), device accessories, mobile applications and software, computer

peripheral, accessories and software (including notebooks, handsets, mobile devices

and accessories, keyboards, security installations and mobile applications), reward,

loyalty and privilege programs, lifestyle, networking events, travelling, banking, alcohol

and tobacco, sports, music, gaming, transportation, household products, food and

beverages, finance, insurance, wealth management services and products, pensions,

investments, brokering, financial advisory, credit and other financial services and

products, betting, education, health and wellness, beauty products and services, fashion

and accessories, electronics, social networking, technology, e-commerce, logistics, retail,

home and decor, media and high-end consumer products and services. Marketing may

be carried out in a variety of ways (such as in the form of a letter, bill insert/message,

email, digital SMS, MMS, instant message, app push notification, targeted TV message,

broadcast message on eye device, by telephone, social media or advertisements on

websites or other means).

Before using and providing your Data for the purposes as set out in this Privacy

Statement, where we are required by law to obtain your written consent, and in such

cases, only after having obtained such written consent, may we use and provide your

Data for any promotional or marketing purpose. 

 

We will honour each individual's request to not use his/her Data for the purposes of

direct marketing. You may opt-out from receiving direct marketing material and/or

communications from the relevant Service, loyalty program and/or Walesi. At the same

time, you may resume receiving the same (if you have previously opted-out of receiving

such material and/or communications from the relevant Service, loyalty program and/or

Walesi) by making a written request to our Privacy Compliance Officer together with

your registered name and service account number, registered telephone number or login

name (as applicable).

 

Transfer of Data outside Fiji or the country in which you receive our Service(s)

At times it may be necessary and/or prudent for us to transfer your Data to places

outside of Walesi or the country in which you receive our Service(s) (“your Country”),

for instance, for the prevention, detection or investigation of crime or for storage,

processing and other purposes for which the Data were collected. In the event that we

do transfer your Data outside of Hong Kong or your Country, we will do so in compliance

with the prevailing requirements of the Ordinance, the GDPR where applicable and all

other applicable privacy and data protection laws and regulations of your Country.

The safety of your Data is important to us

All required efforts are made to ensure that any Data held by us is stored in a secure

and safe place and is accessible only by our authorised employees or other

Organisations referred to in this Privacy Statement.

 

When we pass your Data to third party Organisations for them to process, we seek to

ensure that they have appropriate security measures in place to keep your Data safe

and to comply with applicable principles in relation to data protection. Some of the

people we share your Data with may process it overseas. You can contact us for more

information about the safeguards we use to ensure that your Data is adequately

protected in these circumstances.

 

Retention of your Data

We will retain your Data in accordance with our internal policies. Our policies are in

compliance with the Ordinance, and cover the following

principles:

(a) 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 Data is also retained to satisfy

any applicable legal, regulatory or contractual obligations; and

(b) Data are purged from our electronic, manual and other filing systems based on the

above criteria and our internal procedures. 

 

Our websites (including but not limited to https://www.walesi.com.fj/)

and mobile and TV applications (if any) may contain links to other websites, webpages

and mobile and TV applications operated by third parties. We have no control over the

content of the linked websites, webpages and mobile and TV applications or the way in

which the operators of those websites, webpages and mobile and TV applications deal

with your Data, and are not responsible for the content of such third party websites,

webpages or mobile and TV applications. You should review the privacy policy of such

third party websites, webpages and mobile and TV applications to understand the ways

in which your Data may be used by those third parties.

 

Your right to access, correct and delete Data

We take all reasonable precautions to ensure that the Data we collect, use and disclose

is accurate, complete and up-to-date. However, the accuracy of that Data depends to a

large extent on the Data you provide. You have a right to request access to, and

correction of, your Data and we recommend that you:

(a) let us know if there are any errors in your Data; and

(b) keep us up-to-date with changes to your Data.

If you wish to access or amend any of your Data we hold, or request that we delete any

of your information that is no longer necessary for the provision of our Services, you may

contact us in the manner as set forth under the “How to Contact Us” section.

If you are a user of Walesi, you may exercise your right of access and correction by

logging on to your Walesi account where you will be able to view and correct the Data

held by us and/or any members of the Walesi about you. If you are not a user of My

HKT, you may write to our Privacy Compliance Officer at the details stated in the “How

to contact us” section below.

We may apply an administrative charge for providing you with access to your Data in

response to such request.

You may decline to share Data with us and/or withdraw any consents which you may

have provided, in which case, we may not be able to provide you with some of our

Services.

At any time, you may object to us holding or processing your Data, on legitimate grounds,

save and except as otherwise permitted by the applicable law. 

 

Facebook Data Deletion Instructions 

Walesi does not save your Facebook personal data on its server. However, according to Facebook policy, we have to provide User Deletion Callback URL or Data Deletion Instruction URL.

If you want to delete your data from Walesi App, you can remove your information by following these steps.

1. Login to Walesi App via Facebook

2. Go to Menu -> Settings -> Account Settings

3. Select Delete account

4. Go to your Facebook Account’s Setting & Privacy. Click “Settings”

5. Look for “Apps and Websites” and you will see all of the apps and websites you linked with your Facebook.

6. Search and Click “Walesi” in the search bar.

7. Scroll and click “Remove”.

8. Congratulations, you have successfully removed your app activities and data from the Walesi App

 

How to contact us

For all issues and enquiries regarding our compliance with our obligations under the

Ordinance and the GDPR where applicable, and any request for access to, correction or

deletion of your Data, please contact us in writing at:

Privacy Compliance Officer

Walesi 

or via email to: info@walesi.com.fj

To raise an issue regarding our handling of your Data, please contact us in order that we

can attempt to resolve your issue.

 

This Privacy Statement may be amended from time to time and all handling of Data will

be governed by the most recent version of this Privacy Statement, available on our

website at https://www.walesi.com.fj/. If there is any inconsistency between the

English and other language versions of the Privacy Statement, the English version will prevail.