WIFI STATION is committed to protecting privacy and security of your personal information. This Privacy Policy (hereinafter referred to as this “Policy”) illustrates how we collect, process, use and protect personal information.Please note that:”WIFI STATION” or “us” referred to in this Policy shall be subject to Article 1.2 of the Terms and Conditions.If any term hereunder involves “representation with a legally binding effect”, you agree to use “electronic transmission” as the means of such representation.When you provide us with information of any third party (such as a traveler, contact person or recipient), you represent and warrant that the third party has authorized you to provide his/her personal information to us, and you shall ensure that the third party has acknowledged the contents hereunder and agreed that we may collect, process and use his/her personal information in accordance with this Policy.Please read this Policy carefully. If you do not agree to the processing of your personal information in the way this Policy describes, please do not register as a WIFI STATION member or submit any personal information to us. If you are not an adult in accordance with the laws of your country, please make sure that your guardians have read this Policy and that you register as a WIFI STATION member or submit your personal information to us with the consent of your guardians.If you have any question, comment or would like to exercise your rights with respect to this Policy, please feel free to contact us at global@wifistation.com.hk

1. Scope of this Policy1.1 This Policy applies to all the personal information of WIFI STATION members, potential customers (such as customers who request for information on products, participants who attend the marketing activities, etc.) or partners (such as participants who join the affiliate program, bloggers, photographers, YouTubers, content-creators, etc.) and those that are collected by us through the WIFI STATION website (WIFI STATION.com) and WIFI STATION mobile device application (app) (personal information means data related to any identified or identifiable natural person).1.2 Please note that if you link to any other domain or app that is not part of the WIFI STATION website or app, we may not be able to continue to maintain the security of your personal information. You are advised to read the privacy policy of that domain or app before linking to any other domain or app.

2. Legal Basis for Our Collection, Processing and Use of Personal InformationTo the extent necessary and relevant pursuant to applicable data protection laws, WIFI STATION collects, processes and uses personal information pursuant to any of the following legal basis:2.1 A relationship of contract or quasi-contract with the parties and appropriate security measures have been taken.2.2 With the consent of the parties.2.3 Explicit provisions in the law.2.4 Personal information disclosed by the parties themselves or otherwise lawfully disclosed.2.5 Based on the legitimate interests.

3. How Do We Collect Personal Information/What Personal Information Do We Collect

• 3.1 Personal information provided by you
  We will obtain personal information that you have entered on the WIFI STATION website or app, or provide through telephone, letter, email, communication software or other means, including:
  • 3.1.1 Membership
    Membership data is your and frequent traveler’s personal information including identification, characteristics, account number and password. You can choose whether to update the membership data or not. If you do not choose to update your basic data and frequently-used traveler data, we will not be able to automatically insert your order and traveler data by the system when you place orders. However, we recommend that you update your password regularly to keep your account safe.
  • 3.1.2 Order
    • Customer/recipient/traveler/contact data
      When you place an order, depending on the type of products you purchase, you may need to provide the personal information of different individuals, including identification and characteristics, etc. (for example, you may need to provide your passport name and passport number in both Chinese and English when purchasing foreign tour products, or the recipient’s name and address when you purchase pre-mailed physical tickets). You may also choose whether to update the data to the membership data.
    • Payment and financial data
      Credit card information (card number, expiry date and security code) and other payment method information.
    • Refund proof data
      Depending on the reason for your cancellation/refund, medical and health records may be required.
  • 3.1.3 Business partners (such as data of participants who join the affiliate program, bloggers, photographers, YouTubers, content-creators, etc.)
    If you are interested in becoming our business partner, we need to obtain your personal information, including:
    • Basic data and contact information such as identification, characteristics and working situation
    • Proof data for qualification review
    • Financial account data for payment
  • 3.1.4 Tour-planning
    When you request us to help with your tour planning, we need to obtain basic data and contact information such as identification.
  • 3.1.5 Participants in activities
    When you participate in various activities held by us (such as filling in questionnaires, competitions, psychological tests, lucky draw and other survey or marketing activities), we need to obtain your personal information, such as identification and characteristics, depending on the contents of the activities.
  • 3.1.6 Customer service
    When you make inquiries, feedback or complaints to us through various contact methods, we need to obtain your basic data and contact data such as identification and characteristics. When we communicate over the phone, we may record the whole conversation.
• 3.2 Obtained from a third-party service provider
  • 3.2.1 When you register as a member of a third-party service provider (e.g., Facebook, LINE, Google), we will obtain your data(such as name, photo, email address and any information you choose to provide) and UID according to your settings at the third-party service provider.
  • 3.2.2 We will also obtain relevant data from third-party service providers about your interactions with WIFI STATION on their websites or apps(such as your likes or comments on WIFI STATION’s Facebook page).
• 3.3 Automatic collection via online behaviors
  When you use the WIFI STATION website or app, we will use cookies or similar technology to obtain your personal information and record your online behaviors, such as:
  • 3.3.1 IP address.
  • 3.3.2 Your stay, browsing or clicking on the WIFI STATIONwebsite or app page.
  • 3.3.3 Traffic data.
  • 3.3.4 The webpage you visited before linking to the WIFI STATION website.
    See the Cookie Policy for more information.
• 3.4 Provided by business partners
  If you participate in marketing activities jointly organized by us and our third-party business partners, we may obtain your personal information (such as prize winners’ data) from the business partners to the extent necessary.
• 3.5 Obtained through affiliates
  We may also obtain your personal information from our affiliates , in your location, and add the data to our database to the extent necessary.
  

4.Why Do We Collect Personal Information/How Do We Use Personal Information

• 4.1 Membership management
  When you register as a member of WIFI STATION, we will create a membership profile for you so that we can manage all membership data. You can do the following in the “Account Settings”:
  • 4.1.1 Update basic data and frequently-used traveler data to help you automatically insert the required information when placing orders.
  • 4.1.2 Update the password to maintain the security of your account.
• 4.2 Order management (fulfillment/termination)
  • 4.2.1 After you place an order, we will collect the personal information of the customer/recipient/traveler/contact person depending on the products you purchase in order for us to process and fulfill your order, such as:
    • booking your tour.
    • sending the products you purchase (such as ticket, SIM card, WIFI device, etc.).
    • processing your payment.
    • providing you with information about the products you ordered (such as confirmation letter or advance notice) or contact you or the contact person for products you ordered.
  • 4.2.2 If you want to cancel the order or apply for refund, we may also need additional personal information for processing the refund and qualification review.
• 4.3 Business partner management
  To establish/fulfill our contractual relationships with our business partners (such as participants who join the affiliate program, bloggers, photographers, YouTubers, content-creators):
  • 4.3.1 We will review the proof data provided by you, and after the contractual relationship is established, we will contact you for the required business contacts and payments. We will also recommend information about suitable products to you.
  • 4.3.2 We may also use your personal information to order products for you (such as tours, tickets, etc.) and/or provide your personal information to the supplier or merchants depending on the contents of the products.
• 4.4 Tour-planning and management
  When you request us to help with your tour planning, we will use the data you provide to us to design suitable package for you and contact you. We will also recommend our products to you from time to time.
• 4.5 Activity management
  • 4.5.1 When you participate in any of our activities (such as questionnaires, competitions, psychological tests, lucky draws, etc.), we may contact you to communicate the contents of the activities, or disclose the data to the extent necessary (such as the accounts of prize winners).
  • 4.5.2 When you win the prize, if necessary, we will send the prize to you via your email address or physical address.
  • 4.5.3 If your prize amount reaches the legal threshold, we also need to obtain the necessary personal information from you to declare in accordance with the law.
  • 4.5.4 We will also recommend our products to you from time to time.
• 4.6 Customer service
  When you make inquiries, feedback or complaints to us, we will use your contact information to keep you updated of the status, or provide your data to our supplier, merchant or business partner (such as payment service provider flow or logistics provider) based upon the specific needs in order to assist the handling of the matter. If any dispute arises or is likely to occur, we will also use the communication records between the parties (such as emails or telephone recordings) as evidence.
• 4.7 Marketing
  If you are a member of WIFI STATION or our business partner, or you have ordered any products from us, participated in our activities, inquired about product information (as a potential customer), we will use your contact information to recommend the latest itineraries, discount information, other newsletters or product information you may be interested in, or deliver advertisement to you on third-party platforms (such as Facebook). To the extent required by applicable data protection laws, we will not use personal data for direct marketing purposes unless we have obtained your consent.
• 4.8 Survey, statistics and analysis
  • 4.8.1 We will survey your comments on the products from time to time.
  • 4.8.2 We will analyze users’ behaviors on the WIFI STATION website and app to optimize our performance and service and improve our product planning.
  • 4.8.3 We will analyze the data you left through your online activities (such as products you search and browsing or clicking behaviors, etc.) or your participation in various activities (such as questionnaires you fill out and competitions, quizzes or lucky draws you participate, etc.) to evaluate products you may be interested in.
  • 4.8.4WIFI STATION will collect statistics and analyze the collected data to evaluate customer willingness to purchase products and the items which customers like, develop marketing strategies, improve service quality, predict the future trend of hot selling products, or recommend suitable products.
• 4.9 Exercise of rights/fulfillment of statutory obligations
  • 4.9.1 In case of any consumer disputes, non-performance of contract, infringement or criminal acts, we will use personal information to the extent necessary to make a legal request or defense, such as providing the data to the competent authority or judicial authority.
  • 4.9.2 If required by law, WIFI STATION will also provide your personal information to the competent authority or judicial authority in order to fulfill our statutory obligations.
• 4.10 In the event any of the following occurs, we may also use your personal information for other purposes:
  • 4.10.1 With consent of the parties.
  • 4.10.2 Expressly required by law.
  • 4.10.3 Where it is necessary for protecting public interest, such as when we think that your actions may be illegal, we may provide personal information to the judicial authority.
  • 4.10.4 Where it is to prevent harm to life, body, freedom or property of the parties.
  • 4.10.5 Where it is to prevent material harm to the rights and interests of others.
  • 4.10.6 Where it is beneficial to the rights and interests of the parties.

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5. Who Obtains Personal Information/Why is Personal Information Obtained

• Within the following scope, to the extent necessary, personal information may be obtained by or transferred to third parties:
• 5.1 Where we use the cloud service providers to store personal information in cloud space.
• 5.2 In order to contact you, we use communication software or systems as a medium, your personal data will be processed, used or stored within such communication software or systems.
• 5.3 In order to complete the transaction, the payment service provider (for processing the payment) or the logistics provider (for sending or receiving products, such as collecting your passport to arrange a tour) we cooperate with may obtain your personal information.
• 5.4 Where we provide personal information required for the order to the supplier according to your specific order requirements. Please note that the supplier or merchant receiving the data may, if necessary, contact you or the contact person to collect additional personal information needed for the products or to communicate with you about the products; the supplier or merchant may also provide your order data to others in order to complete your purchase. Please also read the supplier or merchant’s privacy policy.
• 5.5 Where we provide the order data to WIFI STATION’s affiliates in your location.
• 5.6 If you participate in marketing activities jointly organized by us and our third-party business partner, we may provide your personal information (such as the prize winner’s information) to the business partner to the extent necessary.

7. Use of Personal Information /Retention Period

WIFI STATION will continue to use your personal information while the aforementioned collection purpose still exists. Where the purpose of the collection ceases, we will no longer keep the data in a way that will identify you, unless otherwise required by law.

8. How Do We Protect Personal Information

• 8.1 WIFI STATION is committed to protecting the security of your personal information. We take appropriate administrative and technical measures to ensure the legality of our collection, processing and use of personal information, and to prevent personal information from being tampered with, damaged, lost, leaked or otherwise infringed.
• 8.2 We will take reasonable steps with our suppliers or merchants to ensure the security of your personal information in order to maintain the confidentiality, integrity and availability of personal information.
• 8.3 We will also carefully select the business partners we instruct to collect, process or use personal information, and supervise the security of personal information by contractual and other reasonable means.
• 8.4 However, you need to understand that no 100% security maintenance measures over the internet are 100% secure, so we cannot guarantee the absolute security of your personal information.

9. The Rights You May Exercise through Us

• To the extent provided by applicable laws, you may exercise the following rights with respect to your personal information through WIFI STATION:
• 9.1 Access to your personal information, including the right to make an inquiry of or to request to review or make a copy of your personal information. Unless any of the following occurs, we will not refuse the exercise of your rights:
  • 9.1.1 Impairing national security, diplomatic and military confidentiality, overall economic interests or other vital national interests.
  • 9.1.2 Obstructing the performance of statutory obligations imposed by competent authorities.
  • 9.1.3 Impairing significant interests of WIFI STATION or a third party.
• 9.2 Supplement or correction (Depending on the situation, you may need to provide appropriate explanations)
• 9.3 Requesting to stop collecting, processing or using personal information or requesting to delete personal information
  • 9.3.1 If you think that we collect your personal information illegally, you have the right to ask us to stop collecting, processing and using your personal information. You also have the right to ask us to delete your personal information.
  • 9.3.2 If the accuracy of your personal information is in dispute, you have the right to request us to stop processing or using your personal information. However, this shall not apply where it is necessary for us to operate the business, or where you agree us to continue to process or use your personal information in writing (and noting the dispute over the accuracy of personal information).
  • 9.3.3 When WIFI STATION’s purpose of collecting your personal information ceases (that has been achieved or no longer exists, such as where you want to terminate the membership) or the term expires, you have the right to request us to delete or stop processing or using your personal information. However, this shall not apply where it is necessary for us to operate the business (such as during the statutory retention period or account processing not yet completed, etc.), or where you agree us to continue to process or use your personal information in writing.
• 9.4 You may withdraw consent you previously provided to us for certain processing activities by contacting us at global@wifistation.com.hk. For example, if you no longer want to receive marketing materials from WIFI STATION, you may withdraw your consent to receive direct marketing by clicking the link in the marketing materials or contacting us with the above email.
• 9.5 Right to personal information portability
  You may request us to make your personal information available to you in a structured, machine-readable, universally used electronic format, or transfer it to a third party to the extent technically feasible.
• 9.6 The way for Right Exercise
  You may login to access, supplement and correct your personal information, or you may contact WIFI STATION customer service mailbox at global@wifistation.com.hk to exercise the abovementioned rights. You may also file a complaint about the dispute related to your personal information with the competent authority where WIFI STATION is located.

10. Cookie Policy

We use cookie to collect the personal information of website visitors and app users. Please refer to the Cookie Policy for the privacy policy of cookie.

11. Personal Information of Minors

• 11.1 If you are not an adult in accordance with the laws of your location, please have your guardians read and accept this Policy, and your guardians should agree to register you as our member or submit your personal information to us.
• 11.2 If the data you fill in contains the personal information of a minor when placing an order, you should represent and warrant that his/her guardians agree you to provide such minor’s data to us.

12. Change of this Policy

• 12.1 WIFI STATION may update this Policy in the future. You are advised to pay attention to the latest version of this Policy. In the event of a major update, we will notify you proactively in an appropriate manner (such as sending email, bouncing window notification, app notification, etc.).
• 12.2 Where you are not willing to accept our updated policies to collect, process and use your personal information, please contact us at global@wifistation.com.hk.