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Personal Information Collection Statement

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Version: 17 November 2023

This Personal Information Collection Statement shall be read in conjunction with our Privacy Policy Statement.

As part of VTech’s overall regulatory and governance policy, we comply with the requirements of the Personal Data (Privacy) Ordinance (“PDPO”) of Hong Kong SAR. As already stated in our Privacy Policy Statement, this Personal Information Collection Statement informs Data Subjects (as defined under PDPO) of the purposes for which the personal data is collected, to whom it will be transferred and who is to handle data access and correction requests.

This statement is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version, the English version shall prevail.

  1. Types of Personal Data Collected

General

In general, depending on the nature of the relationship[1] between the Data Subject and us, the personal data to be collected and/or held by us will generally include[2]:

(i)

basic identification and personal information (such as name and gender);

(ii)

contact details (such as email address and phone number); and

(iii)

information collected by means of cookies (including but not limited to webpages visited and options chosen).

It is voluntary for the Data Subject to provide the personal data requested by us. However, if the Data Subject fails to provide the required personal data or if the personal data provided is inaccurate or incomplete, we may not be able to process request made by the Data Subject.

Customers

For Data Subjects who are our customers, additional personal data collected and/or held by us include:

(i)

postal address.

It is voluntary for customers to provide the personal data requested by us. However, if a customer fails to provide the required personal data or if the personal data provided is inaccurate or incomplete, we may not be able to proceed with a purchase order or provide certain services to the customer.

Contractors

For Data Subjects who are our contractors, additional personal data to be collected and/or held by us include:

(i)

business address;

(ii)

business phone number; and

(iii)

personal data of the individuals acting for them and communicating on their behalf with us

It is voluntary for suppliers and business partners to provide the personal data requested by us. However, if suppliers or business partners fails to provide the required personal data or if the personal data provided is inaccurate or incomplete, we may not be able to proceed with any potential business transaction or completing any such transaction with them.

Job Applicants

For Data Subjects who are job applicants, additional personal data to be collected and/or held by us include:

(i)

academic certificates and transcripts;

(ii)

job references;

(iii)

membership of professional bodies and qualifications; and

(iv)

other information provided in the job application form.

It is in general voluntary for job applicants to provide the personal data requested by us. However, provision of certain personal data is obligatory before a job application may proceed. If a job applicant fails to provide the required personal data or if the personal data provided is inaccurate or incomplete, such application may not be accepted or processed.

Employees

For Data Subjects who are employees, additional personal data to be collected and/or held by us include:

(i)

bank account numbers;

(ii)

medical or health-related information; and

(iii)

employment or engagement details and records.

Employees are required to provide personal data to us at the commencement of their employment and throughout the continuance of such relationship. If they do not provide the required personal data or if the personal data provided is inaccurate or incomplete, we may be unable to carry out some of our human resources, administrative and management functions including provision of employee benefits.

  1. Purposes for which Personal Data is Collected and Retention Period

General

In general, depending on the nature of the relationship between the Data Subject and us, the personal data will be used for purposes including:

(i)

our provision of goods and services;

(ii)

handling enquires or complaints; and

(iii)

any other purposes reasonably related to any of the above.

We retain the personal data no longer than is necessary for the fulfillment of the purposes of collection (such as in the cases of customers and contractors) unless a longer retention period is required or permitted by applicable laws and regulations.

Customers

The personal data of customers will be used for additional purposes including:

(i)

general marketing research;

(ii)

planning of promotion events;

(iii)

direct marketing to which the Data Subject has consented;

(iv)

product warranty registration; and

(v)

any other purposes reasonably related to any of the above.

Contractors

The personal data of suppliers and business partners will be used for additional purposes including:

(i)

credit rating assessment;

(ii)

planning of production plan and business expansion; and

(iii)

any other purposes reasonably related to any of the above.

Job Applicants

The personal data of job applicants will be used for additional purposes including:

(i)

assessment of suitability for a job vacancy or other suitable posts;

(ii)

obtaining references;

(iii)

verification of identity and qualifications;

(iv)

determination of the preliminary remuneration and benefits package to be offered to a selected job applicant; and

(v)

any other purposes reasonably related to any of the above.

Personal data of unsuccessful job applicants will be destroyed 6 months after rejection of the application.

Employees

The personal data of employees will be used for additional purposes including:

(i)

enabling staff management, planning and supervision;

(ii)

administering employment or engagement-related entitlements, compensation, payroll and benefits;

(iii)

preparing tax returns and statutory filings; and

(iv)

any other purposes reasonably related to any of the above.

We retain certain personal data of employees when they cease to be employed by us, and such data will be retained for no longer than seven years after their cessation of employment. Such data are required for residual employment-related matters relating to retirement benefits and allowing us to fulfil statutory obligations.

  1. Transfer of Personal Data

In general, depending on the nature of the relationship between the Data Subjects and us and in connection with the purposes of collection, we may transfer your personal data to third parties only if necessary including:

(i)

entities engaged by us for the provision of services and supply of goods; and

(ii)

competent government, legal, regulatory, enforcement or judicial authorities which have jurisdiction over us.

Customers

We may transfer the personal data of customers to additional third parties including entities engaged by us for the provision of:

(i)

product repair and replacement services; and

(ii)

delivery, technology and maintenance services.

Contractors

We may transfer the personal data of contractors to additional third parties including:

(i)

banks; and

(ii)

authorities processing the required registration of the business relationship between us and the contractors.

Job Applicants

We may transfer the personal data of job applicants to additional third parties including:

(i)

former employers and academic institutions; and

(ii)

service providers engaged by us for conducting background checks.

Employees

We may transfer the personal data of employees to additional third parties including:

(i)

banks;

(ii)

insurers and their agents;

(iii)

medical and dental practices;

(iv)

service providers such as external lawyers and other professional advisers; and

(v)

fund administrators or managers of provident fund schemes.

  1. Data Access Request and Data Correction Request

A Data Subject is entitled to make a data access or data correction request pursuant to PDPO. All such requests shall be sent by either post or email to our Data Protection Officer, the contact details are set out at the end of this statement.

For data access request, please send us a completed data access request form which is available at https://www.pcpd.org.hk/english/publications/files/Dforme.pdf.

We will inform you of the outcome within 40 calendar days of your submission of the request and will give a reason if the request is refused. We may charge a reasonable fee for data access request.

By Post:
VTech Holdings Limited
23rd Floor, Tai Ping Industrial Centre, Block 1
57 Ting Kok Road, Tai Po
New Territories
Hong Kong
Attn: Data Protection Officer

By Email:
privacy@vtech.com

Remarks:

[1] The categories: customers, contractors, job applicants and employees.

[2] Examples given are for illustrative purpose only, and any words following the terms “including”, “include”, “in particular”, “such as” or any similar expression shall be construed as illustrative and shall not limit the sense of the words, description, definition, phrase or term preceding those terms. The collection and the related purposes, and retention of the personal data and the scope beyond those stated in the illustration will observe all Data Protection Principles contained in the PDPO.

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