Version: 17 November 2023
VTech Holdings Limited, together with its subsidiaries and affiliates, ("VTech", "us" or "we") are committed to protecting the privacy of your personal data. We pledge to duly comply with applicable laws and regulations regarding personal data protection, including the Personal Data (Privacy) Ordinance ("PDPO") of Hong Kong SAR and the Data Protection Principles contained therein ("DPP"). This statement is our policy statement on how we collect, use and handle your personal data. It also describes your legal rights, including your right to make data access request and data correction request. When you visit our website, use our service, contact us or communicate with us, you may provide us with your personal data. Please read this statement carefully before furnishing us with any personal data.
This statement applies to VTech Holdings Limited and the websites operated by VTech Holdings Limited. It does not apply to the VTech affiliates operated in North America, Europe and certain countries, and the websites and services offered specifically in the respective countries, including but not limited to: VTech Communications, Inc. and its website www.vtechphones.com; VTech Electronics North America, L.L.C. and its website www.vtechkids.com; and LeapFrog Enterprises, Inc. and its website www.leapfrog.com. Those VTech affiliates and their websites have their own privacy policies, which may be found on each site.
We will communicate any material changes to this statement by posting the updated version on our website. Unless stated otherwise, the changes will be effective from the date of posting.
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.
VTech collects personal data for lawful purposes and by lawful and fair means. The personal data collected in relation to a specified purpose is adequate but not excessive in respect of the purpose. For the collection of personal data from an individual ("Data Subject" as defined under the PDPO), we will inform the Data Subject:
We collect personal data of Data Subjects in the ordinary course of our business and operation. In general, the Data Subjects include our:
We may collect personal data directly from a Data Subject when the individual interacts with us. We may also collect personal data of a Data Subject indirectly from third parties.
Our Personal Information Collection Statement states:
The collected personal data will be used or disclosed to third parties for the purposes:
Our website is not directed to individuals aged below 18. If we are aware that you are under 18, any personal data submitted by you via our website will be deleted.
You may note that certain data may be collected in your use of our digital platforms:
Do Not Track Signals: Our systems do not currently recognize or respond to browser "Do Not Track" signals.
VTech may from time to time and with your consent, use your personal data to send you marketing materials about, including without limitation, our products, services, offers, promotions, campaigns and events.
You may opt out of receiving direct marketing communications at any time by post or by email to our Data Protection Officer, the contact details are set out at the end of this statement. In the case of direct marketing email, you may opt out by following the steps set out in the email.
VTech takes all reasonably practicable steps and implement internal protocols to safeguard the security of the personal data held by us.
The personal data will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software in data transmission. Personal data so transmitted will be in a secure format so that their privacy and security are guarded against unauthorized access or disclosure, accidental loss, alteration or destruction.
In addition, we adopt contractual or other means to prevent any personal data transferred to our data processors both within and outside Hong Kong (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use, if we are to engage any data processor.
VTech's internal IT systems are developed and maintained by its in-house staff and selected third-party service provider. The third-party service provider does not have access to personal data stored in the IT system except when it is carrying out trouble-shooting on it under the supervision of our staff.
VTech takes all reasonably practicable steps to ensure the accuracy of the personal data held by us.
We retain the personal data no longer than is necessary for the fulfillment of the purposes of collection unless a longer retention period is required or permitted by applicable laws and regulations.
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 requests, please send us a completed data access request form which is available at www.pcpd.org.hk/english/publications/files/Dforme.pdf.
We will inform the requestor of the outcome within 40 calendar days of the submission of the request and will give a reason if the request is refused. We may charge a reasonable fee for data access request.
Our website may contain images of and hyperlinks to websites operated by third parties ("Linked Sites"). VTech is not responsible for the contents of any Linked Sites nor the privacy practices of the Linked Sites. You should remain alert when you exit from our website and access these Linked Sites, and check their privacy statements.
VTech Holdings Limited does not do business in California. However, certain VTech affiliates do conduct business in California, specifically: VTech Electronics North America, L.L.C.; VTech Communications, Inc. and LeapFrog Enterprises, Inc. To learn about the personal information these businesses collect from consumers and how they use that information, and to exercise your rights including your privacy rights under the California Consumer Privacy Act ("CCPA"), please see the privacy policies of these companies: for VTech Electronics North America, L.L.C., visit: www.vtechkids.com; for VTech Communications, Inc., visit: www.vtechphones.com; for LeapFrog Enterprises, Inc., visit: www.leapfrog.com.
VTech Holdings Limited
23rd Floor, Tai Ping Industrial Centre, Block 1
57 Ting Kok Road, Tai Po
Attn: Data Protection Officer