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.
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.
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.
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.
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
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.
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 TerritoriesHong 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.
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:
Collection of Personal Data from the Use of Digital Platforms
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.
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.
If you have any questions concerning this Privacy Policy Statement or our privacy practices, you may contact our Data Protection Officer by either post or email.
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
Version: 3 August 2015
VTech Holdings Limited and its affiliates (collectively “VTech”) appreciate your interest in our companies and your visit to our website (hereinafter named “Website”). The following terms and conditions set forth the basic rules that govern your use of our Website.
Please read these terms and conditions. If you do not agree to the terms stated below, please leave this Website now.
Your use of our Website constitutes your agreement to comply with the following terms and conditions of use. Each time you use the Website, the current version of the terms and conditions will apply. Accordingly, when you use the Website, you should check and review any changes since the last version.
By using this Website, you agree that:
a. Your use of this Website is at your own risk.
b. You assume full responsibility for all costs associated with services or equipment maintenance arising from the use of this Website. You shall compensate and indemnify VTech and hold it harmless from and against any and all damage claims costs and expense, including attorney fees, arising from or related to your use of this Website.
c. In no event will VTech or its affiliates or any party involved in creating, producing or delivering this Website be liable in any manner whatsoever for any incidental, consequential, indirect, special or punitive damages arising out of your access, use or inability to use this Website, or in connection with any failure of performance, error, omission, interruption, defect, delay in operation or transmission, computer virus or line or system failure (including loss profits, loss of business or data, business interruption, and damages that result from inaccuracy of the information or inconvenience, delay, or loss of the use of the Website). The foregoing limitations apply even if VTech or its affiliates or any other party has been advised of the possibility of such damages.
d. VTech reserves the right to change or delete any contents, or suspend or/and terminate your use of this Website at any time for any reason without notice, and shall not be liable for any loss arising from such change and in any way for possible consequences of such change. Since some jurisdictions do not allow the limitation or exclusion of incidental or consequential damages, the liability of VTech, its affiliates, agents, licensors and supplier in such jurisdictions shall be limited to the extent permitted by law.
e. The word “computer”, when used in these terms and conditions, refers to computers, smartphones and all other devices used for accessing the internet.
Unless otherwise specified, the content and information contained on this Website is presented solely for your convenience. This Website is controlled and operated by VTech from its offices within the Hong Kong Special Administrative Region. VTech makes no representation that any Contents or information is appropriate or available for use in other locations.
These Terms and Conditions shall be governed and construed in accordance with the laws of Hong Kong Special Administrative Region. Any dispute arising out of or relating to these Terms and Conditions or your access or use of this Website will be subject to the non-exclusive jurisdiction of the courts of Hong Kong Special Administrative Region.
When you visit our Website or send emails to us, you are communicating with us electronically. You consent to receive communications from us electronically. We will communicate with you by email or by posting notices on this Website. You agree that all agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.
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