私穏政策

1.         Your privacy

Urban Access Solutions CompanyLimited (I, me, my, mine or myself) respects your legal rights of privacy whencollecting, storing, using, processing and transmitting Personal Data and thisPPS explains my privacy practices. I am legally required to comply with thePersonal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong KongSpecial Administrative Region when, in any combination, I collect, hold, use orprocess your Personal Data. In doing so, I will ensure compliance by my staffto the strictest standards of security and confidentiality.

Please read the followingcarefully to understand my policy and practices regarding how your PersonalData will be collected, treated and processed. By providing your Personal Datato us, you are consenting to this PPS and the collection, use, transfer,storage and processing of your Personal Data as described in this PPS.

If you are under the age of 18,you must have a legal representative such as a parent or guardian to acceptthis Policy on your behalf before providing any Personal Data to me.

If there is any inconsistencybetween the English and Chinese version of this PPS, the English version mustprevail.

 

2.         Collectionof Personal Data

Depending on the types andcombinations of goods and services I provide to you, I may collect two basictypes of data from you, “Personal Data” and “Non-Personal Data”.

"Personal Data" means anypersonally identifying data which I may collect from you or ask you to providevoluntarily when you seek any combination of products and services from me andincludes your:

(a)       name as used on your credit card or carregistration;

(b)       vehicleregistration mark number;

(c)       credit card number, CCV number and expirationdate If you choose to use your credit card as your selected method of payment;

(d)       mobilephone number;

(e)       email addresses

from which it is practicable forthe identity of an individual to be directly or indirectly ascertained.

“Non-Personal Data” includes anycombination of aggregate and automatic information, which is data collectedabout the use of any combination of my goods, services and Applications, orabout a group or category of users from which individual identities or otherindividually identifiable information has been removed. This PPS does notrestrict or limit my collection, use and provision of Non-Personal Data.

 

2.1       Personal Data

The following are the commonsituations when I may collect and store your Personal Data, although thesesituations are not exhaustive:

(a)       any combination of you using or browsing my Applications;

(b)       myprovision of services to you, including processing billing and payment for transactionsconducted as part of my services;

(c)       maintenance and operation of my services andApplications;

(d)       collectingmoneys due from outstanding payments for transactions conducted as part of myservices or otherwise; and

(e)       responding to your inquiry, request orcomplaint.

 

2.2       Non-Personal Data

When you use my Applications, Imay keep an activity log that does not identify you individually and cannot beused to identify the identity of any particular user. Generally, I collect andstore the following categories of Non-Personal Data:

(a)       information about your use of a EV chargingstation for the charging service of a vehicle. This information may includecharger ID, location, charge start time, end time, duration, fee, payment type,and charge amount in kwh

(b)       information about your device that you use toaccess any combination of my Applications. This information may include thedevice name, IP address, operating system and version, the type of network andmobile Internet browser you use, the browser’s type and configuration, thegeo-location information and other unique device identifiers of the device,browsing preferences such as language settings and font size, etc; and

(c)        information about your use of any combination ofmy Applications including the domain names you visit and the specific actionsyou take on the Applications, the number of new or returning visits, statisticson the pages visited and referred, a reading history of the web pages and sitesyou have visited and viewed, search terms used and search results, error andcrash statistics and traffic data (such as time, duration and date of access).

The above Non-Personal Data arecollected and used to measure traffic, gauge the popularity of various parts ofmy websites, Applications and services, to gain general knowledge about myaudience and market my websites, Applications and services to advertisers withwhom I may share summarized traffic data. I may also share to third parties(including to those specified under paragraph 4 below) this Non-Personal Datafor any combination of customising, enhancing, optimising, maintaining andimproving the quality of my websites, Applications and services such as fordetermining the optimal screen resolution, language and font settings,transaction flow, etc. This PPS in no way restricts or limits my collection,use, handling and provision of Non-Personal Data.

 

3.         Purposesfor which I will use your Personal Data

I collect your personal data whenyou apply for registration as a user of my services and Applications, when youundertake transactions conducted using any combination of my services andApplications or submit any inquiries, requests or complaints.

The purposes for which I may use your Personal Data will vary depending on the types and combinations of services and products (including the licensing of Applications) you seek from me. Such purposes will be stated in the Personal Information Collection Statement(“PICS”), terms and conditions, Applications or a combination of them relevantto your provision of Personal Data to me. If you fail to supply the PersonalData required, I may be unable to provide the specific combination of requestedproducts and services in full to you.

 

4.         Disclosureand Transfer of Personal Data

In cases where I do collectPersonal Data from you, I will:

(a)       tell you (by way of a PICS or by a separate notification) that I am doing so and any purpose of use that I will make of such Personal Data I collect; and

(b)       where relevant, give you the opportunity to object to particular uses of yourPersonal Data.

I will take all practicable steps to keep your Personal Data confidential but I may (in any combination)disclose, transfer and assign such data to the following parties:

(a)       if I decide to sell, merge or re-organise (in any combination) any part of my business, to any actual or proposed assignee or transferee of or successor to my rights in respect of your Personal Data;

(b)       in any combination, any agent, adviser, auditor, contractor or third-party service provider who provides administrative, telecommunications, computer, payment, fraud prevention, insurance, payment collection, courier, professional services, customer support, data processing and/or other services to me in connection with the operation of my business and the relevant products and services (in any combination) that you seek from me, or who otherwise processes PersonalData for and on my behalf; and

(c)       any person (including government authorities, regulatory or administrative bodies or law enforcement agencies) to whom I, my parent companies or both are under an obligation to make disclosure under the requirement of any law binding on me, my parent companies or both or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which I am expected to comply, or such parties who are authorised by law to request information from me, my parent companies or both.

I may also disclose, transfer or disclose and transfer your Personal Data in the manner as stated in any applicable Personal Information Collection Statement and terms and conditions relevant to the combination of products and services you seek from me.

The parties to whom I disclose, transfer or disclose and transfer your Personal Data may be situated outside ofHong Kong where there may not be in place data protection laws which are substantially similar to, or serve the same purposes as, the Personal Data(Privacy) Ordinance.

 

5.         Linksto other websites and applications

If you use my Applications, there may be advertisements or hyperlinks linking to other website, application or mobile app. If you click on any of these advertisements or hyperlinks, you will leave my Application for another location. At any other website, application or mobile app, the protection of your privacy, Personal Data and your exposure to cookies are not my responsibility and you are advised to refer to the privacy policy of that other location (if any).

Some of my Applications may allow you to link, connect or both to third-party social networking sites. If you choose to link, connect or both to these third-party social networking sites, I may be able to collect certain Personal Data from your social networking profile provided to me by the social networking site. In that case, I will collect and use such Personal Data only for the purpose of providing you with the connection to the social networking site.

 

6.         Cookies

Some of my websites use GoogleAnalytics, a web analytics service provided by Google, Inc. (“Google”). GoogleAnalytics uses "cookies” to help my websites analyze how users use those websites. A cookie is a small text file that is stored on your device (e.g. on your computer) when you visit or access a website. A cookie can be used to identify a computer or a mobile device. It, however, is not used to collect any personal information and does not recognize you personally. In other words, it does not have the function of identifying an individual user of my websites.

Within my websites cookies are used to track the use of and monitor traffic on my websites, as well as to improve, customize and enhance your browsing experience, for example:

(a)       Strictly necessary cookies are used to indicate your active using of my websites and remember the information you’ve entered in a form or details about a payment you want to make. Without them, the information would be lost every time you move to a new page;

(b)       Performance cookies are used to collect anonymous information about how you use my websites, such as which pages you visit on my websites. I use this aggregated information to improve my websites; and

(c)       Functional cookies are used to record information about choices you’ve made and to recommend contents of my websites that are relevant to you and your interests.

On some pages, I feature embedded“share” buttons or widgets that enable you to connect to other socialnetworking sites such as LinkedIn. These sites may set cookies which canidentify you as an individual when you are logged in to their services. I donot control these cookies and you should check the relevant third-party websiteto see how your information is used and how to opt-out.

If you use or continue using mywebsites, I will assume that you are happy for me to set cookies. You maychoose to reject all or some cookies at any time by changing the setting ofyour web browser on your device. Please visit www.allaboutcookies.org to findout how to manage cookies. However, please be aware that if you choose todelete or restrict cookies, you will not be able to use some of the functionsof my websites.

 

7.         Securityand storage

Except as mentioned in paragraph 4above, your Personal Data, however stored, will be accessed only by my employees or contractors who are authorised to do so. Where Personal Data is stored electronically, it will be kept on a secured server and will be encrypted, password-protected (or under some equivalent form of protection) and accessible only by my authorised personnel or my contractors. The network transmission of Personal Data will also be protected by using the SSL protocol.Personal Data are treated as confidential information by me and all employees and contractors designated to handle Personal Data will be instructed to do so only in accordance with this PPS.

Jove does not store your data directly Jove does not store your data directly but uses the services of partners/providers to do so. We systematically choose secure data storage and, when possible, it gets stored on Azure servers in which Jove manages.

 

8.         Use of Personal Data in legal proceedings

If it becomes necessary that Ihave to take action against you for any reason whatsoever including recoveringfrom you any money you owe me, you expressly agree that the Personal Dataprovided by you can be relied upon in identifying and taking legal actionagainst you.

 

9.         Your right to access and correct Personal Data

You may at any time request access to and correct Personal Data relating to you in any of my records. You may also ask me to delete you or your Personal Data from any active mailing or distribution list. To exercise any of your rights, contact me at the address ore mail below marking your communication "Confidential ". In response, I may ask you to provide certain details about yourself so that I can be sure you are the person to whom the data refers. I am required to respond to your requests within 40 days. I may also charge you a reasonable fee for complying with any data access request.

Personal Data Privacy Officer

Any requests (in any combination)

(a)       for access to data or correction of data;

(b)      for general information regarding my policiesand practices with respect to Personal Data;

(c)       about the kinds of Personal Data that I hold;and

(d)      general questions and complaints relating tothis PPS

shouldbe addressed to the person below:

The Data Protection Officer

Urban Access Solutions Company Limited

MTR Headquarters Building, Telford Plaza, 33 Wai Yip StreetKowloon Bay

Kowloon Hong Kong

Email: dpo@jove.com.hk

 

10.       Retention of Personal Data

Personal Data provided by you isretained for as long as the purposes and any directly-related purposes forwhich such data were collected continue. Once it is not necessary to use thePersonal Data to fulfil such purposes (and directly-related purposes), they arethen destroyed within a reasonable time unless their retention is required tosatisfy legal, regulatory or accounting requirements or to protect theinterests of any combination of my parent companies and me.

This PPS is subject to change. Anychanges will be posted on this page. Your continued use of any combination of myApplications and services after the posting of such changes will be deemed tobe your acceptance to such changes.

In the event that there is anyinconsistency between the English and Chinese version of this PPS, the Englishversion must prevail.

 

11. Definitions and interpretation

Unless otherwise defined, theseterms should have the following meanings:

“Application” means any and allversions (including, if any, updates, upgrades, beta versions or anycombination of them) of the software or program used to provide my services inany form, format, media and medium, and any and all websites, micro-sites,software, computer programs, mobile applications and systems and, for suchsites, programs and systems, any other combination of online, digital,electronic and interactive platforms (including front-end and back-endsystems), and any Derivative Works created from or of them, whether conceivedor existing before or after the date of this PPS.

“Derivative Works” means any work created from, based onor derived from the existing works (or any of them) concerned, includingmodifications, improvements, compilations, annotations and translations.

In this PPS, unless statedotherwise, references to the words “include” and “including” are to beconstrued as illustrative and without limitation and the use of the words“must” or “should” in relation to an action, consideration or measure indicatesthat it is a mandatory requirement.

 

July 2023