1.         Your privacy

Urban Access Solutions Company Limited (I, me, my, mine or myself) respects your legal rights of privacy when collecting, storing, using, processing and transmitting Personal Data and this PPS explains my privacy practices. I am legally required to comply with the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region when, in any combination, I collect, hold, use or process your Personal Data. In doing so, I will ensure compliance by my staff to the strictest standards of security and confidentiality.

Please read the following carefully to understand my policy and practices regarding how your Personal Data will be collected, treated and processed. By providing your Personal Data to 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 accept this Policy on your behalf before providing any Personal Data to me.

If there is any inconsistency between the English and Chinese version of this PPS, the English version must prevail.

2.         Collection of Personal Data

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

"Personal Data" means any personally identifying data which I may collect from you or ask you to provide voluntarily when you seek any combination of products and services from me and includes your:

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

(b)       vehicle registration mark number;

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

(d)       mobile phone number;

(e)       email addresses

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

“Non-Personal Data” includes any combination of aggregate and automatic information, which is data collected about the use of any combination of my goods, services and Applications, or about a group or category of users from which individual identities or other individually identifiable information has been removed. This PPS does not restrict or limit my collection, use and provision of Non-Personal Data.

2.1       Personal Data

The following are the common situations when I may collect and store your Personal Data, although these situations are not exhaustive:

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

(b)       my provision of services to you, including processing billing and payment for transactions conducted as part of my services;

(c)       maintenance and operation of my services and Applications;

(d)       collecting moneys due from outstanding payments for transactions conducted as part of my services or otherwise; and

(e)       responding to your inquiry, request or complaint.

2.2       Non-Personal Data

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

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

(b)       information about your device that you use to access any combination of my Applications. This information may include the device name, IP address, operating system and version, the type of network and mobile Internet browser you use, the browser’s type and configuration, the geo-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 of my Applications including the domain names you visit and the specific actions you take on the Applications, the number of new or returning visits, statistics on the pages visited and referred, a reading history of the web pages and sites you have visited and viewed, search terms used and search results, error and crash statistics and traffic data (such as time, duration and date of access).

The above Non-Personal Data are collected and used to measure traffic, gauge the popularity of various parts of my websites, Applications and services, to gain general knowledge about my audience and market my websites, Applications and services to advertisers with whom I may share summarized traffic data. I may also share to third parties (including to those specified under paragraph 4 below) this Non-Personal Data for any combination of customising, enhancing, optimising, maintaining and improving the quality of my websites, Applications and services such as for determining 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.         Purposes for which I will use your Personal Data

I collect your personal data when you apply for registration as a user of my services and Applications, when you undertake transactions conducted using any combination of my services and Applications 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 relevant to your provision of Personal Data to me. If you fail to supply the Personal Data required, I may be unable to provide the specific combination of requested products and services in full to you.

4.         Disclosure and Transfer of Personal Data

In cases where I do collect Personal 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 your Personal 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 Personal Data 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 of Hong 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.         Links to 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 Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics 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 social networking sites such as LinkedIn. These sites may set cookies which can identify you as an individual when you are logged in to their services. I do not control these cookies and you should check the relevant third-party website to see how your information is used and how to opt-out.

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

7.         Security and 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 I have to take action against you for any reason whatsoever including recovering from you any money you owe me, you expressly agree that the Personal Data provided by you can be relied upon in identifying and taking legal action against 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 policies and practices with respect to Personal Data;

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

(d)      general questions and complaints relating to this PPS

should be addressed to the person below:

The Data Protection Officer

Urban Access Solutions Company Limited

MTR Headquarters Building, Telford Plaza, 33 Wai Yip Street Kowloon Bay

Kowloon Hong Kong

Email: dpo@jove.com.hk

10.       Retention of Personal Data

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

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

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

11. Definitions and interpretation

Unless otherwise defined, these terms should have the following meanings:

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

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

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

July 2023