Privacy Statement (Notice)

Ventel Limited is committed to safeguarding the privacy of the personal data entrusted to us.
Our mission is to uphold privacy rights in the digital age.

To this end, our strategic objectives are to:

strengthen public trust and confidence in the way we use data;
deliver outstanding telecommunications services underpinned by high standards of information security and privacy;
keep pace with evolving technology.

We strive to earn the trust of our data subjects daily by adhering to six core privacy principles:

Openness and transparency
Purpose and manner of collection
Accuracy and retention
Access and correction
Use of personal data
Security of personal data

1. Terms and definitions

Personal data means any data:

relating directly or indirectly to a living individual;
from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
in a form in which access to or processing of the data is practicable.

Data subject, in relation to personal data, means the individual who is the subject of the data.

Data user (Controller), in relation to personal data, means a person who, either alone or jointly or in common with other persons, controls the collection, holding, processing or use of the data.

Data processor (Processor) means a person who

processes personal data on behalf of another person; AND
does not process the data for any of that person's own purposes.

Direct marketing means, through direct marketing means, (a) the offering, or advertising of the availability, of goods, facilities or services; or (b) the solicitation of donations or contributions for charitable, cultural, philanthropic, recreational, political or other purposes.

Direct marketing means means:

sending information or goods, addressed to specific persons by name, by mail, fax, electronic mail or other means of communication; OR
making telephone calls to specific persons.

2. About us

Ventel Ltd., Unit 1806 Eastern Commercial Centre, 397 Hennessy Road, Wanchai, Hong Kong.

Our contact our data protection specialist via email privacy@ventel.hk.

3. Overview

This Policy informs you of our processing of your personal data when you:

visit our site,
interact with our company and our specialists,

and the choices you have associated with that data.

In cases where we process Personal data to provide services to our client and according to his instructions, we are the Processor, in extreme cases we act as the Data user.

Should you have any questions about this policy or about how we process your personal data, we encourage you to reach out to us, and we will do our best to resolve your concern. You can contact us through the following channels:

email privacy@ventel.hk or
by writing us to: Ventel Ltd., Unit 1806 Eastern Commercial Centre, 397 Hennessy Road, Wanchai, Hong Kong.

We will send responses to your requests to the e-mail address or in any other form, at your wish.

Please carefully read this document.

4. Rights

The right to be informed

On or before collection: of the purpose of collection, the classes of persons to whom data may be transferred, and whether supply is obligatory or voluntary (with consequences of refusal).

On or before first use: of your rights to access and correction, and the contact details of the person handling such requests.

You may also, at any time, ascertain our policies and practices in relation to personal data, the kinds of personal data we hold, and the main purposes for which it is used.

The right to access your personal data

to ascertain whether we hold your personal data;
to request access to it within a reasonable time, at a fee that is not excessive, in a reasonable manner and intelligible form;
to be given reasons if access is refused;
and to object to such refusal.

The right to correction of your personal data

To request correction - meaning rectification, erasure, or completion - of personal data you consider inaccurate; to be given reasons if the request is refused; to object to such refusal; and, for disputed expressions of opinion, to have a note of your objection attached to the data.

The right to withdraw consent

Rights relating to direct marketing

to be informed, and given a free channel to consent, before we use your data for direct marketing;
to be told of your free cessation right on first such use;
to require us at any time, free of charge, to stop using your data for direct marketing;
to be informed and to give written consent before we provide your data to a third party for direct marketing; and to require us, free of charge, to stop providing your data to third parties for direct marketing and to notify those parties to cease use.

The right to notice before adverse action from automated data matching

The right to complain and appeal

To lodge a complaint with the Privacy Commissioner about an act or practice that may contravene the Ordinance, with assistance from the Commissioner's office in formulating the complaint if needed; and to appeal to the Administrative Appeals Board against a refusal or termination of a complaint investigation, or against a decision not to serve an enforcement notice.

The right to compensation

5. Exercising your rights

You may contact us to exercise your privacy rights or ask questions. You can contact us via email privacy@ventel.hk.

If you make a data access or data correction request, we will respond within 40 days. If we are unable to comply fully within that time, we will inform you in writing before the 40 days expire, explain the reason, comply to the extent we are able, and fully comply as soon as practicable afterwards.

If your request is unclear, we may ask for more details.

A reasonable, non-excessive fee may apply to data access requests; data correction requests are free of charge.

We will need to verify your identity before acting on your request, for example by asking for additional information or identification, and we will decline a request if we are unable to verify who you are.

You can appoint a person authorized in writing to act on your behalf. Parents or legal guardians may exercise these rights on behalf of a minor, and a court-appointed representative or personal representative may act on behalf of a person under their care or a deceased person's estate, where applicable.

If we receive a request that contains information we believe to be false or misleading, we may decline it and will explain our reasons.

If we agree that data about you is inaccurate, we will make the necessary correction — which may include erasure — and, where that data was disclosed to a third party within the preceding 12 months, take practicable steps to notify that third party of the correction.

6. Data sharing

We may share your personal information to our service providers (Processors) who handle data processing for us. Additionally, we might share it with public, government, judicial, and law enforcement agencies, provided we are legally allowed to do so. We can also share your information with trusted third parties, such as:

social networks and web platforms (to carry out communication);
external and internal lawyers and/or specialist advisors (to protect our legitimate interests);
public and governmental agencies (to perform our legal duties and obligation)
the police or other government agencies (in the event of a crime or conducting investigations).

7. Security

Your data security is our top priority.

We strive to protect personal data by taking all necessary and appropriate measures to prevent loss, theft, misuse, unauthorized access, disclosure, alteration, or destruction. We maintain an information security program that incorporates physical, technical, and administrative safeguards. Additionally, we apply standard protection measures and ensure our partners maintain a comparable level of security.

To learn more about our security measures, please visit the respective page on our website.

If you have any questions, please contact us via privacy@ventel.hk.

8. Personal data breach

Should a personal data breach occur, we are committed to limiting its impact and addressing any resulting consequences for you. In such an event, we will take all reasonable measures to remedy the situation and minimize any harm that may follow.

Where warranted, we will notify you of any matters affecting your personal data and inform the relevant regulatory authority of the breach, in line with applicable laws.

9. Changes to this notice

From time to time, we may revise this document to reflect changes in legal, technical, or business circumstances. We encourage you to check our website periodically to stay informed about our privacy practices concerning your personal data.

You can access the current version of our Privacy Policy, along with all prior versions, on our website.

10. List of data processing activities

Whether it is obligatory or voluntary for you to provide us with your personal data depends on the purpose for which it is collected, and, where provision is obligatory, we will let you know the consequences if you do not provide it. This may also be indicated separately at the point of collection — for example, on the relevant form, application, or other channel through which we collect your data.

Processing	Data categories
Respond to inquiries/requests from clients	Unique ID Contact data Employment and work data Company data Communication data Electronic communications data
Obtain client feedback	Unique ID Contact data Company data Employment and work data Communication data Electronic communications data
Client audit	Unique identifiers Employment and work data Company data Contact data Communication data
Manage client relationship	Unique ID Employment and work data Company data Contact data Location data Communication data Electronic communications data
Maintain a database of clients	Unique identifiers Employment and work data Company data Economic data