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PERSONAL INFORMATION COLLECTION STATEMENT FOR TVB NEWS (“PICS”)

1.
This PICS applies only to information submitted and collected through your registration or use of our TVB News App (our “App”) and the services provided therein (our “Service”) provided by Television Broadcasts Limited (“we”, “us”, “our” or “TVB”). By submitting your personal identifiable information, you agree to this PICS, as amended from time to time. This PICS is incorporated into and forms part of our Terms and Conditions (“T&C”) //yr.xjs678.app/terms.php?lang=en . Please also refer to TVB Privacy Policy as set out on //corporate.tvb.com/html/privacy.html.
2.
We regularly review this PICS and may from time to time amend its terms and conditions by updating it on our app (“our App”) or at //yr.xjs678.app/pics.php. By continuing to use our App and Service after any amendments to this PICS, you are agreeing to this PICS as revised, so please do visit our App or //yr.xjs678.app/pics.php periodically for updates.
3.
We respect your personal information and are committed to implementation and compliance with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486 (“the Ordinance”).

COLLECTION OF PERSONAL INFORMATION

4.
Data relating to your use of our App and Service are collected from you when you use our App and Service.
5.
Personal information that we may collect from you includes (a) information you provide when you use our App, contact our support service or during other customer communications; (b) information about your phone or other web enabled device (collectively, the “Device”), which may include mobile app token, language settings, geo-location and location of your device, device type/manufacturer, Internet Protocol (IP) address (and domain names), operating system type and version, network type, and Internet service providers; (c) information about your usage of our Service and App, which may include the time/duration and the contents and pages visited or our Service used (access log); (d) Device identifiers, such as IOS identifiers for Advertising (IDFA), Android Advertising ID etc.; as well as information about ads served, viewed, or clicked on, such as the type of ad, where the ad was served, and whether you clicked on it, etc. (see below PERSONAL INFORMATION FOR SERVING AND PERSONALIZED ADVERTISING.

USE OF PERSONAL INFORMATION

6.
All personal information provided by you are on a voluntary basis. You must provide to us the personal information as set out in Paragraph 5(b) above if you want to process your use of our App and Service. Personal information provided by you will be used by us for the following purposes and any purposes related to and/or for the furtherance of any of these purposes (collectively “Purposes”):
A.
application, administration, continuation and termination of the use of our App and Service;
B.
enabling the provision of services, functions, and activities within our App, which may include, but are not limited to multimedia content and news, etc. and their continue improvements;
C.
providing you with news, notices and other communications of our App and Service such as features, content, technical notices, updates, security alerts, etc.;
D.
enabling the daily operation of and managing your use of the App;
E.
handling and following up service calls, enquiries and complaints;
F.
verification of your identity;
G.
meeting the requirements to make disclosure to any governmental authority in Hong Kong and overseas jurisdictions under the requirements of any law binding on us;
H.
enabling us to introduce other services to our App to better tailored to your needs;
I.
enabling us to provide you with the most effective service in different locations, devices, connectivity and situations;
J.
enabling us to detect, investigate and/or prevent unauthorized or illegal activities;
K.
helping us to monitor and analyse trends, usage and activities in connection with our App and Service;
L.
enabling us to better understand the demographics of our users;
M.
conducting research and statistical analysis in relation to our App and Service, your behaviour and interest in our App and Service ;
N.
App user profiling;
O.
enabling you to participate in interactive features of our App and Service;
P.
making suggestions and recommendations to you and other users of our Service or goods and services that may interest you or them;
Q.
ad serving and personalized advertising purposes (see below PERSONAL INFORMATION FOR SERVING AND PERSONALIZE ADVERTISING) ; and
R.
any other purposes as may be agreed by you from time to time.
7.
You warrant to: (a) provide us true, accurate, current and complete personal information about yourself; and (b) update the foregoing information from time to time. We may suspend or terminate your user account or refuse your access to our Service or any part thereof without notice if we suspect that you have breached this provision.
8.
If it becomes necessary that we have to take action against you for any reason whatsoever including without limitation recovering from you any money you owe us, copyright enforcement, etc. You expressly agree that the personal information provided by you can be relied upon in identifying and taking legal action against you.

PERSONAL INFORMATION FOR SERVING AND PERSONALIZE ADVERTISING

9.
We may use personal information we collect about you (at Paragraph 5 above) for the following purposes:
A.
Serving Ads: to offer advertising inventory in our App and our Service:
B.
Interest-based Advertising: to infer what you may be interested in and to serve ads to you based on these inferred interests:
C.
Geo-targeting: to serve ads based on your current or prior location;
D.
Reporting; to measure ad performance and to report aggregate statistics to our advertising partners;
E.
Fraud Detection and Prevention: Identifying invalid clicks (or, ad queries) and preventing fraudulent behaviour; and
F.
Providing and operating our Service: Auditing, researching, and analysing data in order to maintain, protect, and improve our Service; and to ensure that our technologies function properly.
10.
We may disclose your personal information to the following parties for the following purposes:
A.
We disclose personal information to our advertising partners so that they can decide whether to bid on ad inventory or serve an advertisement and choose the best ad for you, subject to compliance with applicable laws and regulations
B.
We disclose personal information to governmental authorities or other third parties assisting us detecting, investigating, preventing or otherwise addressing fraud, security, or technical issues; and
C.
We disclose aggregate information to our advertising partners, to help them measure the effectiveness and value of our Service. For example, we provide our advertising partners with reports showing how many users visited or clicked on their ads.
11.
Opt Out: iOS: You may opt out by enabling the “Limit Ad Tracking” setting or “Reset Advertising Identifier” in “Advertising” under “Privacy” setting in operation system. Android: You may opt out by enabling the “Opt out of Ads Personalization” or “Reset advertising ID” in “Ads” under “Google” setting in operation system. If you opt out, we or our advertising partners will honour your preferences by only serving contextual advertisements in response to such ad requests, and prohibit the use of any data contained in this opt out report/request to serve personalized advertising or to create a profile of the user or device.
12.
We do not permit our App or Service to be used to collect information of children under the age of 13 for the purpose of personalized advertising;

DISCLOSURE

13.
While we will take all practicable and reasonable steps to protect personal information from unauthorized or accidental access, disclosure, misuse or processing, or from alteration, destruction or loss, we may transfer/assign such information to the following parties:
A.
any actual or proposed assignee, transferee or successor of or to our rights in respect of your personal information n if we decide to sell any relevant part of business;
B.
any agents, suppliers, contractors, professional advisors, insurers, other network operators or third party service providers who provide administrative, telecommunications, computer and other services to us and/or the relevant service(s) in connection with our Service;
C.
any person to whom we are under an obligation to make disclosure under the requirement of any law binding on us or for the purposes of any guidelines or codes of practice issued by regulatory or other authorities with which we are expected to comply;
D.
governmental authorities or other third parties assisting us detecting, investigating, preventing or otherwise addressing fraud, security, or technical issues; and
E.
Those parties as set out in Paragraph 10 at PERSONAL INFORMATION FOR SERVICING AND PERSONALIZE ADVERTISING.
14.
If we become involved in a merger, acquisition, or any form of sale of some or all of our assets, we will ensure the confidentiality of any of your personal information involved (if any) in such transactions and provide reasonable notice before your personal information are transferred and becomes subject to a different privacy policy. An update to this PICS will be posted on //yr.xjs678.app/pics.php subsequently.
15.
If necessary, we may transfer your personal information to places outside Hong Kong or from the country you are located for carrying out the Purposes (or the directly related purposes) specified above, for which personal information were collected. Where such a transfer is performed, it will be done in compliance with the prevailing requirements of the Personal Data (Privacy) Ordinance, Cap 486 of the laws of Hong Kong.

USE OF YOUR PERSONAL INFORMATION IN DIRECT MARKETING

16.
We intend to use your personal information for direct marketing purposes, and we may not so use your personal information unless we have received your consent (which includes an indication of no objection). Subject to your consent, we may use such personal information collected from your registration and use of our Service for marketing of the following services and products:
A.
A. our products and services and/or the products and services of any company within our group;
B.
B. news, rewards, promotions and events related to or offered by us and/or the our group, such as Big Big Channel Limited, TVB Anywhere Limited, TVBI Company Limited and MyTV Super Limited; and
C.
C. joint promotion, rewards and events with merchants and business partners or other third parties offering discount and other benefits to users of our Service, from and in relation to goods and services of or relating to the following industries: entertainment, media and public relations, telecommunications, retail, leisure and sports, food and beverage, transportation and tourism, software and games, education, environmental, health and wellness, non-profit, information technology, social networking, parenting, financial and property.
17.
If you do not wish us to use your personal information for direct marketing at any time, please email us at newsapps@cs.tvb.com. We shall remove your personal information from our archive within fourteen (14) days after we receive your notification.

COOKIE

18.
We use Cookie, which deposit small data files; and other similar technologies like software development kits (“SDKs”) stored on your Device when you access our App. A Cookie can be used to identify a Device, but it is not used to collect personal information of an individual user of our App and/or Service. The information collected by “Cookie” is anonymous aggregated research data and contain no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. Some of the Cookie are required by our App and/or Service to enable you to transact whilst other cookies enable us to give you an enhanced, personalized browsing experience. For example, we use Cookie to remember your volume settings, search history, account type and the time you checked out. Our advertising partners may use Cookie and similar technologies to identify and deliver contents and advertising specific to your interests, to track the effectiveness of such advertising and to provide and analyse their services. Whilst most web browsers automatically accept Cookie, you can edit your browser options to block them. However, if you do so, you may not be able to use some of the functions or access certain areas of our App and/or Service. By using our App or Service, you consent to our use and our advertising partners’ use of these Cookie and related technologies, and the sharing of data with our advertising partners. You can withdraw your consent to our use or Cookie using your browser settings or your Device’s limit ad tracking settings. For more information about the Cookie we use, please see our Cookie Policy at //yr.xjs678.app/cookies.php.

SECURITY OF PERSONAL INFORMATION

19.
Except as provided in Paragraphs 6, 10 and 13 above, your personal information will be accessed only by our employees or contractors who are authorized to do so. Our employees and contractors designated to handle personal information will be instructed to do so only in accordance with this PICS. We have implemented reasonable security measures to safeguard your personal information from unauthorized access, disclosure, use and modification. Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and no transmission over the Internet can be guaranteed to be completely secure.

RETENTION OF PERSONAL INFORMATION

20.
We will retain your personal information for as long as necessary to fulfil the purposes for which such information was collected. We will then destroy such information unless their retention is required to satisfy legal, regulatory or accounting requirements or to protect our interests.

ACCESS TO AND UPDATE OF PERSONAL INFORMATION

21.
If your personal information has been collected by us, you may at any time:
A.
request access to and correct personal information relating to you in any of our records;
B.
ask us to remove your personal information from any active mailing or distribution list; or
C.
cease to use your personal information and terminate your use of our Service subject to our T&Cs.
22.
To exercise any of your foregoing rights, please email us at newsapps@cs.tvb.com marking your communication “Confidential”. In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the personal information refers. We may charge you a reasonable fee for processing such access requests.

GENERAL

23.
Our App and Service may include links to other services or sites. This PICS applies to our App and Service only. You are exposed to cookie that are not our responsibility when you access to linked sites or other services, and any information you submit to linked sites or other services will be subject to the privacy policies of those sites or services (if any). You are advised to review the relevant policies carefully before providing any information to those linked sites or services.
24.
If you wish to contact us directly, please email us at newsapps@cs.tvb.com. All information, other than the personal information that you send through this email, will not be considered or treated as confidential information. Do not send us through this email any information, ideas, suggestions, proposals or comments that you consider confidential or that you want to be treated as confidential.
25.
Your telephone and messaging conversations with our staff may be recorded, retained and used as evidence by us without further notice.
26.
If any part of this PICS shall be deemed unlawful or for any reason unenforceable, then that provision shall be deemed to be severable from this PICS and shall not affect the validity and enforceability of any of the remaining provision of this PICS.
27.
This PICS shall be governed by and construed in accordance with the laws of Hong Kong. Disputes arising here from shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
28.
If there is any inconsistency or conflict between the English and Chinese version of this PICS, the English version shall prevail.
Version 1.0: 7 April 2020
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