Last update: 2021-08-16
BNESIM Limited understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who visits Our Site and will only collect and use information in ways that are useful to you and in a manner consis-tent with your rights and Our obligations under the law.
In this Policy the following terms shall have the following meanings:
means an account required to access and/or use certain areas and features of Our Site;
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
means this website, https://www.bnesim.com/, the app VirtualSIM by BNESIM for iOS and Android, the app BNE Room for iOS and Android;
means the relevant parts of the Personal Data (Privacy) Ordinance, Laws of Hong Kong (Cap 486) (PDPO) and of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
means BNESIM Limited a limited company registered in Hong Kong under license 2531485, whose registered address is NO. 5, 17/F BONHAM TRADE CENTRE 50 BONHAM STRAND, SHEUNG WAN HONG KONG .
1 - Our Site, https://www.bnesim.com/, is owned operated by BNESIM Limited, a limited company registered in Hong Kong under license 2531485, whose registered address is NO. 5, 17/F BONHAM TRADE CENTRE 50 BONHAM STRAND, SHEUNG WAN HONG KONG 2 - Our data protection officer is Christian Brilli who can be contacted at [email protected] 3 - We are regulated by the GDPR.
Some data will be collected automatically by Our Site, other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up for an Account. Depending upon your use of Our Site, We may collect some or all of the following data: 1 - Name; 2 - Date of birth; 3 - Gender; 4 - Business/company name; 5 - Job title; 6 - Profession; 7 - Contact information such as email addresses and telephone numbers; 8 - Demographic information such as post code, preferences and interests; 9 - Financial information such as credit / debit card numbers; 10 - IP address (automatically collected); 11 - Web browser type and version (automatically collected); 12 - Operating system (automatically collected); 13 - A list of URLs starting with a referring site, your activity on Our Site, and the site you exit to (automatically collected);
1. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below. 2. We use your data to provide the best possible products and services to you. This includes: 1 - Providing and managing your Account; Providing and managing your access to Our Site; 2 - Personalising and tailoring your experience on Our Site; 3 - Supplying Our products and services to you; 4 - Personalising and tailoring Our products and services for you; 5 - Responding to communications from you; 6 - Supplying you with email contents e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by clicking an unsubscription link in the newsletter or contacting [email protected]; 7 - Market research; 8 - Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience; 3. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the products and services We can provide you without your consent for Us to be able to use such data. 4. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email]AND/OR telephone AND/OR text message AND/OR post with information, news and offers on Our products AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015. 5. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies: you have given consent to the processing of your personal data for one or more specific purposes; - processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract; - processing is necessary for compliance with a legal obligation to which we are subject; - processing is necessary to protect the vital interests of you or of another natural person; - processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or - processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
1. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct a periodic review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are: 2. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU- approved Model Contractual Arrangements. 3. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site. 4. Steps We take to secure and protect your data include: - Using appropriate technical and organisational steps, and will store it on our database within a secure network. 5. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
1. We may share your data with other companies in Our group. 2. We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. 3. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law. 4. In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
1. When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details AND/OR by managing your Account). 2. You may also wish to sign up to one or more of the preference services operating in the Hong Kong: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at priva[email protected], or using the contact details below in section 14.
15.1 What personal information does BNE Room process? To provide the BNE Room service, BNESIM Limited processes network and usage information including IP addresses for the meeting participants, the user specified URL used to host the meeting, and information about the phone numbers that connect to the meeting (if audio connection is made via a telephone call). In some cases, meeting related content, which may contain personal information, is temporarily stored to enable user functionality in a BNE Room video meeting. Examples include: - If you use the chat function, chat content is stored during the meeting. - If you record a meeting, the recording of the meeting is temporarily stored until it is uploaded to your file hosting service (e.g. DropBox). - If you livestream your meeting, video content is temporarily stored to buffer the live stream. - In addition, users of BNE Room have the option of providing name, email address, and link to a picture that will be displayed to participants in the meeting. 15.2 How is this information used? BNESIM Limited is not in the business of selling personal information to third parties. BNESIM Limited uses this information to deliver theBNE Room service, to identify and troubleshoot problems with the BNE Room service, and to improve the BNE Room service. In addition, BNESIM Limited may use this information to investigate fraud or abuse.
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