28th February 2021

ManagedCONNECT Privacy Policy

Introduction

CITIC Telecom CPC (as defined in "About Us" below) is well aware of the importance of personal information to you. We will strictly follow the requirement of laws and regulations and will do our best to protect your personal information in a safe and controllable manner. Since then, we have prepared the "Privacy Policy" (hereinafter referred to as "this policy") to help you fully understand that during your use of our ManagedCONNECT Website or Mobile App services:

- what information will be collected by us;

- how we will collect, use, store, share and protect your personal information;

- what rights you have on your personal information,

so as to enable you to make more appropriate choices.

Please carefully read and understand this policy before using this Website or Mobile App services, especially the content marked in bold, to ensure that you fully understand and agree before you start.

About Us

CITIC Telecom International CPC Limited and its subsidiaries (abbreviated as “CITIC Telecom CPC” or “WE” or “US”) is an international telecommunications provider with its headquarter in Hong Kong, China. We are the preferred partner of multinational corporations (MNCs) and business enterprises for the provision of state-of-the-art information and communications technology solutions. CITIC Telecom CPC is one of the first service providers to offer private network services in Greater China and Asia Pacific, and serves a wide range of industry customers via multiple branch offices worldwide.

What personal data do we collect?

When you visit ManagedCONNECT website and/or mobile app services (hereinafter referred to as the “service”), based on the requirements for the provision of the service, we need to collect some of your personal information, so that smooth, timely and accurate service can be provided to you and at the same time protected your account safety, details of which are as follows:

1. Account login

In order for you to login to ManagedCONNECT Web or Mobile App services securely, you will need to provide your login name (or email address) and password as your identity verification. For your account safety, please keep your account and password safely and avoid password leak, being stolen and misuse. It is recommended that you should change your password regularly.

2. Personal Data Settings

After successfully login to ManagedCONNECT Web or Mobile App services, you are deemed to have given your consent to our collection of device information (e.g. IP address, MAC address/UUID of your device) for providing services. Also, you can choose to set up and fill in your nickname, email address, and mobile phone number. By your filling in the above information, you are deemed to have given your consent to our collection for providing services for related use.

If you need to use the two-factors authentication (2FA) function for the purpose of account login authentication, you need to provide your email address or mobile phone number for receiving security verification information.

You may require us to send you emails or push notifications about your account, requested services, applications (websites or mobile applications), and as such you will need to provide your email address, mobile phone number or MAC address/UUID of your device.

3. Customer Service

In order to contact you or provide feedback to your submitted questions or comments about the use of products or services, we will need to collect the following personal information:

1) Your first and last name;

2) Your company name;

3) Your company address, billing or shipping physical address;

4) Your e-mail address;

5) Your telephone number or mobile phone number;

6) Any other identifier that permits us to make face-to face or online contact with you;

7) Any information that we collect online from you and maintain in association with your account, such as your username and your password;

8) Any other information that you provide to us when you are communicating with us, for example, your job title, or the reply time at your convenience.

4. Others

If you browse or use our ManagedCONNECT Web or Mobile App services, we will also collect and store information on the use of our services via cookies. Please refer to Cookie Policy for more information.

For what purpose do we collect or use your personal data?

1. To achieve the purpose stated in the section “What personal data do we collect” in this policy.

2. To establish and perform a contract with you, for example when you subscribed the product or services from us:

- The use of personal information may include verifying your identity, communicating with you, providing customer services and arranging the delivery or other provision of products or services.

3. To enable our business operation and pursue our legitimate interests. In particular:

1) To provide services you have requested, and respond to any comments or complaints you may send us;

2) To monitor use of our products and services, improve and protect our products, content, services, Web sites or Mobile App;

3) To provide the customized products or services for you;

4) To ensure network and information security, including preventing unauthorized access to electronic communications system and to stop damage to computer and electronic communication systems timely;

5) May monitor in accordance with applicable law any customer account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime.

4. For compliance with applicable laws and protection of our legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory, investigative purposes (including disclosure of such information in connection with legal process or litigation).

Exceptions to Informed Consent

Please note that in accordance with relevant laws and regulations, we do not need your authorization to use your personal information (as described in the section “What personal data do we collect”) in the following situations:

1. Directly related to national security and national defense security;

2. Directly related to public safety, public health, and major public interests;

3. Directly related to criminal investigation, prosecution, trial and execution of judgements;

4. Protecting your or other individuals’ life, property and other major legal rights, in situations that it is difficult to obtain the consent of the person;

5. Collecting personal information that is voluntarily disclosed to the public by yourself;

6. Collecting personal information from legally publicly disclosed information, such as legal news report , government press release and other channels;

7. Collecting personal information that is required for providing you with products or services in accordance with your requirements;

8. Where it is required to maintain the safe and stable operation of our products or services, such as the discovery or handling of product or service failure;

9. Other circumstances stated by laws and regulations.

Who will we share this data with?

We will not share your personal information with non-service related companies, organizations, or individuals, except for the following cases:

1. When we provide your requested services, implement your orders or follow up with your enquires, we may, in accordance with the actual operational needs, share with (whether in China or overseas) our branches, affiliated companies or third-party service provides your necessary personal information for the purpose of providing services, such as your name, email address and phone number or mobile phone number. We will inform the hosting service providers or technical service providers so that they can cooperate with us to complete the provision of your requested service. When sharing your data with all parties, we will ensure that appropriate protective measures are taken and require third parties to protect your information to the same degree as we do;

2. In order to establish, exercise, defend or protect legal claims, and to protect our legitimate interest, share the data with our affiliate companies, our customer or any third party (including to legal advisors, government and law enforcement authorities and with other parties involved in, or contemplating, legal proceedings);

3. Upon the request of competent regulatory, prosecuting, tax or governmental authorities, courts or other tribunals in any jurisdiction or markets (whether domestic or foreign), or in accordance with or as desirable in respect of any applicable Law, share the data with the regulatory authority or courts;

4. To prospective sellers or buyers as part of a sale or merger of our or any affiliates’ business or assets (subject to local laws) Under this circumstances, we will request the recipient of the data to continue to protect your personal data;

5. With your consent or if allowed by other laws and regulations.

Where will we send your data?

We may transfer your personal information to our CITIC Telecom CPC affiliates or third parties (e.g., service providers) overseas, which may involve the transfer of personal information (includes your name, phone or mobile number, email address, MAC address/UUID) to overseas (includes countries outside the European Economic Area). And the data protection standards of these countries may be different from the data protection standards of your region (e.g. the data protection standards of European Economic Area). For a list of the countries in which we operate, please see here. We will strictly comply with the laws/regulations and guarantee your personal information safety.

Where we store your data?

The personal information we collect when you are using services in our ManagedCONNECT website or Mobile App is stored in the territory of the People’s Republic of China (including the Hong Kong Special Administrative Region). If some products or services are cross-border related, we may need to transfer your personal information (your name, phone or mobile number, email address, MAC address/UUID) overseas. We will strictly comply with the laws/regulations and guarantee your personal information safety.

How long do we store your data?

If you are our customer, we will keep your personal information for the duration of the contractual relationship you have with us, and, to the extent permitted by the applicable laws, for as long as necessary to perform the purposes set out in this notice after the end of the contractual relationship, and the duration of such storage period will depend on statutory and contractual requirements, the nature of our relationship with you, the nature of the data concerned and technical necessities. Unless the law require us to hold certain information for specific periods, other than that, your personal information will be deleted 7 years after the contractual relationship ends, and we will review and delete data every 6 months.

If personal data is collected with your consent and authorization, until you cancel the authorization, we will continue to process the data so as to allow us to implement your requests. We also keep a record of your request that we shall not process your data so that we can respect your request in future.

How do we protect your data?

We strive to maintain a high standard of security and have put in place robust technical and organizational measures for the protection of your data, especially for the security of digitally stored data, such as a strict policy on personal identification, access control, instructions on how to ensure security of personal data, a safety back-up procedure and secured connections. We will apply reasonably applicable data security procedures to prevent unauthorized access, disclosure or sharing of your data.

Access to your personal data is restricted to individuals who need such access in order to assist with our provision of services. We have strict confidentiality obligations that apply to these individuals. Failure to meet these obligations may result in disciplinary and other actions, including rescission of a contract, termination of employment and criminal prosecution.

What rights do you have in relation to your data?

You have the right to make request to us via the methods listed in section “Contact Us” for:

1. allowing you to access to and make a copy of your personal data in our possession;

2. supplying you with a copy of the personal information provided by you to us or requesting us to send a commonly used, machine readable format copy to a third-party ;

3. Enquiring, supplementing or updating your personal data in order to make it accurate;

4. Deleting your personal information from our records after the end of your service contract, except for those data which we must retain for the period of time as required by laws and regulations;

5. Restricting the process of your personal data, provided that this will not affect your usage of the subscribed service,

6. To void your account;

7. And you may also: making objection to our processing of your personal data in certain circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing);

8. Withdrawing your consent at any time. However, this will not affect our use of your personal data prior to the withdrawal of your consent.

These rights may be limited under certain circumstances – for example, where we can demonstrate that we have a legal requirement to process your data. In such circumstances, it may mean that we are able to retain data even if you withdraw your consent.

Links on our Website

Our Website or Mobile App may contain links to other websites. This policy does not apply to external links or external websites, and these external ljnks or external websites may contain their own applicable privacy policies or rule in use of personal information and we shall not be responsible for the privacy protection of these external links or external websites. We encourage you to review the privacy policy of any company or website before submitting any Personal Data.

Cookie

To ensure proper functioning of ManagedCONNECT Website and Mobile App Services, we will store cookies on your computer or mobile device, or other browsers (or associated applications) that usually include identifiers, site names, and some numbers (collectively referred to as "Cookies"). With the help of cookies, the ManagedCONNECT service website or mobile application can record your session data.

You may choose to accept or reject our cookies in your browser or associated applications. For more information about our use of cookies, please view our Cookie Policy. If you block these cookies on our website or mobile app, under certain circumstances it may affect your browsing of our website, and you may need to change your browser settings every time you visit our website.

Changes

We will regularly review this policy to ensure that it is clearly visible on our website and/or mobile app. We may update or amend this privacy statement from time to time. If we have updated or amended this policy, we will inform you by posting a notification on the website and/or mobile app or notify you by way of pop-up windows or push notifications, along with an updated version of the privacy policy for your perusal.

Contact Us

If you are European resident or have any questions regarding the processing of your data for European region, please feel free to contact our Data Protection Officer and we will reply you within 10 working days. We have appointed Bird & Bird DPO Services SRL as a Data Protection Officer and may be reached by using the following contact details:

- mailing address: Bird & Bird DPO Services SRL, Avenue Louise 235 b 1, 1050 Brussels, Belgium;

- phone number: +44 (0)20 7415 6000;

- email address: help@citictel-cpc.com or DPO.CITICTelecom@twobirds.com;

- key contact: Vincent Rezzouk-Hammachi.

For any other region related questions regarding the processing of your data, you may contact us by email help@citictel-cpc.com and we will reply you within 10 working days.