Last Updated: 1 Jan 2018
TrainTrain is an online training service provided by Train Train Limited ( “TrainTrainHK”, “we” or “us”), a company registered in Hong Kong with the office at Room 2001, 20/F, Mongkok Commercial Centre, 16 Argyle Street, Mongkok, Kowloon, Hong Kong.
This Privacy & Cookies Notice (“Notice”) aims to give you information on how we collect, use, disclose or process personal data about you through your use of our website www.traintrain.com.hk (“Website”), mobile application (“Mobile App”), including any data you may provide to us in paper form, online, by telephone, email or any other means when you use or purchase our product(s) or service(s), register or log in as a member, visit our Website, download/enable our Mobile App or take part in any of our contest or survey (together, the “Services”) in accordance with the requirements in the Hong Kong Personal Data (Privacy) Ordinance (“PCPD”) and where applicable, the Hong Kong Personal Data Protection Act 2012 (“PDPA”). “Personal Data” means data, whether true or not, about you where you can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access. This Notice was last updated and became effective on the above date.
It is important that you read this Notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information about you so that you are fully aware of how and why we are using such information. This Notice supplements other notices and is not intended to override them.
By browsing our Website, interacting with us, submitting information to us, purchasing or using any of the Services offered by us, you signify that you have read and understood this Notice and consent to our collecting, using, disclosing and sharing your data in the manner set forth in this Notice.
OVERVIEW
What type of personal data do we collect from you?
We may collect from you your identity information, contact information, financial information, transaction information, technical information, profile information, usage information, and marketing and communications information. We may also collect from you statistical information. We do not collect any special categories of personal data (such as race or ethnicity, religion, etc.). We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or your authorized representative or (b) collection and use of personal data without consent is permitted or required by the PCPD or where applicable, the PDPA or other applicable laws.
How do we collect personal data from you?
We collect information when you fill in forms on our Website, purchase or use our products and services, Mobile App, such as your identity information, contact information, and financial information. We collect information about your preferences from your interactions with us, and from specific requests you make. We also collect device and technical information from you when you use our Website and Mobile App.
How do we use your personal data?
We use your personal data to fulfill our contract with you, manage your relationship with us and/or to administer your Train Train Limited membership. We also use your information to maintain our Website and Mobile App and to customize our products and services to your preferences to provide the best service possible. In addition, we use your information to market our products and services to you.
Who do we share your personal data with?
We share your information with our third party service providers to the extent necessary for them to provide administrative, telecommunications, IT system, and computer services, local distribution services, corporate support services, and other services to us and/or the relevant service(s) in connection with our Services. We use these third parties services solely to process or store your information for the purposes described in this Notice. We also share your information with our related group companies and business partners who help us provide or deliver our products and services, and with government bodies as required by law.
Where do we process your personal data?
We are a company based in Hong Kong. Personal data collected will be stored and backed up in Hong Kong or outside of Hong Kong. Most of our third party service providers are based outside of Hong Kong, so the processing of your personal data will involve a transfer of your information outside of Hong Kong. All our third party service providers to whom your personal data will be transferred will contractually be required to comply with the obligations set forth in this Notice.
How long do we retain your personal data?
We retain your information for as long as it is necessary as the law permits to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
How can you exercise your rights over your personal data?
You have the right to know whether we possess information about you and if we do, you have the right to (a) access such information; (b) request for information about the ways we use or disclose such information, and (c) correct any such information. You may also at any time (i) ask us to remove your information from any active mailing or distribution list, or (ii) withdraw your consent and request us to stop using and/or disclosing your information for any purposes listed in this Notice. To exercise any of your foregoing rights, please contact us marking your communication “Confidential – Privacy & Cookies Notice” and specifying our Services that you have registered. 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 information refers. Where permitted by law, we reserve the right to charge you a reasonable administrative fee for processing the access requests.
Use of Cookies & Similar Technologies
We use cookies and/or similar technologies to provide you with convenience and a more personalized experience on our Website and Services. By continue using our Website or any of our Services, you agree to our use of cookies and/or similar technologies as set forth in this Notice
Dispute Resolution
If you have any concerns or complaints, please contact us.
How will we notify you of changes to this Notice?
We may revise this Notice from time to time and the updated versions will be posted on our Website and date stamped so that you are aware of when this Notice was last updated. Please check back frequently to see any updates or changes to this Notice. If we make any material changes to this Notice, we will provide notice including banners on our Website, Mobile/TV Apps or TV Box.
Contact Us
You may contact our Data Protection Officer Team if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Data Protection Officer Team
Train Train Limited
What type of personal data do we collect from you?
- Depending on the nature of your interaction with us, we may collect, use, disclose, transfer and store different kinds of personal data (information) about you. We have grouped them together in the following categories:
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- By registering or logging in to our Website or Services using your TrainTrain Account, we will collect, use and retain any information needed for the registration or log-in that you have permitted TrainTrain Account to share with us, such as your salutation, first name, last name (surname), username or similar identifier, email address, and phone number. Please review the privacy notice of TrainTrain Account.
- We also collect, use and share Statistical Information such as analytical or demographic data for any purpose. Statistical Information may be derived from the personal information about you but is not considered personal data in law as this information does not directly or indirectly reveal your identity. For example, we may make use of your usage information to calculate the percentage of users accessing a specific service or website feature. However, if we combine or connect statistical data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Notice.
- We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”), or (b) collection and use of personal data without consent is permitted or required by the PCPD or where applicable, the PDPA or other laws.
- Where we need to collect personal data by law, or under the terms of a contract we have with you and you decline to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In such event, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
- The accuracy of Personal Data. We will take reasonable efforts to ensure that your personal data is accurate and complete, including contacting you or requesting updates from you from time to time. However, we generally rely on personal data provided by you (or your authorized representative). By submitting your personal information to us, you warrant to (a) provide us true, accurate, current and complete personal data about yourself; and (b) update the foregoing information from time to time. Failure on your part to do so may result in our inability to provide you with the products and services you have requested. We may suspend or terminate your membership account or refuse your access to our Services or any part thereof without notice if we suspect that you have breached this provision.
- In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by logging in to the “My Account” page in the Mobile App or contacting us.
- 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, you expressly agree that the personal information provided by you can be relied upon in identifying and taking legal action against you.
How do we collect personal data from you?
- We use different methods to collect data from and about you including through:
- Direct interactions (information you give us). You may give us your Identity, Contact and Financial Information by filling in forms on our Website, downloading/enabling our Mobile App by corresponding with us by post, phone, email, and other electronic means or otherwise. This includes personal data you provide when you:
- apply for our product(s) or services;
- subscribe to our services or publication;
- request marketing to be sent to you;
- enter a contest, promotion or survey;
- contact us with a question or request for assistance;
- interact with us through telephone, email or any other means; and
- give us feedback.
- Automated technologies or interactions. As you browse or interact with our Website, buy or use any of our product(s) or services (such as using our Mobile App, or when you create or log into your account with us), we may automatically collect Technical Information about your device, browsing actions and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Information about you if you visit other websites employing our cookies. Cookies allow us to analyze web traffic and evaluate how you move around for analytics purposes to understand how you and other users use it so that we can make it more intuitive. Please see Use of Cookies & Similar Technologies section of this Notice for further details.
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public services as set out below:
- Technical Information from the following parties:
- analytics providers such as Google Inc.;
- advertising networks; and
- search information providers.
- Identity, Contact, Financial and Transaction Information from affiliated entities, business partners, service providers, social media or other customers or your representatives with appropriate consent from you.
- Identity and Contact Information from publicly available sources such as the registries of companies.
- Telephone calls. We will inform you if we monitor or record any telephone conversations between you and us for security reason, for record keeping of the transaction and/or for staff training purposes.
- If you provide us with any personal information about other individual(s), you warrant, represent and undertake to us that (a) such individual(s) is informed of and agrees to the provisions of this Notice and has authorized the disclosure; (b) you have obtained clear and unambiguous consent of such individual(s) before using, disclosing and sharing their personal information to us for the relevant purposes; and (c) such individual(s) is informed that we may contact them for further information. We may require you to provide us with written evidence of such consent.
How do we use your personal data?
- We will only use your personal data when the law allows us to. We will collect, use and retain your personal data for the following purposes and any purposes related to and/or for the furtherance of any of these purposes (together, the “Purposes”):
- facilitating the application, administration, continuation, and termination of the use of the Services, including but not limited to membership account maintenance and closure, processing renewal of subscription contracts and customer relationship management);
- enabling the provision of the Services, including but not limited to providing you with customized services and marketing and to ensure the proper functioning of our products and services;
- enabling us to perform the contract we are about to enter into or have entered into with you;
- sending you subscription renewal notices and reminders;
- processing and completing transactions requested by you;
- providing you with news, notices and other communications of our Services, such as features, content, technical notices, updates, security alerts, etc.;
- promoting and marketing products and services offered by us to you;
- processing billing and payment, determining amounts outstanding, and, if necessary, conducting credit checks and collection of outstanding payments;
- enabling the daily operation of and managing your membership accounts in relation to our Services, including but not limited to technical support, network maintenance, and troubleshooting;
- handling and following up requests, service calls, inquiries, and complaints;
- verifying your identity and your eligibility to our offers, contests and/or promotions or other events;
- complying any applicable legal, governmental or regulatory requirements including any disclosure or notification requirements, to which we are subject to;
- enabling us to provide other services better tailored to your needs, including customizing the ads shown to you and notifying you about special offers and products or services available from us or our partners that may be of interest to you in accordance with your marketing preferences;
- enabling us to provide you with the most effective service in different locations, devices, connectivity, and situations;
- monitoring and analyze trends, usage, and activities in connection with our Services so as to help us improve, review, develop and efficiently manage the Services offered to you;
- enabling us to detect, investigate and/or prevent unauthorized or illegal activities;
- conducting research in relation to the products and services provided by us;
- enabling us to better understand the demographics of our users;
- performing statistical analysis of your behavior and interest in any services provided by us;
- customer profiling and analyzing your purchasing preferences;
- enabling you to participate in interactive features of our services, including identifying your friends or individuals, and sharing and communicating with them your shopping experience, when you choose to do so;
- enabling you to take part in a contest, prize draw or complete a survey;
- making suggestions and recommendations to you and other users of our Services or goods and services that may interest you or them;
- processing referral payments and/or commission fees to our external partners; and
- any other purposes as may be agreed upon by you from time to time.
- The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
- We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).
- We strive to provide you with choices regarding certain personal data uses particularly in marketing and advertising. With your consent where required by applicable laws, we may use your Identity, Contact, Technical, Usage, and Profile Information to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services, and offers may be relevant for you (“marketing”). You will receive marketing communications from us across various platforms such as email, telephone, text messaging and online if you have requested information from us or purchased goods and services from us or if you provided us with your information when you entered into a contest or registered for a promotion and, in each case, you have not opted out of receiving marketing. Where required by law, we will ask you to explicitly opt-in to receive marketing from us.
- You have the right to withdraw your consent at any time by logging in to “My Account” to update your preferences, or by following the opt-out instructions on any marketing messages sent to you, or by contacting us.
Who do we share your personal data with?
- While we will take all practicable and reasonable steps to protect personal data from unauthorized or accidental access, disclosure, misuse or processing, or from alteration, destruction or loss, we may transfer/assign such data to the following parties:
- any agents, suppliers, contractors, professional advisors, insurers, other network operators or third party service providers who provide administrative, telecommunications, IT system and computer services, local distribution services, corporate support services and other services to us and/or the relevant service(s) in connection with our Services;
- 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;
- any third parties to whom we may choose to sell, transfer, outsource or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice;
- governmental authorities or other third parties assisting us in detecting, investigating, preventing or otherwise addressing fraud, security, or technical issues.
- We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
Where do we process your personal data?
- TrainTrainHK is a company incorporated in Hong Kong. Personal data collected will be stored and backed up in Hong Kong or outside of Hong Kong. Many of our third party service providers are based outside of Hong Kong, so the processing of your personal data will involve a transfer of your personal data outside of Hong Kong.
- Where a transfer of personal data is performed, we will take appropriate steps to ascertain that the foreign recipient of the personal data is bound by legally enforceable obligations to provide to the personal data transferred a standard of protection that is comparable to that under the PDPA.
How do we protect your personal data?
- To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
How long do we retain your personal data?
- We may retain your personal data for as long as it is necessary to fulfill the purposes for which it was collected, or as required or permitted by applicable laws, including for the purposes of satisfying any legal, business, accounting, or reporting requirements.
- We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
How can you exercise your rights over your personal data?
- You have the right to know whether we possess information about you and if we do, you have the right at any time to:
- request access to and correct such information in any of our records;
- request for information about the ways we use or disclose such information;
- object to our use of information about you in order to send you promotions, special offers, marketing messages; and
- withdraw your consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above (whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request).
- To exercise any of your foregoing rights, or if you have any comments, questions or complaints about our privacy practices, please contact us marking your communication “Confidential – Privacy & Cookies Notice” and specifying our Services that you have registered.
- Upon receipt of your written request, we may (a) require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed, (b) ask you to provide certain details about yourself so that we can be sure you are the person to whom the information refers, and (c) notify you of the consequences which may affect your rights and liabilities to us.
- Where permitted by law, we reserve the right to charge you a reasonable administrative fee for processing the access requests and we will, in such circumstances, inform you of the fee before processing your request.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclosure personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.
How will we notify you of changes to this Notice?
- This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.
- We regularly revise this Notice from time to time without any prior notice and updated versions will be posted on our Website. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
Use of Cookies & Similar Technologies
- We use cookies and other similar technologies (together, “Cookies”) on our Website, Services, and Mobile App for storing information to help provide you with a better, faster, and safer experience and for advertising purposes.
- Cookies are text files that are placed in your browser or device when you visit or use our Website, Services, and Mobile App.
- We use Cookies for the following purposes:
- enabling certain features and functions, e.g. remembering your user-id, selections, online purchase, browsing, and other service preferences;
- building up a profile of how you and other users use our Website, Services, and Mobile App;
- improving the efficiency of our Website, Services, and Mobile App;
- administering services to you and to advertisers, including but not limited to serving you relevant and targeted advertisements; and
- establishing usage statistics.
- We use three broad categories of Cookies:
- Strictly Essential Cookies
These are necessary for our Website and Mobile App to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as logging in, e-billing or filling in forms.
- Functionality Cookies
These are used to recognize you when you return to our Website and Mobile App. These enable us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language). You can set your browser to block or alert you about these cookies, but some parts of our Website and Mobile App may not work properly as a result.
- Analytical/Performance Cookies
These allow us to count visits and traffic sources, so we can measure and improve the performance of our Website and Mobile App. They help us know which pages are the most and least popular and see how visitors move around the Services. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Website and Mobile App.
- Targeting Cookies
These are set through our Website and Mobile App by our advertising partners, such as advertising networks and exchanges. These cookies collect information about your visit to our Website and Mobile App and elsewhere on the Internet. They may also collect your device identifier, IP address, or identifier for advertising (IDFA). These cookies may be used to build a profile of your interests and show you relevant advertisements on our Website and Mobile App or elsewhere on the Internet. This is often called online behavioral advertising (OBA). We may also use cookies on third party websites, mobile sites and apps to show you OBA ads based on data collected by those cookies. If you do not allow these cookies, you will not experience targeted advertising and promotion from these advertising partners, but advertisements that are not specific or personalized to you or your device may still be served to you.
- Third party cookies are covered by the third-parties’ privacy policies. We do not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact us and we will try our best to assist by providing you information about these third-party advertising agencies. We are not responsible for the personal data policies (including personal data protection and cookies), content or security of any third party websites linked to our Website.
Contact Us
- You may contact our Data Protection Officer Team if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Data Protection Officer Team
Train Train Limited
- We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable laws).
- For general inquiries or feedback on our Services, please contact our Customer Service at This email address is being protected from spambots. You need JavaScript enabled to view it..
General
- This Notice is written in English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this Notice, the English version shall prevail.