“LuckySIM” is owned and operated by Lucky Sim Limited. Lucky Sim Limited (“Lucky Sim”, “we”, “us”, “our”) is committed to protecting your privacy. We will only use the information that we collect about you lawfully.
Our Policy explains what information we collect on the Website and/or Mobile Apps, how we use and/or share this information, and how such information is maintained. By using the Website and/or Mobile Apps, you signify your acceptance of this Policy. If you do not agree to the terms of this Policy, in whole or part, you should not use the Website and/or Mobile Apps. Please note that this Policy applies only with respect to the information collected on the Website and/or Mobile Apps and not any information collected or obtained through other methods or sources.
Our Policy ensures that any information you provide us remains private and secure. To reassure you, below we provide details of the information you provide to us, and how it will and, more importantly, will not be used. We will never collect sensitive information about you without your explicit consent. The information we hold will be accurate and up to date. You can check the information that we hold about you by contacting us (and there may be an administrative fee payable for this). If you find any inaccuracies we will delete or correct it promptly.
2. Collection of Personally Identifiable Information
We collect personally identifiable information (“PII”) that is volunteered during registration or in response to specific information requests explicitly presented to you.
We may also collect your IP (Internet Protocol) address to help diagnose problems with our server, and to administer the Website and/or Mobile Apps. An IP address is a number that is assigned to your computer and/or mobile phone when you use the Internet. Your IP address is also used to help identify you during a particular session and to gather broad demographic data.
We may ask for your name, postal address, email address, date of birth, telephone number and details of a payment mechanism, such as credit card details during your use of the Website and/or Mobile Apps.
3. Use and Sharing of PII
All PII is retained in accordance with the Data Protection Principles and other applicable data protection laws in Hong Kong. We use PII to provide you with information about LuckySIM, to properly provide you with the service and for marketing ourselves to you. It is our policy not to sell or pass any PII to any other organizations (not in our group companies) unless we are required to do so for fraud prevention and detection. We will never sell or rent your PII to anyone else for their marketing purposes without your consent.
However, we may pass your PII to our agents and subcontractors to help us with any of our uses of your data set out in this Policy. For example, we may use third parties to provide us with marketing or customer service assistance or send it to a credit card provider to process a payment. Our third party online payment system collects and records your first payment information as convenience, which will be transmitted by SSL directly to the bank for processing payment for your transaction and future transactions. Please note that LuckySIM does not store any of this data and does not have any access to this data. If you wish us to inform our online payment system not to keep your credit card data on file, please do send email to cs@LuckySIM.com.hk or call us at (+852) 3188 2226. We will inform our credit card provider to delete the data.
We also always reserve the right to disclose PII in order to:
(a) comply with applicable laws;
(b) respond to governmental enquiries (or enquiries from a legal, governmental or quasi-governmental or local authority agency or Internet protection agency of any type);
(c) comply with a valid legal process or procedure; or
(d) protect our rights or property, the Website and/or Mobile Apps, and/or other users of the Website and/or Mobile Apps.
By submitting PII to us, you acknowledge that provided we have used your data in the ways set out in this Policy, we cannot be held responsible for any use of your data by third parties who receive and process your data.
Please note that we may email you for the following purposesas part of the service. For example, we send (or may send) emails to you in some of the following example circumstances:
- after registration, notifying you of your account details;
- as reminder emails about the services we offer (particularly if you have not used them yet or not used them for a while);
- to send you information or vouchers which you have asked for;
- as a newsletter;
- as promotional emails; and
- to offer related services to you from Lucky Sim Limited.
However, in terms of any marketing or promotional emails we may send, we will always give you the chance to opt-out (or unsubscribe) from them in the future.
6. Security and Retention
The PII which we hold will be held securely within our systems in accordance with our internal security policy and the law. Regarding information transmitted between the Website and/or Mobile Apps and and/or users, while we take reasonable precautions to safeguard this information, we may be unable to prevent unauthorized access to such information by third parties or inadvertent disclosure of such information during transit. Users acknowledge this risk when communicating with the Website and/or Mobile Apps.
7. Transfer in Certain Circumstances
If there is a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization or liquidation of Lucky Sim Limited, in our sole discretion, we may transfer, sell or assign information collected on and through the Website and/or Mobile Apps (including, without limitation, PII and other information), to one or more relevant third parties.
8. Customer Service
If you have any questions or concerns, please feel free to send emails to cs@LuckySIM.com.hk
9. Changes to Policy
Please note that this Policy forms part of the Terms & Conditions of the Website and/or Mobile Apps and forms part of the agreement between you and us. We may, from time to time, amend this Policy, in whole or part, in our sole discretion. Any changes to this Policy will be effective immediately upon the posting of the revised policy on the Website and/or Mobile Apps. Depending on the nature of the change, we may announce the change: (a) on the home page of the Website and/or Mobile Apps, or (b) by email, if we have your email address. However, in any event, by continuing to use the Website and/or Mobile Apps following any changes, you will be deemed to have agreed to such changes. If you do not agree with the terms of this Policy, as it may be amended from time to time, in whole or part, you must terminate your use of the Website and/or Mobile App.