Disclosure and Sharing of Personal Data


  1. All personal data held by / ConnectAPAC will be kept confidential but ConnectAPAC may disclose information about you to the following parties to use, disclose, process or retain your personal data for the purposes mentioned above and any other purposes indicated in this paragraph below:

(i) companies in the ConnectAPAC Group;

(ii) contractors, agents, third party companies or suppliers who are involved in delivering the products and services you have ordered or used;

(iii) any banking or financial institutions, charge or credit card issuing companies;

(iv) credit information or reference bureaux;

(v) professional advisers such as lawyers

(vi) any agent, contractor or third party service provider who provides administrative, operator, computer, payment, data analytics or other services to ConnectAPAC in connection with the operation of its business;

(vii) any person to whom ConnectAPAC is under an obligation to make disclosure under the requirements of any law binding on ConnectAPAC or under and for the purposes of any guidelines issued by regulatory or other authorities with which ConnectAPAC is expected to comply;

(viii) third party reward, loyalty and value added service providers

  1. Collection of Customer’s Personal Information
  2. a) For the purpose of carrying on ConnectAPAC’s business including sale, provision, registration and advertisements of ConnectAPAC’s and related products and services, ConnectAPAC will collect your personal information when you:

(i) purchase a product from ConnectAPAC through the store or online

(ii) subscribe or register a service of ConnectAPAC

(iii) update your personal information in relation to your registration or subscription to ConnectAPAC’s services

(iv) enquire information about a product or service from ConnectAPAC

(v) contact ConnectAPAC with an enquiry or complaint

(vii) enter any promotions, competitions, prize draws through ConnectAPAC’s services

(viii) use ConnectAPAC’s products or services; or

(xi) take part in market research;

(x) visit or browse ConnectAPAC’s websites.


4. ConnectAPAC may promote or refer to online stores or websites operated by its business partners or other third parties on ConnectAPAC’s website. If you want to use or order any services or products from them and click on their links, any information that you provided which is transferred to them will be beyond ConnectAPAC’s control. ConnectAPAC takes no responsibility over such links. You are advised to study their privacy policies.


5. Direct Marketing

ConnectAPAC intends to use your personal data such as your contact details, including name, telephone number, email address, delivery address and other information such as information about the products or services you have viewed online or purchased and your location data so that ConnectAPAC and/or its business partners can send you information, materials, products, offers and news about the following products and services :

(i) all products or services by ConnectAPAC including its online platforms, mobile applications, mobile voice and data communications, IDD/roaming, entertainment and information services, Internet connectivity and data communications on the Internet;

(ii) reward, loyalty or privileges programmes and related products and services; and (iii) products and services offered by ConnectAPAC’s business partners including travel, dining, entertainment, apparel, health & beauty, education, household, transportation, banking, insurance and other consumer products and services. SmarTone will seek your consent or indication of no objection before ConnectAPAC uses your personal data in direct marketing.

(iii) You may opt out (free of charge) from receiving direct marketing communications at any time in writing by post to the address


6. Data Transfer

(i) At times it may be necessary and/or prudent for ConnectAPAC to transfer certain personal data to other group companies or service providers outside of the Hong Kong Special Administrative Region (“Hong Kong”). This may happen if ConnectAPAC’s servers or suppliers and service providers are based outside of Hong Kong or if you use ConnectAPAC’s services and products while visiting countries outside Hong Kong. ConnectAPAC will take steps to ensure that your personal information is used by such third parties in accordance with this policy.

7. Update of Privacy Policy

This Privacy Policy is subject to change from time to time without prior notice and any changes will be posted on ConnectAPAC’s website or You are advised to check for the latest version regularly. If there is any inconsistency or conflict between the version posted on the website and the previous versions, this version shall prevail. All handling of personal data will be governed by the most recent version of the policy. If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version will prevail.