TransUnion Limited (“TransUnion”) is committed to protecting your privacy, and supports a general policy of openness about how we collect, use and disclose the personal information of Hong Kong consumers.
This TransUnion Privacy Policy provides an overview of our business and explains how we collect, use and disclose the information about consumers that appears in our database, TransUnion mobile application (“TransUnion Mobile”) or web site, www.transunion.hk (the “Site”).
1.1 We collect your personal information primarily from the following sources:
credit providers who are our members who provide credit information about you, including credit card and consumer loan data, hire purchase data and mortgage data;
directly from you when you:-
provide us with comments regarding our services;
access or use any Products (as defined under our Service Agreement) or functions in our Site or TransUnion Mobile. You may be asked to provide information through our Site or TransUnion Mobile for various purposes such as applying for your credit report on-line, making enquiries with us or using our Products or functions. You may provide to us certain personal information, such as first and last name; address; date of birth; identity document number; contact number; email address; account ID and password; and credit card information. We will use the information collected from you for the purpose for which you provided such information;
decide to purchase one of our products or services, subscribe to our emails or newsletter, participate in one of our contests or surveys or transact other business with us, use any Products or functions in our Site or TransUnion Mobile;
submit any information for an employment purpose;
post, publish, transmit, upload any content to our Site or TransUnion Mobile;
1.2 Information We Collect
All these data will be kept in our secure server and no Personal Data will be transferred to any third parties.
2.1 We limit our use of consumers' personal information to those purposes which have been disclosed to consumers by our members, or for purposes which are otherwise permitted by the laws. We disclose personal information in compliance with the law primarily by means of credit reports to both consumer and members. Specifically, we use and disclose personal information in the following circumstances:
to provide our consumer credit reporting services and other related services to our members; or
to provide consumer credit information directly to consumers who have requested a copy of their credit reports, or to provide related services to consumers.
2.2 We may use information about your subscription of our service/ products, such as your usage patterns, to customize your web site and/or customer service experience.
2.3 As a service to you, we will use your email address to provide you a receipt of your purchase. Some of our subscription products, such as TransUnion Credit Watch, may include alert emails or other informational emails that are sent on a daily, weekly or monthly basis. These emails are part of the subscription benefits and cannot be disabled for persons who are subscribers of these products.
2.4 Our third party call center operator may use information about you in our database to verify your identity, when providing assistance to you. We may also use information provided by you and in our database to confirm your identity and to prevent unauthorized or fraudulent access and/or transactions on our Site and TransUnion Mobile.
2.5 We may provide anonymous information (i.e., information that does not identify individual consumers) in the form of aggregate, geographic or demographic data to our members, customers or service providers.
2.6 We may share information without personal identifiers with third parties engaged to assist us in providing services and information to our members. These service providers are prohibited from using your personal information for any purpose other than to provide this assistance and are required to protect personal information disclosed by us and to comply with the general privacy principles described in this Privacy Policy. Some of these service providers are located outside of Hong Kong. As a result, your personal information may also be subject to applicable local laws, which may be different from Hong Kong laws.
2.7 We may disclose your personal information to third parties in the good faith belief that such action is necessary in order to comply with applicable law, or be responsive to, legal process served on us (such as a subpoena or court warrant), or if we believe such disclosure is necessary to protect and defend the rights, property or safety of TransUnion, our users or others.
2.8 We may disclose your personal information to consultants, agents and advisors, such as attorneys and accountants, in the good faith belief that such disclosure is within the scope of their professional duties to TransUnion and with the understanding that such professionals will abide by our security and confidentiality policies.
3.1 We will use your information for the direct marketing purpose only if you give your consent to us. You may sign up for our free newsletter or personalised offers in a variety of ways. For counter services, you may tick the box on the application form to opt-out from receiving information about credit management products or services from us. For on-line services, you may opt-in during the online ordering process by ticking the opt-in box that states,
“Please send me helpful tips & news about my service, including special offers from TransUnion and trusted partners!”
“TransUnion may use and transfer my personal information to its authorized agent in or outside Hong Kong for direct marketing of TransUnion's credit management products or services including but not limited to marketing materials, special offers, discounts, and free credit tips!”
After the completion of your order, you shall be asked to provide us with the consent for Personalised Offer by pressing the button of “AGREE & CONTINUE”:-
“… … you agree to:-
… …
authorize TransUnion to access, use, process and analyze your personal information provided by you, Internet Information and all or part of your consumer credit data which may be held in our database from time to time to provide you personalized offers of TransUnion and our trusted partners.”
3.2 If you decide to receive our tips and news, special offers or personalized offers from us and our trusted partners, TransUnion may use your personal information, including your name, contact details, products and other service portfolio information, transaction pattern and behaviour, financial background and demographic data held by us from time to time, to contact you and to transfer them to our authorized agent in or outside Hong Kong for direct marketing of TransUnion’s credit management products or services including but not limited to marketing materials, personalized offers, special offers, discounts, and free credit tips which include the following classes of products, services and subjects: (a) financial, insurance, credit card, banking and related products and services; (b) reward, loyalty, co-branding or privileges programmes and related products and services; (c) products and services offered by our co-branding/ trusted partners; and (d) donations and contributions for charitable and/or non-profit making purposes.
3.3 The aforementioned products, services and subjects may be provided by or (in the case of donations and contributions) solicited by us and/or: (a) any affiliates of TransUnion;
(b) third party financial institutions, insurers, credit card companies, securities and investment services providers; (c) third party reward, loyalty, co-branding or privileges programme providers; (d) co-branding/ trusted partners of ours or any affiliates of TransUnion; and (e) charitable or non-profit making organisations.
3.4 TransUnion may carry out "matching procedures" in Hong Kong or overseas for the marketing purposes described in Clauses 3.2 and 3.3 above.
3.5 TransUnion may, from time to time, engage third parties to provide marketing services on their behalf, and may share your personal information described in Clauses 3.2 and 3.3 above with these third parties for such purposes. In addition to marketing the above products, services and subjects ourselves, we may provide the data described in Clause 3.2 to all or any of the persons described in Clause 3.3 above for use by them in marketing those products, services and subjects, and we require your written consent (which includes an indication of no objection) for that purpose.
3.6 In case you no longer want to receive these messages via email or any other means, you may request us to stop doing so by opting-out of receiving the email by responding to the newsletter and asking to be unsubscribed, or calling our customer service department and asking to be taken off the list. If you signed up for our newsletter by selecting the special offers opt-in box during the ordering process, you may unsubscribe through the above two processes. Alternatively, you may go to transunion.hk log-in as a subscriber, click on your "profile" link, go to "My Settings", and de-select the Emails & Special offers opt-in box. In case you want to opt out for personalized offers, you may email us at contact@transunion.hk to cancel your subscriptions.
4.1 In order to process your transactions and provide you with quality customer service, for counter services we need you to provide information requested on the application form such as your full name and address, and for on-line services we need your full name and current and/or billing address, your email address (so we can contact you) and, if you purchase one of our products or services, a valid credit card number, your identity card number and certain other personal information, such as your date of birth, address information, employment information, and certain credit card and loan account information. We use such information to verify and authenticate the credit card number (for on-line services), and to confirm that the person requesting your personal information or credit report really is you and not an impostor or other person improperly seeking to access your information.
4.2 You hereby give your consent to and authorize TransUnion to:-
use, process all information, including any photo images, videos or documents, provided by you, and match against each other; and
access all or part of your consumer credit data which may be held in our database from time to time (“Your Credit Data”), and to match all or part of Your Credit Data and other data held in our database against the information you provide,
for the purpose of verifying your identity, documents or any information, and to monitor, detect and avoid fraudulent transactions on your account on our Site or TransUnion Mobile.
4.3 You may not be able to register, subscribe or purchase the products on our Site or TransUnion Mobile, or to obtain your credit report at our counter, if you do not agree to give us your consent to verify your identity.
5.1 TransUnion retains your personal information in our credit information database for as long as necessary to fulfil the purpose(s) for which it was collected and to comply with applicable laws.
5.2 All credit reports will be retained in a secured environment for up to 6 months to enable us to deal with queries. Information provided by non-e-Cert users who have not yet provided supporting documents for account activation purpose will be retained for 61 days. All records pertaining to payment and service order history will be retained by us for up to 2 years for administrative purposes.
6.1 We take the protection of personal information seriously. We have adopted procedures to secure storage of personal information and are committed to working with our members to protect the security of personal information during any transfer to or from us. We have also instituted a number of safeguards to identify and help prevent the fraudulent use of personal credit information.
6.2 For counter services, the physical application form will be destroyed within 1 week after completion of transaction at counter, and the information on the application form will be retained for 3 months in a safe and secured environment and thereafter purged. For our online services, in our Site or TransUnion Mobile, we takes precautions to secure your personal information. If and when we ask you to provide your personal information, we will do so through a Web page that uses the Transport Layer Security (TLS) protocol. This protocol provides security for your information by encrypting it as it travels from your computer to our computer. For security purposes we then move all of the personal information that we collect or obtain about you, including your credit report, to an environment on our proprietary network that has controls in place to limit access to and secure the data maintained therein. For more information about our security practices, please review our Security Policy.
7.1 You may request a copy of your credit report at a fee.
7.2 For on-line services, you may correct or update at any time the personal information that you provided and that we maintain on you by accessing our Site or TransUnion Mobile and selecting your "profile" from the Main Navigation.
7.3 When gathering personal information, we work with our members to increase their awareness of the importance of providing only personal information that is accurate, complete, and up-to date. However, TransUnion cannot alter the information reported by our members, unless the information is determined to be wrong, incomplete or otherwise inaccurate. If consumers do not agree with the accuracy of the information TransUnion has on file, we have procedures to verify such information and, where appropriate, to amend or correct it. We also have established complaint procedures to address consumer concerns and to appropriately investigate and address inquiries and complaints.
7.4 Requests to access or correct your information provided to us can be made by email to contact@transunion.hk or, by calling our Consumer Services and Operations Department at (852) 2577- 1816, or contact us at our office address, Suite 811, 8th Floor, Tower 5, The Gateway, 15 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong
8.1 Our Site or TransUnion Mobile may offer links to third party web sites including the Hong Kong Post Office (by use of the e-Cert service) and payment gateways for credit card payment. You should be aware that operators of linked web sites may also collect your personal information (including information generated through the use of cookies) when you link to their web sites.
8.2 TransUnion is not responsible for how such parties collect, use or disclose your information and it is important for you to familiarize yourself with their privacy policies before providing them with your personal information.
We define children as individuals under the age of 16. Our Site or TransUnion Mobile is not intended for the use of children and we do not intend to collect information about children through our Site or TransUnion Mobile. You must be at least 18 to access any products through our Site or TransUnion Mobile or become a subscriber of any subscription program entitled to subscription benefits.
TransUnion reserves the right to modify this Privacy Policy at any time without notice. The Privacy Policy posted at any time via our Site or TransUnion Mobile shall be deemed to be the Privacy Policy then in effect.
In the event of an acquisition of all or part of TransUnion by another company, or in the event that TransUnion were to sell or dispose of all or a part of the business, the acquirer would have access to the information maintained by the TransUnion business, which could include your personal information, subject to applicable law. The acquirer's privacy policy might be different than TransUnion's privacy policy, or the acquirer might choose to amend TransUnion's privacy policy. You will be notified by email if, as a result of such acquisition, the privacy policy is materially changed or if the acquirer's privacy policy is materially different than TransUnion's privacy policy. In connection with such notice, you will be given an opportunity to inform the acquirer that you do not consent to the use or disclosure by the acquirer of your personal information in accordance with such new or revised privacy policy.
For enquiries regarding this policy, please contact us at contact@transunion.hk or, our Consumer Services and Operations Department at (852) 2577- 1816.