TransUnion Limited Privacy Policy
TransUnion Limited (“TUHK”, or “our” or “we” or “us”) is committed to protecting your privacy, and supports a general policy of openness about how our collection, use and disclosure of the personal data comply with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong.
This privacy policy provides an overview of our business and explains how we collect, use and disclose personal data we receive during daily operations, including TransUnion Hong Kong mobile application (“TransUnion Mobile”) or web site, (the “Site”).
1. Where We Collect Your Personal Data
1.1 We may collect your personal data from various sources as summarized in the following table:
Type of personal data | Description | Source |
Consumer data | 1. Identifying information: name, email address, contact number, identity document numbers; and 2. Details of payments and transactions. | When you access, use or purchase any services, products (as defined under our Service Agreement). |
Consumer credit data (including without limitation credit card and consumer loan data, hire purchase data and mortgage data) | 1. Identifying information: name, address history, contact number history, identity document numbers; and 2. Credit account information: Open and closed accounts, past due accounts and amounts. | When you consent to us for obtaining your individual credit report from TransUnion Credit Information Services Limited (“TUCIS”), the selected credit reference agency under the Multiple Credit Reference Agencies Framework. |
Business contact information | Name, job title, email address, contact number, account information. | When you contact us or when we subsequently request it to proceed your written inquiry, service appointment, newsletter subscription, data subject request and job application. |
Proof of identity or authority and other supporting documentation | To prove your identity by authenticating your biometric data. If you enquire on someone else’s behalf, we may ask for proof of authority, such as a power of attorney. Sometimes we may require additional supporting documentation. | |
Employee information | Employment and educational history, background checks, performance appraisals, IP addresses and biometric data (optional). | |
Information gathered in dealing with your enquiry or complaint | Dealing with an enquiry involves investigating the circumstances. This type of information depends on the enquiry or complaint. | Internal records and external organizations, such as clients and suppliers. |
Our response and other correspondence | Our response to and other correspondence relating to your enquiry or complaint. | We produce this ourselves. |
CCTV footage | Images and videos recorded by on-premises CCTV cameras. | CCTV cameras installed in our business premises. |
2. How We Use and Disclose Your Personal Data
2.1 The use of your personal data is limited to purposes which have been disclosed before or at the time of data collection, or for purposes which are otherwise permitted by the laws.
2.2 Specifically, we use and disclose personal data in the following circumstances:
Type of personal data | Purposes of use of personal data |
Consumer data | 1. Providing services, facilities and goods. 2. Payments and billing. 3. Research and development of products. 4. Conducting surveys and analytics. |
Consumer credit data | 1. Compiling credit report with credit data from TUCIS. 2. Providing you access to your individual credit report via TransUnion Mobile and the Site. |
Business contact information | 1. Business communications and relationship management. 2. Engagement of contractors, subcontractors or other service providers. 3. Payments and billing. |
Employee information | Recruitment and human resources management, relating to such matters as employees’ appointment, employment benefits, payments, termination, performance appraisal and discipline, etc. |
Proof of identity or authority and other supporting documentation | To verify and authenticate identity before granting access or making corrections to your personal data. |
Information gathered in dealing with your enquiry or complaint | Processing your enquiry or complaint. |
Our response and other correspondence | |
CCTV footage | Ensuring safety of our staff and visitors and the security of our information and assets. |
2.3 We may provide you with additional privacy notices where we believe that it is appropriate to do so. Those additional notices supplement and should be read together with this Privacy Policy.
2.4 We will disclose personal data when authorized or required by law, regulations or rules, for example, in response to a court order or requests from law enforcement agencies or regulatory authorities.
2.5 We may also disclose your personal data to third parties who help us use it for the purposes described in Section 2.2. These service providers are prohibited from using your personal data for their own purposes unless you have been notified of this purpose or given your consent.
2.6 We may also share anonymized information with other third parties, but only where the information cannot realistically be identified as relating to you.
3. Retention of Your Personal Data
3.1 We keep personal data only for as long as is necessary for the purposes for which it is held, subject to legal, statutory and regulatory requirements mandating the retention of data.
4. Security of Your Personal Data
4.1 We take the protection of personal data seriously. We have adopted appropriate physical, electronic, and managerial procedures to protect personal data against unauthorized or accidental access, processing, erasure or other use.
5. Access and Correction of Your Personal Data
5.1 You have rights to ascertain whether we hold personal data relating to you, to obtain a copy of those data, and to correct any data that is inaccurate.
5.2 Requests to access or correct your personal data provided to us can be made to our Data Protection Officer at dpotuhk@transunion.com or by post to our office address, 8th Floor, Tower 5, The Gateway, 15 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong.
6. Changes to this Privacy Policy
6.1 We reserve the right to modify this privacy policy at any time without notice. The privacy policy posted at any time shall be deemed to be the privacy policy then in effect.
6.2 For enquiries regarding this privacy policy, please contact our Data Protection Officer at dpotuhk@transunion.com or by post to our office address at Section 5.2 above.
7. English Version to Prevail
7.1 In the event of any ambiguity or inconsistencies between the English and Chinese versions of this privacy policy, the English version shall prevail.
Updated as of 1st day of November, 2023
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