Privacy Policy Statement

Version: 17 Nov 2023

VTech Communications Limited, together with its subsidiaries and affiliates, (“VTech”, “us” or “we”) are committed to protecting the privacy of your personal data. We pledge to duly comply with applicable laws and regulations regarding personal data protection, including the Personal Data (Privacy) Ordinance (“PDPO”) of Hong Kong SAR and the Data Protection Principles contained therein (“DPP”). This statement is our policy statement on how we collect, use and handle your personal data. It also describes your legal rights, including your right to make data access request and data correction request. When you visit our website, use our service, contact us or communicate with us, you may provide us with your personal data. Please read this statement carefully before furnishing us with any personal data. 

This Privacy Policy does not apply to the VTech affiliates operated in North America, Europe and certain countries, and the websites and services offered in the respective countries, including specifically: VTech Communications, Inc. and its website www.vtechphones.com; VTech Electronics North America, L.L.C. and its website www.vtechkids.com; and LeapFrog Enterprises, Inc. and its website www.leapfrog.com. Those VTech affiliates and their websites have their own privacy policies, which may be found on each site.
We will communicate any material changes to this statement by posting the updated version on our website. Unless stated otherwise, the changes will be effective from the date of posting. 
This statement is written in English and may be translated into other languages. In the event of any inconsistency between the English version and the translated version, the English version shall prevail. 

1. Collection of Personal Data

VTech collects personal data for lawful purposes and by lawful and fair means. The personal data collected in relation to a specified purpose is adequate but not excessive in respect of the purpose. For the collection of personal data from an individual (“Data Subject” as defined under the PDPO), we will inform the Data Subject: 

1. the purpose(s) for which the personal data is to be collected and the groups of persons to whom the personal data may be transferred; 
2. whether it is obligatory or voluntary to supply the personal data, and the consequences of not supplying obligatory personal data;
3. the right of the Data Subject to request access to and correction of personal data held by us; and 
4. the party responsible for handling data access and correction requests.

We collect personal data of Data Subjects in the ordinary course of our business and operation. In general, the Data Subjects include our: 

1. customers;
2. contractors;
3. job applicants; and
4. employees. 

We may collect personal data directly from a Data Subject when the individual interacts with us. We may also collect personal data of a Data Subject indirectly from third parties. 

Our Personal Information Collection Statement  states: 

1. the kind of personal data collected or held by us;
2. the purposes for which we may use such personal data; and
3. the classes of persons to whom the personal data may be transferred. 

The collected personal data will be used or disclosed to third parties for the purposes:

1. for which it is collected; 
2. as specified in the Personal Information Collection Statement ; or
3. as required or permitted by the PDPO and other applicable laws.

Our website is not directed to individuals aged below 18. If we are aware that you are under 18, any personal data submitted by you via our website will be deleted.

2. Collection of Personal Data from the Use of Digital Platforms

  
You may note that certain data may be collected in your use of our digital platforms:

1. A cookie is a small text file that is stored by your web browser on your computer. Every time you revisit our website, your web browser sends these cookies (“Cookies”) back to us so that we can customize your experience to better match your interests and preference, or to simply facilitate your use of our website.
2. Generally, we use Cookies to help us operate our website and collect information about online activity. The information we collect via Cookies is usually statistical data about users’ browsing actions and patterns, and does not show personal details that identify you. We shall use the information we collect via Cookies for statistical analysis in order to operate, improve and personalize our website, and the products and services we offer.
3. You can control how your web browser handles Cookies received from websites. You can choose to accept or decline Cookies from our website. However, if you turn off or refuse to accept Cookies from our website, you may not be able to use some of the features and functionality available on our website.
4. A pixel tag (also known as a clear GIF or web beacon) is an invisible tag that may be placed on certain pages of our website but not on your computer. When you access these pages, pixel tags generate a generic notice of that visit. They usually work in conjunction with Cookies, registering when a particular computer visits a particular page. If you turn off Cookies, the pixel tag will simply detect an anonymous website visit.
5. In addition, we may use Google Analytics (“Google Analytics”) or other similar tools provided by third parties to analyse user traffic patterns and user behaviour. Google Analytics generates statistical and other information about use of our website by means of Cookies, which are stored on your computer. Google Analytics will store and use the information, which we are not responsible therefor. You are invited to familiarize yourself with Google’s privacy policy  or if applicable, the privacy policy of other tool providers to find out how they use Cookies, storage and use of the information.

Do Not Track Signals: Our systems do not currently recognize or respond to browser “Do Not Track” signals.

3. Direct Marketing

VTech may from time to time and with your consent, use your personal data to send you marketing materials about, including without limitation, our products, services, offers, promotions, campaigns and events. 

You may opt out of receiving direct marketing communications at any time by post or by email to our Data Protection Officer, the contact details are set out at the end of this statement. In the case of direct marketing email, you may opt out by following the steps set out in the email. 

4. Security of Personal Data

VTech takes all reasonably practicable steps and implement internal protocols to safeguard the security of the personal data held by us. 

The personal data will be securely stored with restricted access by authorized personnel only. We utilize encryption/security software in data transmission. Personal data so transmitted will be in a secure format so that their privacy and security are guarded against unauthorized access or disclosure, accidental loss, alteration or destruction.

In addition, we adopt contractual or other means to prevent any personal data transferred to our data processors both within and outside Hong Kong (i) from being kept longer than is necessary for processing of the data; and (ii) from unauthorized or accidental access, processing, erasure, loss or use, if we are to engage any data processor.

VTech’s internal IT systems are developed and maintained by its in-house staff and selected third-party service provider. The third-party service provider does not have access to personal data stored in the IT system except when it is carrying out trouble-shooting on it under the supervision of our staff.

5. Accuracy and Retention Period of Personal Data

VTech takes all reasonably practicable steps to ensure the accuracy of the personal data held by us. 

We retain the personal data no longer than is necessary for the fulfillment of the purposes of collection unless a longer retention period is required or permitted by applicable laws and regulations.

6. Data Access Request and Data Correction Request

A Data Subject is entitled to make a data access or data correction request pursuant to PDPO. All such requests shall be sent by either post or email to our Data Protection Officer, the contact details are set out at the end of this statement. 

For data access requests, please send us a completed data access request form which is available at https://www.pcpd.org.hk/english/publications/files/Dforme.pdf.

We will inform the requestor of the outcome within 40 calendar days of the submission of the request and will give a reason if the request is refused. We may charge a reasonable fee for data access request.

7. Third-Party Websites

Our website may contain images of and hyperlinks to websites operated by third parties (“Linked Sites”). VTech is not responsible for the contents of any Linked Sites nor the privacy practices of the Linked Sites. You should remain alert when you exit from our website and access these Linked Sites, and check their privacy statements. 

8. California Residents

The California Consumer Privacy Act (the “CCPA”) provides California residents with certain rights regarding their personal information that is collected by certain businesses.  However, VTech Communications Limited is a business-to-business (“B2B”) company that generally collects personal information only from individuals acting as employees, owners, directors, officers, or contractors of other businesses.  As such, VTech Communications Limited is exempt from many of the provisions of the CCPA pursuant to Cal. Civ. Code 1798.145(n)(1).  VTech Communications Limited does not sell personal information to third parties.  In addition, VTech Communications Limited will not discriminate against any California residents who exercise any of the applicable privacy rights under the CCPA. 

9. Contact Us

If you have any questions concerning this Privacy Policy Statement or our privacy practices, you may contact our Data Protection Officer by either post or email. 

By Post: 
VTech Holdings Limited
23rd Floor, Tai Ping Industrial Centre, Block 1
57 Ting Kok Road, Tai Po
New Territories 
Hong Kong
Attn: Data Protection Officer

By Email: 
privacy@vtech.com