Privacy Policy

As a user ("User") of the website(s) ("Website(s)") of TOM Group Limited ("TOM"), it may be necessary for you to provide TOM and/or its subsidiaries ("TOM Group") and/or any company which is or may be interested in collecting your personal information ("Information") at the time of registration or whenever you are using the Websites. The terms "You" and "User" as used herein refer to all individuals and/or entities accessing the Websites for any reason or any purpose. Such Information may include, without limitation, your name, date of birth, gender, contact information, e-mail address, education level, occupation, interests and favorite activities. YOU HEREBY AGREE THAT THE INFORMATION YOU PROVIDE TO TOM IS PROVIDED VOLUNTARILY, AND IS ACCURATE, TRUE, CURRENT AND COMPLETE. If this is not the case or TOM has reasonable grounds to suspect as such, TOM has the right to cancel your registration and/or refuse any and all current or future use of the Websites and its services to you. If the Information you provide to us is incomplete or incorrect, TOM may not be able to provide or continue to provide the products and/or services offered on the Websites to you or may not permit you or may discontinue your access to the Websites. You understand and acknowledge that all or any part of the Information you provide to TOM will be collected and may be used for one or more of the following purposes:

  1. collecting data for identity ratification and records;
  2. analyzing and comparing your Information with that of others for product and/or services customization and/or marketing (direct or otherwise) purposes;
  3. enabling TOM to comply with its obligations to interconnect or other industry practices;
  4. sending you information about different products and services;
  5. maintaining contact lists for correspondence;
  6. compiling aggregate statistics on the Websites usage;
  7. performing procedures for comparing the User's data with other information supplied by the User (for whatever purpose), including, without limitation, procedures undertaken for the purpose of taking adverse action against the User (whether such comparison is by manual or automated means);
  8. forwarding publicity and/or marketing materials or other information to the Users from charitable organizations or any other types of organizations selected by TOM from time to time;
  9. meeting any legal, governmental or regulatory requirements in Hong Kong or any other applicable jurisdiction, including disclosure and/or notification requirements;
  10. assisting any person who is acquiring or participating in any contractual arrangements involving TOM to evaluate such acquisition or participation; and
  11. carrying out the User's instructions, responding to enquiries by that User or made on his/her behalf and providing the Users with an effective and efficient service.


TOM's policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of the Information will be in accordance with the laws of Hong Kong including the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) ("PDPO") and are as set out herein and also in the Privacy Policy Statement.

To enable TOM to provide you with customized and personalized services, TOM may use cookie files or other methods to store and track information about you when you visit the Websites and this may be done without your awareness of the occurrence.

You acknowledge and agree that you are solely responsible for the form, content and accuracy of any material or Information placed by you on the Websites.

You are aware, agree and authorize that all Information supplied by you will be retained by and stored in one or more databases of TOM and will be provided to, disclosed to, accessed by and/or transferred to:

  1. any person or bodies corporate or division of any member of the TOM Group and/or any member of the Hutchison Whampoa Limited group of companies;
  2. any person or bodies corporate under a duty of confidentiality owed to TOM;
  3. employees of TOM;
  4. any contractors, agents, other persons or bodies corporate engaged by TOM for or in relation to any of the purposes listed above or any third party service providers who provides administrative, telecommunications, computer, payment, securities clearing, insurance, professional or other services to TOM;
  5. any person or corporation to whom any member of the TOM Group transfers or proposes to transfer its interests and/or obligations in respect of that User or any product or service provided to that User;
  6. any nominee, trustee, co-trustee, centralized securities depository or registrar, custodian, insurance company, estate agent, solicitor or other person who is involved with the provision of TOM services and/or products to that User;
  7. any person by whom TOM is required by any applicable legal, governmental or regulatory requirements to make disclosure; or
  8. any other person reasonably requiring the same in order for TOM to carry out the purposes set out herein.


You agree that TOM may release your Information when such release is reasonably necessary to (i) comply with applicable law, (ii) enforce or apply the terms of any of User agreements, (iii) protect the rights, property or interest of TOM or its Users or (iv) comply with TOM's Privacy Policy Statement. You are aware of your rights under the PDPO, including, among other things, the right to: (1) check whether we hold any of your Information; (2) have access to your Information held by TOM; (3) request correction of your Information; (4) learn more about our policies and practices (from time to time) in relation to the Information and the types of Information held by us; (5) disallow access or use of your Information by TOM; and (6) be informed of any action taken in response to any such request and/or request of a statement to be attached to your Information which you can supply to TOM relating to the fact that you have requested a correction. You agree to pay to TOM such reasonable charges which may be requested by TOM in relation to the time and attendance involved in complying with your request in this regard.

Given the nature of the Internet, TOM cannot guarantee the transmission of data is 100% secure. However, TOM shall take all reasonably practicable steps to ensure that any Information collected by TOM via the Websites is safe and secure from third party interference. However, please note that TOM's advertisers or other web sites that have links on the Websites may collect personal data about you.

TOM shall retain your Information for so long as you are a registered User. Once you have given us your Information, you may receive from TOM, from time to time, telephone calls, email and direct mailings containing promotional materials. If you do not want to receive them, please write to TOM's Data Protection Officer at the address provided below. You may also be asked to indicate your preference before signing up for any of TOM's paid services. You may review and update your Information online by visiting the Websites.


Access or correction requests can be made by sending the request in writing to the following address:

Personal Data Officer,
TOM Group Limited,
48/F, The Center,
99 Queen's Road Central,
Hong Kong

Fax No.: (852) 2186 7711
Email Address: pdo@tomgroup.com