Privacy Statement of The Location Company Ltd. and its subsidiaries and associates incorporated and doing business in Hong Kong (hereinafter collectively referred to as "The Location Company")

We are committed to protecting your personal and financial information. In order to deliver to you the services we contract to provide we need to collect and maintain certain information concerning you and/or your company. This Privacy Statement describes the personal and corporate information we collect, what we do with it, and how we protect it. Please rest assured that we operate in compliance with the Personal Data (Privacy) Ordinance and any relevant guidelines/codes laid down by the Office of the Telecommunications Authority.

Types of personal information we collect

  • Your name, address, identity card number, date of birth, contact details, and, in connection with applications and services which require such information for the proper delivery of The Location Company's service to you but not further or otherwise, particulars of family and/or next of kin, medical history, employment information, banking information and the like.


  • A record of the messages, calls and transactions you send, make and execute in the course of operating our Applications or using any SIM card delivered to you for the purpose of enjoying our services.

  • A record of your historic location over periods of time and/or the historic location of Subscribers and/or other persons nominated by you to carry devices containing SIM cards supplied by The Location Company.

  • The relationship(s) between you and any Subscriber, Authorised Contact or other responsible person nominated by you in connection with the operation of an Application or use of one of our services.

  • The relationship(s) between you and any Employer, Customer or other authorised person who has nominated you as a Subscriber, Authorised Contact or other responsible person in connection with the operation of an Application or use of one of our services.
Types of corporate information we collect
  • Your company's name, address, incorporation and Business Registration number, nature of business, particulars of your employees or officers, banking information, etc

  • The equipment we have installed and/or licensed in your Company's premises, the Location Application software installed thereon and any other software with which the Location Application software is required to interact directly or indirectly.

  • A record of the messages, calls and transactions your employees and/or other Subscribers nominated by you send, make and execute in the course of operating our Applications or using any SIM card delivered to you or any employee or other Subscriber nominated by you for the purpose of enjoying our services.

  • A record of the historic location over periods of time of your employees and/or Subscribers and/or other persons nominated by you to carry devices containing SIM cards supplied by The Location Company.

  • Any employee, officer, contractor or supplier of The Location Company who has a duty to perform the services or any part thereof which The Location Company has committed to provide to a Customer and needs such information for the purposes of providing such services or any part thereof.
Information we do not disclose

The Location Company will not disclose personal information about you or any employee of yours or any Subscriber or other person nominated by you to carry a device containing a SIM card supplied by the Location Company to anyone except as required or permitted by law or with your consent. We shall not under any circumstances sell your personal information (although we may participate in certain profits of parties to whom we have disclosed the information as provided below) and this commitment is made with the intent that it should bind any receiver or liquidator of our company.

The Location Company will not disclose information as to your present or historic location (where you are or where you have been) or as to the present or historic location of any employee or other Subscriber nominated by you or any other user of a SIM card provided for use with a Location Company Application except to:
  • the Location Company Customer who is your employer or who nominated you as a Subscriber or user of a Location Company SIM card; or

  • an Authorised Contact nominated by the Location Company Customer who nominated you as a Subscriber or user of a Location Company SIM card; or

  • the Police, Ambulance, or other service deemed necessary to perform any required tasks in the case of an emergency; or

  • as required by law in the case of government or regulatory organisations having jurisdiction over us including (but not limited to) the Office of the Telecommunications Authority.
Who we will disclose information to

The Location Company shares the record of the messages, calls and transactions you, your employees and/or other Subscribers nominated by you send, make and execute in the course of operating our Applications or otherwise enjoying our services with the network operator who provisioned the SIM card(s) used in connection with such operation for billing purposes only.

The Location Company shares personal information about you and any employee of yours and any Subscriber or other person nominated by you to carry a device containing a SIM card supplied by the Location Company (including where necessary present or historic locations) with agents and contractors to the extent that they need such information for the proper performance of their duties under a contract for services entered into with The Location Company but not further or otherwise. Such parties may include (but are not limited to) service providers for concierge and call centre services, emergency location services and the like. All such agency or service contracts bind the recipient of any such information by confidentiality covenants which are more restrictive than this Privacy Policy.

The Location Company may also disclose such part of the aforesaid information as is necessary for the collection of outstanding fees and charges due from you or your company in the event that your account becomes delinquent.

The Location Company may disclose limited personal information about you to a subsidiary or associated Location company or to a Licensee whom we have licensed to develop and/or operate Applications using our Location Platform and/or with whom we have a marketing programme. The information we share is limited to your name, contact information, and type of account. We never disclose the records of your messages, calls or transactions or your present or historic locations in this connection.
Finally, The Location Company discloses personal information to non-affiliated third parties as permitted or required by law in the case of government or regulatory organisations having jurisdiction over us including (but not limited to) the Office of the Telecommunications Authority.

You can ask us not to share this information with anyone (except those required by law and those who require the information to deliver the services or any part thereof which we have contracted to provide to you) by checking the opt-out box at the foot of this Privacy Statement.

How does The Location Company protect the confidentiality and security of my personal information?

We maintain physical, electronic, and procedural safeguards that comply with all statutory provisions in effect in Hong Kong governing privacy and data protection and with all relevant standards necessary to guard your personal information. Our servers use Secure Sockets Layer (SSL) technology where necessary or appropriate to prevent unauthorised parties from viewing the personal or private corporate information that you give or access during a secure session. This is why you must enter a unique username and password each time you view your personal or corporate information on line.

We also limit access of your personal information to only those employees who need the information to provide products or services to you, such as customer service personnel. The Location Company conducts internal audits of its business practices and procedures from time to time to ensure maintenance of the standards of protection of personal and corporate information by our staff and contractors.

What should I know about "cookies"?

"Cookies" are information that a website can send to your browser and store on your computer. Cookies do not contain personal information about you (unless you knowingly provide it). They usually contain only information about the pages or links that you view.

The Location Company uses cookies to enhance navigation and the functionality of our website, to verify your identity and to personalise and streamline your experience on the site. We also use cookies to let us know how you are using our website so that we can improve both the website and your experience of it.

You do have control over cookies. Most browsers allow you to be notified before a cookie is placed on your computer. You can also set most browsers to refuse cookies, although this may negatively affect your Internet experience. You can also erase cookies that are already on your computer. For more information on working with cookies, see your browser or operating system's user manual, FAQ, or online help.

For answers to other questions regarding the Location Company Privacy Statement, please email info@locationco.com.


Remarks: Should there be any discrepancy between the English and Chinese versions, the English version shall prevail.
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