Cookies Policy

1. Scope and Definitions

1.1 This Cookies Policy explains how the Company uses cookies and similar technologies when a User accesses or uses the Website. It should be read with the General Terms and Privacy Policy.

1.2 Unless otherwise defined in this Cookies Policy, capitalized terms have the meanings given in the General Terms. The interpretation rules in the General Terms apply unless the context requires otherwise.

1.3 In this Cookies Policy:

“Cookie” means a small text or data file placed on or accessed from a User’s browser or device when the User accesses or uses the Website.

“Similar Technologies” means technologies performing functions similar to Cookies, including pixels, tags, web beacons, scripts, software development kits, local storage, device identifiers and other tracking or storage technologies.

“Strictly Necessary Cookies” means Cookies or Similar Technologies required to transmit communications, operate or secure the Website, record cookie choices, or provide functionality expressly requested by a User.

1.4 If there is an inconsistency between this Cookies Policy and the Privacy Policy concerning the collection, use, disclosure or other processing of Personal Data, the Privacy Policy prevails. The General Terms prevail for all other purposes.

 

2. How Cookies and Similar Technologies Work

2.1 Cookies and Similar Technologies allow the Website to recognize a browser or device, remember information about a User’s visit and support particular functions.

2.2 Depending on their purpose, these technologies may be used to:

(a) operate, secure and protect the Website;

(b) manage network traffic, load balancing, sessions, forms and service enquiries;

(c) remember language, location, display and other preferences;

(d) monitor Website availability, performance and usage;

(e) understand how Users interact with information about the Company’s telecommunications, data centre, network, cloud connectivity, cybersecurity, AI and other products or services; and

(f) measure communications or marketing campaigns, where applicable.

3. Consent and User Choices

3.1 Strictly Necessary Cookies may be used without consent where permitted by applicable law because they are required to operate or secure the Website, transmit communications, record cookie choices or provide functionality expressly requested by a User.

3.2 Where applicable law requires consent for a non-essential Cookie or Similar Technology, the Company will request that consent through a cookie banner, preference centre or other appropriate mechanism before using that technology.

3.3 A User may withdraw or change consent at any time through any cookie-preference mechanism made available on the Website. Withdrawal does not affect processing conducted before withdrawal.

3.4 A User may also delete or block Cookies through browser or device settings. Browser settings may not update preferences recorded through the Website’s consent mechanism, and Users may therefore need to manage both settings separately.

3.5 Disabling a Cookie or Similar Technology may affect the availability, security, performance or functionality of the Website.

4. Types and Categories of Cookies

4.1 By duration, Cookies may be:

(a) Session Cookies, which generally expire when the browser is closed; or

(b) Persistent Cookies, which remain until their stated expiry or until deleted by the User.

4.2 By source, Cookies may be:

(a) First-Party Cookies, placed or controlled by the Company; or

(b) Third-Party Cookies, placed or controlled by an independent provider whose services or content are used on the Website.

4.3 Depending on the Website’s actual configuration, the following purpose-based categories may be used:

(a) Strictly Necessary Cookies, as defined in Clause 1.3;

(b) Functional Cookies, used to remember preferences and provide enhanced or personalized functionality, including AI-enabled chat, virtual-assistant or recommendation features, where made available;

(c) Analytics or Performance Cookies, used to measure Website traffic, availability, performance and interaction with content, products or services; and

(d) Advertising or Marketing Cookies, used, where applicable, to measure campaigns, attribute referrals or interactions and deliver or assess relevant advertising on the Website or third-party platforms. Users may manage Advertising and Marketing Cookies through the cookie banner, preference centre or other cookie-management mechanism made available on the Website, where applicable.

4.4 The Company may make further details about the Cookies and Similar Technologies used on the Website, including their providers, purposes, categories and durations, available through a cookie banner, preference centre or other notice displayed on the Website. Such details may be updated from time to time to reflect changes in the Website’s configuration.

5. Information Collected

5.1 Depending on the Cookies and Similar Technologies used, the Company or relevant third-party providers may collect:

(a) IP address and approximate location derived from it;

(b) browser type, operating system, device type and technical configuration;

(c) Cookie identifiers, session identifiers and similar online identifiers;

(d) referring and exit pages, pages viewed, links selected, access times, visit duration and navigation paths;

(e) Website availability, response time, error and performance information;

(f) language, display and other preferences;

(g) campaign, referral and interaction information;

(h) cookie-consent and preference records;

(i) security, authentication and fraud-prevention information; and

(j) interaction metadata relating to AI-enabled Website features, including session identifiers, feature usage, timestamps and technical events.

5.2 Information collected through Cookies or Similar Technologies may constitute Personal Data where it identifies a User or can reasonably be combined with other information to identify a User. The Company will process such Personal Data in accordance with the Privacy Policy and applicable law. The Company will not retain information collected through Cookies or Similar Technologies for longer than is reasonably necessary for the purposes for which it is used, unless a longer retention period is required or permitted by applicable law.

5.3 Where an AI-enabled Website feature uses Cookies or Similar Technologies, the Company will categorize those technologies according to their actual purpose and, where required by applicable law, obtain consent before using any Cookies or Similar Technologies other than Strictly Necessary Cookies. Personal Data processed through the feature is governed by the Privacy Policy and any notice presented with that feature.

5.4 Session Cookies are generally deleted when the User closes the browser. Persistent Cookies remain on the User’s device or browser for the period specified in the applicable cookie banner, preference centre or other notice made available on the Website, unless deleted earlier by the User or otherwise removed in accordance with the Website’s settings.

6. Third-Party Services and Technologies

6.1 The Website may use third-party services and technologies for:

(a) Website hosting, content delivery, traffic management and load balancing;

(b) cybersecurity, fraud prevention and performance monitoring;

(c) analytics and measurement;

(d) embedded videos, maps, social-media content or other external functionality;

(e) AI-enabled chat, virtual-assistant, recommendation or other interactive features, where made available; and

(f) campaign measurement, referral attribution or advertising, where applicable.

6.2 Third-party providers may place or access Cookies or Similar Technologies and collect information described in Clause 5. Their activities may be conducted on the Company’s behalf or independently for their own purposes, depending on the relevant service and arrangement.

6.3 The Website may use analytics services, including Google Analytics where enabled, to understand Website traffic, usage, performance and interaction with content. Details of any analytics provider and its technologies will be included in the information made available under Clause 4.4.

6.4 Where a third-party provider independently determines the purposes or means of processing, its own privacy and cookie notices apply. The Company does not control Cookies or Similar Technologies placed independently by that provider.

6.5 Information collected by third-party providers may be transferred to or processed in jurisdictions outside Hong Kong. Any Personal Data processed by or on behalf of the Company is handled in accordance with the Privacy Policy and applicable law.

7. Security

7.1 The Company will take reasonable and practicable technical and organizational measures to protect Personal Data collected through Cookies and Similar Technologies against unauthorized or accidental access, processing, erasure, loss or use.

7.2 No electronic transmission, storage system or security measure can be guaranteed to be completely secure. The Company does not warrant absolute security against unauthorized access, disclosure, loss or misuse.

7.3 Further information concerning the Company’s processing, security and retention of Personal Data is set out in the Privacy Policy.

8. Managing Cookie Preferences

8.1 A User may manage Cookies and Similar Technologies through any cookie banner, preference centre or other mechanism made available on the Website.

8.2 Most browsers and devices also allow a User to view, delete or block Cookies and manage related settings. The available controls and their operation depend on the relevant browser or device.

8.3 Controls made available by a third-party provider may need to be managed separately through that provider’s website, application or opt-out mechanism.

8.4 Some browsers or devices may transmit “Do Not Track”, Global Privacy Control or similar preference signals. The Website’s response to those signals will depend on applicable law and the Website’s technical configuration. Where required by applicable law, the Company will take reasonable steps to recognise supported preference signals.

9. Effects of Disabling Cookie

9.1 Deleting, rejecting or disabling Cookies or Similar Technologies may affect the availability, security, performance, appearance or functionality of the Website. Certain forms, preferences, interactive features or embedded content may not function correctly.

9.2 Strictly Necessary Cookies may remain active where permitted by applicable law because they are required to operate or secure the Website, transmit communications, record cookie choices or provide functionality expressly requested by a User.

9.3 To the maximum extent permitted by applicable law, the Company is not liable for any loss of functionality, degraded user experience or other consequence resulting from a User’s browser, device or cookie-preference settings, or from controls operated independently by a third-party provider.

10. Changes to This Cookies Policy

10. The Company may amend this Cookies Policy from time to time to reflect changes in applicable law, Website functionality, technologies, providers or processing practices.

10.2 Unless otherwise stated or required by applicable law, an amendment takes effect upon publication on the Website. The Company will take reasonable steps to notify Users of any material change affecting the purposes for which Personal Data is collected or processed.

10.3 Continued use of the Website after an amendment does not substitute for consent where applicable law requires consent to a Cookie or Similar Technology. The Company will request any required consent before using the relevant non-essential technology.

10.4 Users should review this Cookies Policy periodically. The date at the beginning indicates when it was most recently updated.

11. Third-Party Websites and Embedded Content

11.1 The Website may contain links to third-party websites or display embedded content or functionality provided by third parties. Interacting with that content may allow the relevant third party to place or access Cookies or Similar Technologies.

11.2 The Company does not control the privacy or cookie practices of an independent third party. Users should review the privacy and cookie notices of the relevant provider before interacting with its website, content or functionality.

12. Contact Us

12.1 For questions concerning this Cookies Policy or the Company’s use of Cookies and Similar Technologies, contact the Data Protection Manager using the contact details set out in the Privacy Policy or by email at dpm@ntt.com.hk.