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Personal Information Collection Statement for Registered Users of Carbon Wallet Application and CW Points Promotion (“PICS”)

This PICS sets out our policy for handling personal data collected and used for Registered Users of the Application and Carbon Wallet Points (CW Points) Promotion. Unless otherwise defined here, any capitalized terms in this PICS shall adopt the same definitions contained in “Carbon Wallet Application Terms and Conditions of Use and Service”. In the event of any conflicts or inconsistencies between the different language versions of this PICS, the English version shall prevail. By providing your personal data to us, you agree to the terms of this PICS. If you do not agree with this PICS or do not want to provide your personal data to us, you can use the Application as a guest/anonymous user. We may update this PICS from time to time by posting the updated version on the Application and notifying you of major changes (if any). Please check this PICS from time to time to understand your privacy rights.

1.    Collection of Personal Data

User Registration

1.1    User registration is entirely voluntary in the Application.  If you choose to register, Personal Data collected by or in connection with the Application would include but not limited to:

Mandatory data: 
•    Device information (e.g. operating system)
•    Name 
•    Gender
•    Mobile number 
•    Email address 
•    Settings and usage of the Application (e.g. cookies, browsing histories)


Voluntary data:
•    Access of current geo-location of your device
•    Month & Year of birth
•    District


1.2.    With your device location, we can provide you with better experience in the Application, such as by automatically identifying your nearby vegan restaurants and recycling points. Your device will not store location records on the Application without your authorisation. You can control how the Application can access your device locations through your device’s operating system and the Application’s setting menu. 

1.3.    If you are under the age of 18, you must ask your parent or guardian before providing any Personal Data to us.


CW Points Promotion

1.4.    Registered Users will be entitled to participate in Carbon Wallet Promotion to earn CW Points and the relevant Rewards, subject to the applicable Rules of Promotion.  For CW Points Promotion, we may further collect or obtain the following types of Personal Data that you voluntarily submit to the Application and/or any Participants in connection with your eligible green activities under the relevant promotion programs concerned:

Registered Users’ voluntary submission of Personal Data to earn CW Points with green activities captured in the Application:
•    Photograph proof and information record of certain eligible recycling activities at the designated recycling points;
•    Receipt scanning proof for certain eligible green activities at the designated restaurants or stores as defined by Carbon Wallet;
•    QR code scanning after completing certain eligible green activities at the designated restaurants or stores as defined by Carbon Wallet;
•    QR code scanning at water dispensary stations offered by the relevant Participants;
•    Record of eligible activities and CW Points data through system integration with the relevant Participants’ database;
•    Apple Heath / Google Health step counting data;
•    Address and contact information for delivery of products and/or services offered by the Participants for Rewards redemption.


If you link your octopus card with the Application to earn CW Points with eligible trips on MTR, your further Personal Data will be collected as follows:-
•    Octopus card identification numbers;
•    Trip records on the railway network of MTR Corporation Limited in Hong Kong (i.e. MTR 9 main commuter lines: Kwun Tong Line, Tsuen Wan Line, Island Line, South Island Line, Tung Chung Line, Tseung Kwan O Line, East Rail Line, Tuen Ma Line and Disneyland Resort Line, excluding light rail, MTR buses, Airport Express and High Speed Railway)

It is completely voluntary for you and any other persons (such as your friends and family members) to earn CW Points together for your benefit from eligible green behaviours that are made by those other persons.  By your submission of any Personal Data and eligible green activity records made by those other persons, you agree and confirm that you have already notified and obtained the relevant permission/consent from those persons for your use and submission of their Personal Data and eligible green activity records for our handling and use of their Personal Data and records in accordance with the terms of this PICS.  If you have not obtained such permission/consent, please do not provide any data and records of those persons to us.  You shall remain responsible for your dealings with the Personal Data of those other persons.  For the purpose of this PICS, the reference to “your Personal Data” shall include any Personal Data of any other persons that you may from time to time provide to us under or in connection with the Application and/or CW Points Promotion.  No dual claim or earning of CW Points will be allowed for the same eligible spending between you and those other persons. 

1.5.    If you fail to provide us with accurate and complete Personal Data marked as mandatory above, we may not be able to process your Registered User registration, or provide the relevant information, products or services to you in the Application and/or the relevant Promotions, or some functions of the Application may be unable to fully operate. 

2.    Purposes of use of Personal Data

2.1.    We may collect, obtain, process, access, use, store and/or handle Personal Data for any or all of the following purposes:-

a.    Provision, operation, administration, management and improvement of the Application and/or CW Points Promotion (including, without limitation, by or through use of customer research, profiling, surveys, or other statistical tools);

b.    Provision of the relevant services of Carbon Wallet and/or the Participants on or through the Application to Registered Users, including but not limited to the arrangement for delivery services of the relevant products and/or services of the Participants for Registered Users’ redemption of Rewards;

c.    Provision of service information and promotion of relevant products and/or services of the relevant Marketing Subjects of Carbon Wallet and/or any or all of the Participants on or through the Application, including but not limited to the calculation of Carbon Savings and respective conversion into CW Points for the Registered Users, and handle inquiries and contact Registered Users where necessary concerning any of the foregoing matters;

d.    For relevant legal or regulatory compliance purposes, and/or to facilitate and enable protection and enforcement of rights, interests and/or properties of Carbon Wallet and/or our Related Companies; and/or

e.    Other purposes ancillary or directly related to any of the above.

3.    Use and/or Transfer of Personal Data for Direct Marketing

3.1.    We may use and/or transfer your Personal Data for direct marketing of products and/or services of Carbon Wallet and/or the Participants relating to the Marketing Subjects on or through the Application and/or CW Points Promotions, but we cannot do so unless we have received your consent (which includes an indication of no objection) to do so.

3.2.    With your consent, Carbon Wallet shall use your Personal Data (and/or transfer relevant Personal Data to the relevant Participants, if any, where applicable) for direct marketing for or in relation to any or all of the following:

a.    any CW Points Promotions, subject to the applicable Rules of Promotion;

b.    any products and/or services of the relevant Marketing Subjects which may be provided or advertised from time to time by Carbon Wallet and/or any or all of the Participants on or through the Application (including through any Content, any Third Party Materials and/or any Third Party Links/Platforms) and/or under or through any CW Points Promotions, and any related news, rewards, benefits, promotions, offers, notices, notifications, discounts, advertisements and events offered thereunder.

3.3.    If you at any time wish to opt-out from direct marketing, please go to the “Profile” section, select “Direct Marketing” and adjust the settings in the Application accordingly. You may also contact us in writing at:

4.    Disclosure and Transfer of Personal Data

4.1.    We will take all reasonably practicable steps to keep your Personal Data confidential. We may need, for any of the circumstances below, to disclose, transfer or assign your Personal Data to any of the following parties:

a.    any person (including but not limited to government authorities, regulatory or administrative bodies or law enforcement agencies) to whom we are under an obligation to make disclosure under any applicable laws and regulations;

b.    any agent, advisor, auditor, consultant, contractor and/or third party service provider who provides advisory, consultancy, administrative, telecommunications, customer services assistance and support, technology, payment, fraud prevention, insurance, data processing and/or other services to us for, in connection with or with respect to the operation of our relevant businesses and/or who otherwise processes Personal Data for and on our behalf. For avoidance of doubt, we will not share, disclose or transfer your Personal Data to any data brokers for market research, analytics or profiling purposes;

c.    any actual or proposed assignee, transferee or successor of or to our rights in respect of your Personal Data as an asset in connection with a merger or sale or re-organization involving our business or changes in corporate control; 

d.    the relevant data transferees for direct marketing under Section 3.

5.    Third Party Materials and/or Links/Platforms in the Application

5.1.    The Application may contain Third Party Materials and/or Third Party Links/Platforms.  Please refer to those third parties’ privacy policies to protect your own privacy.

5.2.    In the event that we receive your Personal Data (if any) from any of those third parties, we will treat your Personal Data so obtained in the same manner as our own collection, use and handling of your Personal Data subject to the provisions of this PICS.

6.    Use of application settings and usage tools

6.1.    When you access or use the Application, we may use cookies, beacons and/or other available unique application settings and usage tools to identify your device and browsing activities for operating, managing and improving the Application. In order for the Application to work properly, it is not possible to disable these tools. If you do not agree to our use of these tools, you should not use the Application.

7.     Security

7.1.    Except for the data disclosure and transfer scenarios under Section 4, your Personal Data will be accessed only by our authorised personnel and/or authorized contractors. Where Personal Data are stored electronically, they will be kept on a secured server and will be password-protected (or under some equivalent protection) and accessible only by those authorised personnel. Network transmission of Personal Data will be secured. Authorized personnel designated to process and handle Personal Data will be instructed to do so only in accordance with this PICS.

8.    Retention of Data

8.1.    We will keep your Personal Data for as long as necessary to fulfil the aforesaid purposes. Personal Data which is no longer required will be destroyed or anonymised as soon as practicable, unless their retention is required to satisfy any applicable legal, regulatory or accounting requirements or to protect Carbon Wallet’s interests. 

9.    Questions and Complaints 

9.1.    You have the right at any time to request access to and/or correction of your Personal Data held by us. You may also request us to unsubscribe you from any active mailing or distribution lists. If you want to make such a request or have any questions or complaints about our privacy policies, please contact us at or through the address below:

Carbon Wallet Company Limited
Address: 7/F, MTR Headquarters Building, Telford Plaza, Kowloon Bay, Kowloon, Hong Kong
Attention: Personal Data Privacy Officer
(Marked Confidential and "Carbon Wallet / CW Points Promotions")

Version: 17 June 2022

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