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

This PICS sets out the policy of Carbon Wallet Company Limited (“Carbon Wallet” or I, me, my, mine, myself) for handling personal data collected and used for registered users (“Users” or you, your, yours, yourself, yourselves) of the Carbon Wallet mobile application (“App”) and Carbon Wallet promotion programmes (“Programmes”) under which Carbon Wallet Points (“CW Points”) are awarded to Users which can be redeemed for rewards (“Rewards”). Unless otherwise defined here, any capitalized terms in and terms of this PICS shall adopt the same definitions and rules of interpretation contained in Carbon Wallet’s “Terms and Conditions of CW Points Promotion Programmes”. In the event of any conflicts or inconsistencies between the different language versions of this PICS, the English version should prevail. By providing your personal data to me, 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 me, you should: (a) neither use the services or functions of the App nor participate in the Programmes or (b) access the App as a “guest” user not able to participate in the Programmes or earn CW Points. I may update this PICS from time to time by posting the updated version on the App 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 App. To enable me to provide you with a license to use the App and to participate in the Programmes, be awarded CW Points and provide you with Rewards (“Services”) to you, you agree that I can collect, hold, process and use your personal information and other information (“Required Information”). If you do not agree to provide the Required Information to me, I may not be able to provide you with the Services you request. If you choose to register and use the App and Services, the personal data collected by or in connection with the App would include:

1.1.1    Mandatory data (or Required Information):    Device information (e.g. operating system and mobile device identification number);    Name;    Gender;    Mobile number;    Email address;    Settings and usage of the App (e.g. cookies, browsing histories);    IP (internet protocol) address and domain name; and    If you elect to participate in the Octopus payment option or the Earning CW Points from Use of MTR Transportation Services Programme or both, your Octopus Card number to link to your Carbon Wallet account to have the Octopus system report eligible transactions to me.


1.1.2    Voluntary data:    Access of current geo-location of your device;    Month and year of birth; and    District of your residence.


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

1.4.    Users registered for a Programme will be permitted to participate in the Programme to earn CW Points and the related Rewards, subject to the applicable Terms and Conditions for that Programme. Users registered for a Programme may voluntarily disclose, and I may collect or obtain, the following types of personal data that they submit to the App or to any participants connected with their eligible green activities under or related to Programme (such as a merchant, university or agency participating in or sponsoring a Programme or facilitating the reporting of eligible transactions; “Participants”) or to both:

1.4.1     Photograph proof and information to record eligible recycling activities at the designated recycling points;
1.4.2    Scanned receipts submitted as proof of eligible green activities at the designated restaurants or stores as defined by Carbon Wallet;
1.4.3    Scanned QR codes submitted after completing eligible green activities at the designated restaurants or stores or events as specified by Carbon Wallet;
1.4.4    As available, scanned QR codes submitted at water dispensary stations provided by Participants;   
1.4.5    Scanned QR codes submitted after completing eligible recycling activities at smart recycling bins as specified by Carbon Wallet;
1.4.6    Record of eligible activities and CW Points data through system integration with the relevant Participants’ database;
1.4.7    Apple Heath or Google Health step counting data; and
1.4.8    Address and contact information provided for delivery of products, services or some combination of them offered by the Participants for Rewards redemption.

If you link your Octopus card with the App to earn CW Points for eligible trips on the MTR Corporation Limited (“MTR”) rail network, I may collect more of your personal data as follows:

1.4.9     Octopus card identification numbers; and
1.4.10    Trip records on the railway network of MTR in Hong Kong (i.e. MTR’s 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).


I may collect more of your personal data if you link (or bind) your Octopus card with the App to participate in the Octopus payment option. The additional personal data is your Octopus Card number which needs to be linked to your Carbon Wallet account so the Octopus system can provide me with reports on your eligible transactions paid for with Octopus. 

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 activities 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 and consent from those persons for your use and submission of their personal data and eligible green activity records for my handling and use of their personal data and records in accordance with the terms of this PICS.  If you have not obtained such permission and consent, please do not provide me with any personal data and records of those persons. You must remain responsible for your collection, handling and disclosure of the personal data of those other persons. For the purpose of this PICS, references to “your personal data” should include any personal data of any other persons that you may from time to time provide to me under or in connection with the App, the Programmes, Reward redemptions or any combination of them.

1.5.    If you fail to provide us with accurate and complete personal data marked as mandatory above, I may not be able to process your User registration, or provide the relevant information, products or services to you in the App or the relevant Programmes, or some functions of the App may be unable to fully or properly operate. 

2.    Purposes for use of personal data

2.1.    I may collect, obtain, process, access, use, store or handle (or any combination of them) personal data for any of the following purposes:

2.1.1    Provision, operation, administration, management and improvement of the App, Programmes or any combination of them (including by use of customer research, profiling, surveys, or other statistical tools);
2.1.2    Provision of the relevant services of Carbon Wallet, the Participants or any combination of them on or through the App to Users, including the arrangements for delivery of the Participant’s products, services or both as required to satisfy Users’ redemption of Rewards;
2.1.3    Provision of service information and promotion  of relevant products, services or both of Carbon Wallet, the Participants or any combination of them on or through the App. Such service information may include the calculation of Carbon Savings and its respective conversion into CW Points for Users. The Participants or I may need to access such information to handle inquiries and contact Users where necessary concerning any of the above matters;
2.1.4    For Carbon Wallet’s and its parent companies’    relevant legal or regulatory compliance purposes;
2.1.5    To facilitate and enable protection and enforcement of Carbon Wallet’s and its parent companies’ rights, interests, properties or any combination of them; and
2.1.5    Other purposes ancillary or directly related to any of the above.


3.    Use and transfer of personal data for direct marketing

3.1.    I must receive your consent (which includes an indication of no objection) before I may use, transfer or both use and transfer your personal data for the direct marketing of products or services (or some combination of them) of Carbon Wallet or the Participants (or some combination of them)   on or through the App or Programmes (or some combination of them).

3.2.    With your consent, Carbon Wallet may (a) use your personal data, (b) transfer your relevant personal data to the relevant Participants, if any, where applicable, or (c) both use and transfer your personal data for direct marketing for or in relation to any of the following:

3.2.1       any Programme, subject to the applicable Terms and Conditions; 
3.2.2.    any products, services or any combination of them which may be provided or advertised from time to time by Carbon Wallet, the Participants or any combination of them on or through the App (including through any third-party materials, any third-party links or platforms or any combination of them), under or through any Programmes or any combination of the App and Programmes; and
3.2.3    any related news, rewards, benefits, promotions, offers, notices, notifications, discounts, advertisements and events offered on, under or through the App, Programmes or any combination of the App and Programmes.

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 App accordingly. You may also contact me in writing at:

4.    Disclosure and transfer of personal data

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

4.1.1    any person (including government authorities, regulatory or administrative bodies or law enforcement agencies or stock exchanges) to whom I am under an obligation to make disclosure under any applicable laws, regulations or rules;
4.1.2    any agent, advisor, auditor, consultant, contractor, third-party service provider or any combination of them who provides advisory, consultancy, administrative, telecommunications, customer services assistance and support, technology, payment, fraud prevention, insurance, data processing, order fulfillment, multi-channel customer service and marketing automation platform or other services to me for, in connection with or with respect to the operation of my relevant businesses or who otherwise processes personal data for and on my behalf. I will not share, disclose or transfer your personal data to any data brokers for market research, analytics or profiling purposes;
4.1.3    any actual or proposed assignee, transferee or successor of or to my rights in respect of your personal data as an asset in connection with a merger or sale or re-organization involving my business or changes in corporate control; and 
4.1.4    the relevant data transferees for direct marketing under Section 3.


5.    Third-party materials, links and platforms in the App

5.1.    The App may contain third-party materials and third-party links and platforms.  Please refer to those third parties’ privacy policies to protect your own privacy.

5.2.    In the event that I receive your personal data (if any) from any of those third parties, I will treat your personal data so obtained in the same manner as my 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 App, I may use (either separately or in some combination) cookies, beacons and other available unique application settings and usage tools to identify your device and browsing activities for operating, managing and improving the App and Programmes. Some of these tools are required in order for the App to work properly. You may not disable these mandatory tools. If you do not agree to my use of these mandatory tools, you should not use the App. Some of the tools are optional, and you may opt out of using (or not give your consent to my use of) the optional tools. 

7.     Security

7.1.    Except for the disclosure and transfer of personal data permitted under Section 4, only by our authorised personnel and/or authorized contractors will access your personal data. Any personal data stored electronically will be kept on a secured server and will be password-protected (or under some equivalent protection) and accessible only by authorised personnel. Network transmission of personal data will be secured. Authorised 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.    I will keep your personal data for as long as necessary to fulfil the purposes detailed above. 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 legitimate interests. 

9.    Questions and Complaints 

9.1.    You have the right at any time to request access to and correction of your personal data held by me. You may also request me 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 my privacy policies, please contact me 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 Programmes")

Version: 8 February 2024

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