Privacy Policy

What Data We Collect

We collect personal data in limited circumstances, only when you voluntarily provide it or when it is generated through standard website operation.

Information you provide directly:

• Name and email address (submitted through our contact form)
• Phone number (optional, if provided in the contact form)
• Enquiry content and any background information you share voluntarily
• Payment details (processed through our bank or FPS at the time of enrolment — we do not retain card details)

Information collected automatically:

• Standard website access logs (IP address, browser type, pages visited)
• Cookie data, as described in our Cookie Policy

How We Use Your Data

We use personal data for the following purposes, and no others:

• Responding to enquiries you submit through our contact form
• Managing programme enrolments and communicating relevant logistical information
• Sending information about upcoming cohorts, where you have indicated interest
• Complying with applicable legal and regulatory requirements
• Improving the performance of our website through aggregated, non-identifiable analytics

We do not use your personal data for automated decision-making or profiling.

Legal Basis for Processing

Under the PDPO, we rely on the following grounds when handling your personal data:

• Consent — when you submit our contact form or agree to cookies
• Contractual necessity — to manage your programme enrolment
• Legitimate interest — to maintain secure website operation and improve our services
• Legal obligation — where required by Hong Kong law

Data Retention

We retain personal data only for as long as necessary for the purposes for which it was collected:

• Enquiry records: up to 12 months after last contact, unless enrolment follows
• Enrolment records: up to 7 years, to comply with business record requirements under Hong Kong law
• Website logs: up to 6 months in standard server logs

Data Sharing

We do not sell, trade, or rent personal data to third parties. We share data only in the following limited circumstances:

• Service providers — companies that help us operate our website (hosting, analytics) under data processing agreements
• Legal requirements — where disclosure is required by Hong Kong law or regulatory authority

Third-party services we may use include Google Analytics (website analytics) and standard email service infrastructure. These providers operate under their own privacy policies.

Data Security

We maintain reasonable technical and organisational measures to protect personal data from unauthorised access, use, or disclosure. These include secure server infrastructure, access controls limited to authorised staff, and routine review of security practices. In the event of a data breach that affects your personal data, we will notify you in accordance with applicable PDPO requirements.

Cookies

We use cookies to help our website function and to understand how visitors use it. You can manage your cookie preferences at any time. For full details, please see our Cookie Policy.

Your Rights Under the PDPO

Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate personal data
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days as required by the PDPO.

Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

Children's Privacy

Our programmes are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently received such data, please contact us so we can delete it promptly.

Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via a notice on our website. The "Last Updated" date at the top of this page reflects the most recent revision. Continued use of our website following any update constitutes acceptance of the revised policy.

Contact

For questions or requests related to personal data, contact our data privacy contact: