1. HK Learning Skills Association Limited (“HKLSA”) pledges to meet and comply with the requirements of the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong) (“Ordinance”). In doing so, HKLSA has committed itself to protect and keep in strict confidence any personal data (as defined below) collected.
2. This Statement is important and should be read thoroughly in order to understand the privacy policies of HKLSA in respect of any personal data it collects from you, as a data subject (as defined below).
3. HKLSA may amend, update, vary or add to this Statement from time to time without any prior notice as necessary and any revised Statement will be published on this website.
4. By accessing and using this HKLSA’s website and any of its pages, you are agreeing to the terms and conditions set out herein.
5. If there is any inconsistency between the English version and the Chinese version of this Statement, the English version shall prevail.
Type of Personal Data
6. The term “personal data”, wherever mentioned in this Statement, includes the following kind of information:
a. All the data which may be collected or held by HKLSA from time to time in connection with the registration and establishment of user’s account or the use or continuation of provision of educational services, products and facilities, the following data relating to a data subject (including any updated data of any of the following data):
i. full name;
ii. date of birth;
iii. correspondence address and/or residential address;
iv. e-mail address;
v. telephone number;
vi. fax number;
vii. Hong Kong Identity Card Number or travel document number;
viii. school name;
ix. class code; and
x. information as referred to in the paragraphs below under ‘Cookies, Domain Names and IP Addresses’.
b. Information collected through computer technologies by third parties whom HKLSA works with to find out more about users of HKLSA’s website, including number of the visitors, behaviour and usage patterns, for more accurate reporting and to improve the effectiveness of marketing of HKLSA.
c. Other data collected from data subjects in the ordinary course of the continuation of the relationship between HKLSA and data subjects such as the followings:
i. when a data subject uses HKLSA’s website;
ii. when a data subject register to conduct on-line shopping activities through any of HKLSA’s website;
iii. when a data subject submits any work or statement through HKLSA’s website;
iv. when a data subject takes part in any activities published by HKLSA on its website or other website linked to HKLSA’s website;
v. when a data subject makes a purchase or obtains a product or service introduced or referred to by HKLSA on its website (except for any online payment);
vi. when a data subject enters into, uses and/or makes a comment on a discussion board, blog or similar forum established on HKLSA’s website; and
vii. when a data subject participates in online activities as published on HKLSA’s website including learning software, online learning games, competitions, assessments, exercises and other online activities as published from time to time.
7. The term "data subject(s)", wherever mentioned in this Statement, includes the following categories of individuals:-
e. Users of HKLSA’s website; and
f. Users of education related services and products so forth provided by HKLSA or its partners.
8. For the avoidance of doubt, "data subjects" shall not include any incorporated bodies. The contents of this Statement shall apply to all data subjects and form part of any contracts for services that the data subjects have or may enter into with HKLSA from time to time. If there is any inconsistency or discrepancy between this Statement and the relevant contract, this Statement shall prevail insofar as it relates to the protection of the data subjects' personal data. Nothing in this Statement shall limit the rights of the data subjects under the Ordinance.
Cookies, Domain Names and IP Addresses
10. “Cookies” are small bits of information that are automatically stored in your computer hard drive which can be retrieved by this website.
11. Cookies can make the site more useful by storing information about your preferences on particular websites and thus enabling HKLSA as website owners to provide more useful features for its users. The information collected by cookies is anonymous aggregated research data, and contain no name or address information or any information that will enable anyone to contact you through telephone, e-mail or any other means. Most web browsers are initially set to accept cookies and if you would prefer, you can disable the functionality of cookies. However, by disabling cookies, you may not be able to take full advantage of HKLSA’s website.
12. Every time you log on to this website, HKLSA will, through its network servers, automatically collect your domain name and IP address for the purpose of verification and HKLSA will use such data for visitor flow statistical and data analysis.
Collection of Personal Data
13. From time to time, it is necessary for the data subjects to supply HKLSA with personal data in connection with the registration and establishment of user’s account or the use or continuation of provision of educational services, products and facilities.
14. HKLSA may work with third parties that use applications or computer technologies to find out more about users of HKLSA’s website.
15. Failure to supply such personal data may result in HKLSA being unable to register and establish a user account or use or continue the provision of educational services and products and facilities.
Protection of Children under the age of 18
16. Data subjects who are under the age of 18 must obtain permission from their parents or legal guardians before providing any personal data to HKLSA.
Purposes of Use of Personal Data Collected
17. The purposes for which the personal data relating to the data subjects may be used will vary depending on the nature of the data subjects' relationship with HKLSA, they may include the following:
a. assessing the merits and suitability of the data subjects as actual or potential applicants for educational services, products and facilities;
b. conducting statistical and data analysis;
c. allowing a purchase or an obtaining of a product or service introduced or referred to by HKLSA;
d. communicating with data subjects or its authorised;
e. enabling HKLSA to ensure smooth operation of the products, services and facilities provided to the data subjects, and to improve, optimize and configure the services for the data subjects;
f. researching and/or designing and/or implementing education related services, products and facilities;
g. marketing services, products and other subjects (please see further details related to ‘Direct Marketing’ below);
h. conducting, or allowing to be conducted, research on usage and activities on parts of HKLSA’s website including number of visitors, behaviour and usage patterns, for more accurate reporting and to improve the effectiveness of marketing of HKLSA;
i. performing investigation or inquiry of any illegal conduct;
j. complying with obligations, requirements, arrangements or procedures that apply to HKLSA or that it is expected to comply according to:
i. any law binding or applying to it within the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future;
ii. any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies within Hong Kong existing currently and in the future; and
iii. any contractual obligations or other commitment applying to it under any contractual arrangement HKLSA has with its agent, representative, contractor, business partner or other third party which HKLSA has entered into a contractual relationship with;
k. maintaining an usage or purchase history or pattern of data subjects for HKLSA to evaluate into future opportunity in education products, services and facilities; and
l. purposes incidental, associated or relating to any of the above items (a) to (j).
Transfer of Personal Data Collected
18. Personal data held by HKLSA relating to data subjects will be kept confidential but HKLSA may provide and disclose (as defined in the Ordinance) such personal data to the following parties for the purposes set out in the previous paragraph:
a. any agent, contractor, business partner or other third party which HKLSA works together with in its provision of such service, product or facility, wherever situated;
b. any party that a data subject has initiated a business transaction with or will make a payment to or through;
c. any party to whom HKLSA is under an obligation or otherwise required to make disclosure under the requirements of any law binding or applying to it within or outside Hong Kong, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies with which HKLSA is expected to comply, or any disclosure pursuant to any contractual or other commitment of HKLSA, all of which are within Hong Kong and may be existing currently and in the future;
d. such party as authorized to receive a response from HKLSA in accordance with Part V of the Ordinance; and
Storage of Personal Data and Security
19. All personal data collected from data subjects will be stored in secure servers of HKLSA in order to prevent any unauthorized or accidental access, processing or erasure.
20. HKLSA maintains this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure personal data.
21. HKLSA will take all practical steps to ensure that personal data will not be kept longer than necessary and HKLSA will comply with all statutory and regulatory requirements of Hong Kong concerning the retention of personal data.
22. While HKLSA does everything it can to protect personal data from unauthorized use, processing and disclosure, data subjects should take precaution not to share, provide or facilitate unauthorized use of an unique username and/or password assigned by HKLSA or allow access or use of it by others. If, in the unlikely event, unauthorized transactions have been discovered through no fraud, fault or negligence on the part of data subjects, the data subjects should inform HKLSA immediately.
23. HKLSA intends to use the data subject's data in direct marketing and HKLSA requires the data subject's consent (which includes an indication of no objection) for that purpose.
24. The specific requirement regarding data subject's consent (which includes an indication of no objection) under Part VIA of the Ordinance shall take effect on 1st April 2013. In this connection, please note that:-
a. the name, contact details, product and services portfolio information, usage pattern and demographic data of the data subject held by HKLSA from time to time may be used by HKLSA in direct marketing and the following classes of services, products and subjects may be marketed:
i. education related services, products and facilities;
ii. co-branding partners of HKLSA for a particular service, product or facility which can be found on HKLSA’s website as the case may be; and
b. other than marketing the above services, products and subjects itself, HKLSA does not intend to provide any personal data to all or any of the persons described in paragraph 18 for use by them in direct marketing, and HKLSA requires the data subject’s written consent (which includes an indication of no objection) for that purpose.
25. If a data subject does not wish to receive any marketing and other promotional materials from HKLSA, a data subject can always have an opportunity to opt-out by email to firstname.lastname@example.org . HKLSA will then, at no cost to the data subject, act on the request to opt-out within 21 days and ensure that the data subject will not included in future direct marketing promotions.
Rights of Access or Correction of Personal Data
26. In accordance with the terms of the Ordinance, HKLSA has the right to charge a reasonable fee for the processing of any data access request. Any data access request must be made in writing and with completed form as prescribed under the Ordinance.
27. The persons to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of personal data held are to be addressed is as follows:
HK Learning Skills Association Limited
11B, Centre 600, No. 82 King Lam Street, Lai Chi Kok, Kowloon.
Tel: 2324 1180