A. Commitment to Personal Data Protection
We are committed to protecting your personal data privacy. To ensure that you can make informed decisions and feel confident about providing to us personally identifiable information (Data) relating to you, we outline in this notice the practices of 21st Century Learning International Ltd and the choices you have concerning the collection and use of your Data.
B. The Data We Collect
The types of Data we collect from you will depend on the specific type of services and products as requested by or provided to you for the purposes mentioned below, and may include:
- Your personal information, including your name, gender, date of birth, nationality, passport or other identification number,
- Your contact information, including but not limited to telephone numbers, mailing addresses, email addresses, and fax numbers;
- Your business information, such as, school name and position title.
We may also collect non-personally identifiable information about you, such as, your use of our websites, personal preferences and comments, and responses to promotional offers and surveys.
By providing the Data to us, you acknowledge that such provision is fair and reasonable in the circumstances and we stress that it is not obligatory for you to provide the Data to us. However, if you elect not to provide the Data to us, we may not be able to supply you with the relevant information, services or products.
C. Purposes for which the Data are Collected and Used
We may use the Data you provide for one or more of the following purposes (for our policy on using and sharing your personal data for promotional and marketing purposes, please see section E. Use and Transfer of Data for Direct Marketing Purposes):
- For the supply of any other products and/or services that we may offer to you or you may require from us from time to time;
- For payment purposes for such information, services or products;
- For use of the online services available at any of our websites and/or through other telecommunication channels;
- For identification and verification purposes in connection with any of the services or products that may be supplied to you;
- For reserving places on training courses or at conferences with or through us;
- For communicating with you by email, mail, fax, phone or other means;
- For the use of any of our subsidiaries, associate companies and/or business associates in connection with any of the above purposes and/or any of the services such companies and associates may be offering to you from time to time; and/or
- For any other incidental or associated purposes relating to the above and any other purpose which a customer or a service recipient may from time to time agree.
We will not knowingly or intentionally use, share, sell or rent the Data provided to us in ways unrelated to the purposes aforementioned.
D. Disclosure and Transfer of Personal Data
We may disclose and transfer the Data to our subsidiaries, associated companies and/or business associates and other persons who we consider appropriate in connection with the services and products provided or to be provided to you and/or otherwise relating to the purposes mentioned above. Otherwise, we will not disclose or transfer the Data to other parties.
The Data you provide to us may also be sourced from or transferred to other jurisdictions outside the Hong Kong Special Administrative Region of the People’s Republic of China (Hong Kong) for the purposes mentioned above. We will try to ensure, as far as possible and practicable, that Data sourced or transferred outside Hong Kong is protected to standards in line with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) (the Ordinance), subject to any other requirements and limitations of the particular jurisdiction.
We may disclose the Data when required by law or court order of any jurisdiction, or as requested by any government or law enforcement authorities or administrative organs, or in the good faith that disclosure is otherwise necessary or advisable including and without limitation to protect the rights or properties of 21st Century Learning International Ltd and its subsidiaries and associated companies or in circumstances which we consider to be related to any of the purposes for which the Data are collected. This also applies when we have reason to believe that disclosing the Data is necessary to identify, contact or bring legal action against someone who may be causing interference with our rights or properties, whether intentionally or otherwise, or when anyone else could be harmed by such activities.
E. Use and transfer of Data for Direct Marketing Purposes
In addition to the purposes set out above, with your consent, we intend to use your name and contact details for our marketing, research, promotional and customer relationship management purposes including sending you information relating to 21st Century Learning International Ltd products and services in the following categories: conference promotions, training course promotions, blog and newsletter, events, research and questionnaires about our services, membership programs.
For purposes of direct marketing, we may provide your name and contact details to other companies and marketing or research service providers so that they can send you promotional materials in relation to products and services within the above Classes of Marketing Subject. The materials may be sent to you by postal mail, email or other means.
F. Data Security
We will keep the Data you provide to us by us in the appropriate form only for as long as is necessary to fulfill the purposes mentioned above after which it will be destroyed.
In order to ensure the correct use and to maintain the accuracy of Data collected from you, as well as preventing unauthorized or accidental access, processing, erasure or other use of the Data, we have implemented various physical, electronic and management measures to safeguard and secure the Data we collect.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in future.
Cookies contain information about you and your preferences. For example, it might only contain a record of which pages within the site you visited, to help the site customize the view for you the next time you visit.
Only the information that you provide, or the choices you make while visiting a website, can be stored in a cookie.
For example, the site cannot determine your email name unless you choose to type it. Allowing a website to create a cookie does not give that or any other site access to the rest of your computer, and only the site that created the cookie can read it.
H. Log Files
We may also collect information regarding your IP address, browser type, domain name and access time. This information is used for our own research purposes and as it is not linked to any personal information so is separate from the Data. In rare instances, IP addresses may be used to assist in deterring and/or preventing abusive or criminal activity on the website.
I. Our Commitment to Data Security
To maintain the accuracy of the Data, as well as preventing unauthorized access and ensuring the correct use of the Data, we have carried out appropriate physical, electronic and management measures to safeguard and secure the Data we collect online. We use an industry standard for encryption over the Internet known as Secure Socket Layer (SSL) protocol, to protect the Data. The Data you provide to us will be stored in a database for no longer than is necessary. The website has a firewall in place, which should protect the Data collected from you against unauthorized or accidental access. However, complete confidentiality and security is not yet possible over the Internet, and privacy cannot be assured in your communications to us. You acknowledge that personal information is disclosed at your own risk, and may be subject to unauthorized use by others. This may result in, among others, you receiving unsolicited messages from other parties. We are not responsible in any manner for direct, indirect, special or consequential damages, howsoever caused arising out of the communication of information to us. You are encouraged to protect against unauthorized access to your password details. Make sure you sign out from your account when finished particularly when using a shared computer.
J. Other Websites
In order to anticipate your needs, our websites may contain links to third party sites that are operated under different privacy practices.
All such websites are independent from our websites and we have no control over the contents of such other websites or their privacy policies or compliance with the law, and do not vouch for their security. You should therefore be fully aware the provision of the link does not constitute an endorsement, approval, or any form of association by 21st Century Learning International Ltd. You should therefore remain alert when you leave our site, and read the privacy statements of other websites. We have no control over Data that is submitted to these third parties. You access the data on such websites at your own risk.
K. Your Choice
You always have ultimate choice and control over the type of information you would like to receive from us. When you use our online services or receive our promotional materials, you will have the chance to indicate your choice to receive, or not to receive in future, promotional materials from us or associated companies and/or business associates. With your consent, we will occasionally send you updates about our latest products and services, as well as special offers. Should you decide not to receive any updates from us, feel free to cancel your subscription to these services by contacting us via the contact information provided on the websites or as indicated in the relevant materials.
L. How to Access or Correct Your Data or Contact Us
You are entitled to access or correct any Data relating to you held by us. If you wish to obtain a copy of any of your Data or if you believe that the Data relating to you which we collect and maintain is inaccurate, please write to us at the address below.
A request for access to Data, correction of Data, or for information regarding policies and practices and kinds of Data held by 21st Century Learning International Ltd may be sent to us at the following address:
The Privacy Compliance Officer
21st Century Learning International Ltd
1003 Malaysia Building, 50 Gloucester Road, Hong Kong
In accordance with the terms of the Ordinance, we have the right to charge a reasonable fee for the processing of any data access request.
You may access and obtain a copy of our Data Privacy and Security Policy Statement, as amended from time to time at www.21c-learning.com so that you are always informed of the way we collect and use the Data.
This notice is in compliance with the Ordinance.
It is written in the English language and may be translated into other languages. In the event of any inconsistency between the English version and the translated version of this notice, the English version shall prevail.