Website Privacy Notice

This privacy notice sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us in connection with your use of this website and our services, including any data you may provide when you register for our online and offline courses. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

This website is not intended for children and we do not knowingly collect data relating to children.

1. Important information and who we are

Oriental Wisdom Academy for Business Co., Limited, a company registered in Hong Kong with company number 78485250 and whose registered office is at Room B, I/F., Nelson Court, 45 Waterloo Road, Mong Kok, Kowloon, Hong Kong (OWA, we, us or our in this notice) are committed to protecting and respecting your privacy. OWA is the controller and is responsible for your personal data. If you have any questions about this privacy notice, please contact us using the information set out in the contact details section.

2. The types of personal data we collect about you

Personal data means any information that can be used to identify directly or indirectly a specific individual.

We may collect, use, store and transfer different kinds of personal data about you. What information we collect will depend on which of our services you use. The information we may typically collect is as follows:

For our customers attending online or offline courses

  • Identity Data includes first name, last name, any previous names, username or similar identifier, marital status, title, age, date of birth, gender, name and number of your ID card.
  • Contact Data includes billing address, home address, location (country, province, city), email address and telephone numbers, including mobile number, as well as the name and mobile number of your emergency contact, and their relationship to you.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments from you and other details of your purchases from us.
  • Professional Data includes details such as your company name, size, main business and revenue scale, your job title, your industry, the number of your direct and indirect subordinates in the company, your professional specialisms, membership of any professional bodies, your highest educational attainment and the name and major of the relevant institution.
  • Course Registration Data includes your current and future course registration information, including your reasons and expectations for applying for the course, your main experiences of personal growth and obstacles faced, your preferred religious belief/school of thought, any special requests made, any previous medical history including information relating to any accessibility requirements or disability.
  • Profile Data includes your username/membership details and password for any account you have set up with us via our website, your interests, preferences, feedback and survey responses.

For website users (including customers that use our website)

  • Technical Data includes internet protocol (IP) address, your login information, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website.
  • Usage Data includes information about how you interact with and use our website and services, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs).
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals’ Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Your interactions with us

You may give us your personal data by filling in online forms or by corresponding with us by telephone or email. This includes personal data you provide when you:

  • create an account on our website or update your account information;
  • make a booking;
  • speak at or otherwise participate in one of our courses;
  • subscribe to our service or publications;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or contact us via telephone or email, including when you report a problem with our website. If you do contact us, we may keep a record of that correspondence.

Automated technologies or interactions

As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy for further details.

Third parties or publicly available sources

We will receive personal data about you from various third parties and public sources as set out below:

  • Technical Data is collected from the following types of company:
    • analytics providers such as Google Analytics;
    • advertising networks; and
    • search information providers.
  • Contact, Transaction and Financial Data is collected from providers of technical, payment and delivery services.
  • Identity and Contact Data is collected from publicly available sources such as the website of the organisation for whom you work, the websites of professional bodies of whom you are a member.
  • We may receive personal data about you from the organisation for which you work.

4. How we use your personal data

Legal basis

The law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

  • Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.
  • Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
  • Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.
  • Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you are not an existing customer and subscribe to an email newsletter.

There are special rules about how we can use any data concerning health or your religious or philosophical beliefs. For data concerning health or your religious or philosophical beliefs, in addition to the lawful bases outlined above, we must also comply with an Article 9 UK GDPR condition. In the sections below we have set out the conditions that we rely upon when processing these types of data.

Purposes for which we will use your personal data

Purpose: To register you as a new customer and create your account

  • Data used: Identity Data, Contact Data, Course Registration Data, Professional Data
  • Legal basis: Performance of a contract with you
  • Article 9 UK GDPR Condition: Article 9(2)(a) with your explicit consent

Purpose: To process your booking request and deliver our services to you

This includes:

  • Manage payments, fees and charges and process transactions
  • Collect and recover money owed to us

Much of this processing is completed by our payment partner, currently PayPal and WooCommerce.

  • Data used: Identity Data, Contact Data, Transaction Data, Professional Data, Course Registration Data, Financial Data, Profile Data
  • Legal basis: Performance of a contract with you; Necessary for our legitimate interests (to deliver our services to customers; and recover debts due to us)
  • Article 9 UK GDPR Condition: Article 9(2)(a) with your explicit consent

Purpose: To manage our relationship with you

This includes:

  • Notifying you about changes to our terms or privacy notice
  • Dealing with your requests, feedback, complaints and queries and providing you with the information you request from us
  • Improving our service to you, including our customer service and technical support, by evaluating feedback and information from you
  • Data used: Identity Data, Contact Data, Course Registration Data, Professional Data, Profile Data, Marketing and Communications Data
  • Legal basis: Performance of a contract with you; Necessary to comply with a legal obligation; Necessary for our legitimate interests (to keep our records updated, manage our relationship with you, improve our services and keep people up to date about our services)
  • Article 9 UK GDPR Condition: Article 9(2)(a) with your explicit consent

Purpose: To enable our suppliers to perform business activities on our behalf and maintain our accounts and records

(e.g. credit card processing, customer support services or market research)

  • Data used: Identity Data, Contact Data, Financial Data, Transaction Data, Course Registration Data, Professional Data, Profile Data, Marketing and Communications Data
  • Legal basis: Necessary for our legitimate interests (to provide customers with services and to enable us to manage our operations)
  • Article 9 UK GDPR Condition: Not applicable.

Purpose: To administer and protect our business and this website

(including troubleshooting, data analysis, testing, statistical and survey purposes, system maintenance, support, reporting and hosting of data)

  • Data used: Identity Data, Contact Data, Course Registration Data, Professional Data, Technical Data
  • Legal basis: Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security and in the context of a business reorganisation or group restructuring exercise); Necessary to comply with a legal obligation
  • Article 9 UK GDPR Condition: Not applicable.

Purpose: To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you

  • Data used: Identity Data, Contact Data, Profile Data, Usage Data, Technical Data, Marketing and Communications Data
  • Legal basis: Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)
  • Article 9 UK GDPR Condition: Not applicable.

Purpose: To use data analytics to monitor, develop and improve our website, our services, customer relationships and experiences and to measure the effectiveness of our communications and marketing

  • Data used: Technical Data, Usage Data
  • Legal basis: Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
  • Article 9 UK GDPR Condition: Not applicable.

Purpose: To send you news, updates, relevant marketing communications, to enable you to partake in a prize draw, competition or survey and make personalised suggestions and recommendations to you about goods or services that may be of interest to you

Based on your Profile and Transaction Data (or, where you are a prospective customer, you have told us you would like our marketing materials). Much of this processing is completed by our third party provider, currently Mailchimp.

  • Data used: Identity Data, Contact Data, Profile Data, Transaction Data, Course Registration Data, Professional Data, Technical Data, Usage Data, Marketing and Communications Data
  • Legal basis: Necessary for our legitimate interests (to carry out direct marketing to our customers or those who have expressed an interest in our services, develop our services and grow our business); For other individuals, your prior consent to receiving direct marketing communications
  • Article 9 UK GDPR Condition: Not applicable.

Purpose: To comply with legal or regulatory requirements

This includes:

  • Complying with legal or regulatory requirements, which may be set out in law or a court order
  • Assisting regulators or comply with their guidance
  • Exercising our rights or defend legal claims
  • Data used: Identity Data, Contact Data, Profile Data, Transaction Data, Course Registration Data, Professional Data, Technical Data, Usage Data, Marketing and Communications Data
  • Legal basis: Necessary for our legitimate interests (to enforce our legal rights; to co-operate with the regulator and comply with our contractual and other obligations); Necessary to comply with a legal obligation
  • Article 9 UK GDPR Condition: Article 9(2)(f) – necessary for the establishment, exercise or defence of legal claims

Direct marketing

If you are a new customer, during the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from OWA via email.

If you are an existing customer, you will receive marketing communications from us via email with information about services similar to those which were the subject of a previous sale or negotiations of a sale to you, if you have requested information from us or purchased services from us and you have not opted out of receiving the marketing.

We may also analyse your Identity, Contact, Transaction, Technical, Usage and Profile Data to form a view of which services and offers may be of interest to you so that we can then send you relevant marketing communications.

Third-party marketing

We will get your express consent before we share your personal data with any third party for their own direct marketing purposes.

Opting out of marketing

You can ask to stop sending you marketing communications at any time by contacting us in writing using the contact details below or by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences, by following the opt-out links within any marketing communication sent to you.

If you opt out of receiving marketing communications, you will still receive service-related communications that are essential for administrative or customer service purposes for example updates to our Terms and Conditions, or checking that your contact details are correct.

Cookies

For more information about the cookies we use and how to change your cookie preferences, please see [COOKIE POLICY].

5. Disclosures of your personal data

We may share your personal data where necessary with the parties set out below for the purposes set out in the Purposes for which we will use your personal data section above.

  • External third parties including our service providers:
    • that provide us with IT, marketing, customer service and other administrative or technical services;
    • that host our online courses;
    • that provide us with payment processing services.

We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  • Our professional advisors.
  • Courts, tribunals, law enforcement authorities and regulators to comply with our legal obligations or to support them in carrying out their duties.
  • Third parties with which we may negotiate or choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

6. International transfers

We may transfer your personal data to service providers that carry out certain functions on our behalf, such as the fulfilment of your booking, the processing of your payment details or the provision of support services. This may involve transferring personal data outside the UK and EU to countries which have laws that do not provide the same level of data protection as UK / EU law. All of our systems are based in Hong Kong.

If we transfer your personal data out of the UK and EU to countries which have laws that do not provide the same level of data protection as the UK / EU law, we always ensure that a similar degree of protection is afforded to it. We do this by either ensuring the receiving country has been considered to provide an adequate level of protection for personal data by the UK government, or by ensuring that approved contractual safeguards are in place to ensure that adequate protection is in place.

7. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

We will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information. We typically retain data for a maximum of 7 years.

9. Your legal rights

You have a number of rights under data protection laws in relation to your personal data.

You have the right to:

  • Request access to your personal data (commonly known as a “subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data in certain circumstances. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your right to object.
  • You also have the absolute right to object any time to the processing of your personal data for direct marketing purposes (see Opting out of marketing in paragraph 4 for details of how to object to receiving direct marketing communications).
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data (see the table in paragraph 4 for details of when we rely on your consent as the legal basis for using your data). However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in one of the following scenarios:
    • If you want us to establish the data’s accuracy;
    • Where our use of the data is unlawful but you do not want us to erase it;
    • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
    • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

If you wish to exercise any of the rights set out above, please contact us – see Contact details in paragraph 10.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all valid requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Contact details

If you have any questions about this privacy notice or about the use of your personal data or you want to exercise your privacy rights, please contact us in the following ways:

  • Email address: info@ow-academy.com
  • Postal address: Room B, I/F., Nelson Court, 45 Waterloo Road, Mong Kok, Kowloon, Hong Kong

11. Complaints

Hong Kong

You have the right to make a complaint to the Office of the Privacy Commissioner for Personal Data (PCPD), the regulator in Hong Kong for data protection issues PCPD at Unit 1303, 13/F, Dah Sing Financial Centre, 248 Queen’s Road East, Wanchai, Hong Kong.

We would appreciate the chance to deal with your concerns before you approach the PCPD so please contact us in the first instance.

12. Changes to the privacy notice and your duty to inform us of changes

We keep our privacy notice under regular review and may update this privacy notice to reflect changes to our information practices. In that case, the “last updated” at the top of this page will also change. We encourage you to periodically review this page for the latest information on our privacy practices.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address. If you wish to make any changes to your personal data, you can do this by emailing us or by logging into your account online.

13. Third-party links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.