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This policy (together with any other documents referred to in it) sets out the basis on which any personal information and data provided by the relevant users of the Site (whether registered or not) (“Users”) to us via the MAST Education Website and MAST Education services and any associated software experiences as a whole (collectively, "MAST" or the “Application”) will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
1 Information and Personal Data Collection
1.1 In order to provide a better service to Users, we may collect and process the following data about Users:
(a) information that Users provide by filling in forms on our site http://www.masteducation.com (www.masteducation.com also includes all affiliated webpages under the domain www.masteducation.com) (“our site”). This includes information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services. We may also ask Users for information at other times, for example in connection with a promotion or when Users report a problem with our site;
(b) if Users contact us, we may keep a record of that correspondence;
(c) we may also ask Users to complete surveys that we use for research purposes, although Users do not have to respond to them;
(d) details of Users’ visits to our site and the resources that Users access.
1.2 We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists. If a User who has become a tutor listed on the Application (“Tutor”) is inactive for a period of 4 or more years, Tutor’s data will be deleted.
2 Purpose of Collection and Use of Personal Data
2.1 The purposes for which information and data submitted by Users may be used by us in and outside the Hong Kong Special Administrative Region (“Hong Kong SAR”) include:
(a) ensuring that content from our site is presented in the most effective manner for Users and for Users’ computer;
(b) providing Users with alerts, newsletter, education materials or information that Users requested or signed up to;
(c) carrying out our obligations arising from any contracts entered into between Users and us;
(d) allowing Users to participate in interactive features of our service, when Users choose to do so;
(e) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision of our products and services;
(f) complying with laws and regulations applicable to us or any of our affiliates in or outside the Hong Kong SAR;
(g) legal proceedings, including collecting overdue amounts and seeking professional advices;
(h) researching, designing and launching services or products including seminars/events/forums;
(i) promoting and marketing services and products subject to Users’ exercise of the opt-out right (please see further details in paragraph 2.2 below); or
(j) purposes directly related or incidental to the above.
2.2 We intend to use Users’ data in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
(a) Users’ name, contact details (including address, contact number, email address), products and services information, transaction pattern and behavior, background and demographic data held by us from time to time may be used by us in direct marketing;
(b) the following classes of services, products and subjects may be marketed in direct marketing:
(i) services and products related to our site and/or our affiliates (including marketing affiliates programs we are a part of);
(ii) reward, loyalty or privileges programmes, promotional offers and related services; and
(iii) invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
(c) We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to Users. Users may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
3 Disclosure of Users’ Personal Data
3.1 We will keep the personal data we hold confidential but may provide information to:
(a) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services;
(b) our overseas offices, affiliates, business partners and counterparts (if any);
(c) persons under a duty of confidentiality to us;
(d) persons to whom we are required to make disclosure under applicable laws and regulations in or outside the Hong Kong SAR, including government taxation office’s enquiry relating to Tutors’ earning; or
(e) actual or proposed transferees or participants of our services in or outside the Hong Kong SAR.
4.1 All information you provide to us is stored on secure servers. Where we have given Users (or where you have chosen) a password which enables you to access certain parts of our site, Users are responsible for keeping this password confidential. We ask Users not to share a password with anyone.
4.2 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect Users’ personal data, we cannot guarantee the security of Users’ data transmitted to our site; any transmission is at Users’ own risk. Once we have received Users’ information, we will use strict procedures and security features to try to prevent unauthorized access.
6 Data transfers
We may hold Users’ data on servers in the Hong Kong SAR and any other territories as we see fit from time to time. We may also transfer Users’ data to our overseas offices or to any party listed in paragraph 3.1 above, who may be located in or outside of the Hong Kong SAR.
7 Your consent and rights
7.1 By using our service, submitting an application [M1] or visiting our website, Users’ consent to the collection and use of Users’ information and other activities as outlined in this policy.
7.2 Under the Hong Kong Personal Data (Privacy) Ordinance (the "Ordinance"), Users have the right:
(a) to check whether we hold personal data about Users and to access such data;
(b) to require us to correct as soon as reasonably practicable any data relating to Users which is inaccurate;
(c) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and
(d) to object to the use of Users’ personal data for marketing purposes and we shall not use Users personal data for marketing purposes after Users communicate Users objection to us.
7.3 Users may exercise Users’ opt-out right by notifying us if Users wish to object to the use of Users’ personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to:
Michael Ho, MAST Education Limited
Rm 1104 Crawford House, 70 Queen's Rd. Central, Central, Hong Kong
7.4 In accordance with the terms of the Ordinance, we have the right to and may charge a reasonable fee for processing any data access request.
8 Governing law and jurisdiction
Last updated: October 3, 2016