*[ Positive Learning Academy for You “PLAY” is a brand of Alpha Expert Limited “ALPHA”. At PLAY website, playacademy.com.hk (“PLAY,” “We,” or “Our”), we are committed to the protection of your privacy and personal information.]
Alpha Expert Limited (“ALPHA”) (“ALPHA”, “we”, “us”, “our”) recognizes and understands that customers, website visitors, and mobile application users are concerned about the privacy of personal data. ALPHA pledges to comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the “PDPO”) of the Laws of Hong Kong Special Administrative Region.
2. Collection of Information
You may be invited to provide to ALPHA your personal data on ALPHA ‘s relevant website(s) or mobile application(s) (if any), or through other media on a voluntary basis for different purposes at different times. If you are under the age of 18, you should obtain consent from your parent or guardian before you provide ALPHA with your personal data.
3. Log Files
Cookies are alphanumeric identifiers that we transfer to your computers, mobile phones or other devices through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate ALPHA’s website(s) or mobile application(s (if any)), while others are used to enable a faster log-in process, or to allow us to store and track information about your interests and preferences at ALPHA’s website(s) or mobile application(s) (if any).
We may also engage third parties to track and analyse non-personally identifiable data from the website(s) or mobile application(s) (if any). We use the data collected by such third parties to help us administer and improve the quality of ALPHA’s website(s) or mobile application(s) (if any) and to analyse usage of the same. This is unrelated to and separate from your personal data. Such third parties may combine the non-personally identifiable data that we provide about you with other information that they have collected. You can edit your browser settings to disable cookies but to do so you may not be able to utilize certain functionality of the website(s) (and/or mobile application(s) (if any) where applicable) of ALPHA.
If you interact with ALPHA on social media platforms (for example if you “Like” ALPHA’s Facebook page), ALPHA can interact with you and send you messages via these platforms. ALPHA will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your personal data. We are not responsible for what third parties post on our social media accounts.
5. Kinds of Information Collected
For the different purposes in the course of conducting ALPHA’s business, you may be required to provide to ALPHA your personal data, which may include your name, gender, age, date of birth, month and year of birth, contact details, e-mail address, mailing/correspondence address, contact number, membership number, marital status, family status, educational level, occupation, username and password, Log Files, Tracking Data, social media account information, etc. Details of personal data to be collected will also be set out in the relevant PICS provided to you on or before collection of such personal data.
6. Purposes and Uses of Personal Data Collected
ALPHA will use your personal data for specific purposes identified in the PICS provided to you on or before your personal data is collected. This includes sharing your personal data with, and your personal data being used by, third parties as set out in our PICS for those purposes.
7. Accuracy of Information
You may be requested to provide to ALPHA certain personal data for specific services. If you fail to provide or update accurate information as requested for each specific service, the provision of such services by ALPHA may be affected.
8. Retention of Information
ALPHA will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are or are to be used. If you are a subscriber of ALPHA services, your personal data will be retained for a reasonable period after termination of your subscription for verification and audit purposes. The above is subject to any legal, statutory, regulatory or accounting requirements.
9. Third Party Merchants
ALPHA may have on-line stores or some services and/or products which are hosted in the website(s) of ALPHA but are operated by third party merchants. If you provide your personal data to the third party merchants in order to use, order or receive any services and/or products from the third party merchants, please note that your personal data is beyond the control of ALPHA and thus is outside the scope of protection afforded by ALPHA.
10. Third Party Websites
11. Service Providers
12. Security of Information
Your personal data may be stored in physical locations and/or servers located within or outside Hong Kong and/or shared with third parties with physical locations and/or servers located within or outside Hong Kong, in each case in accordance with our PICS. However, we will take all reasonable measures to ensure that your personal data is stored and processed securely, regardless of the place or country in which it is stored, and we will procure by contract or use our reasonable endeavours to ensure that any third parties will do the same.
No data transmission over the internet or any other public network can be guaranteed to be completely secure, and privacy cannot be assured in your communications to us. You are encouraged to protect against unauthorized access to your password. You are advised to sign out from your account (if any and applicable) when finished particularly when using a shared computer.
ALPHA may disclose your personal data as required by law, by any government departments, regulatory authorities, enforcement agencies and courts of competent jurisdiction. ALPHA excludes all liability for disclosure of your personal data in this manner.
14. Use in Legal Proceedings etc.
If it becomes necessary for ALPHA to take action against you for recovering from you the debt you owe to ALPHA, you agree that your personal data can be used by ALPHA in identifying and taking legal action against you.
15. Access and Correction of Information and Withdrawal of Consent
You have the right to request in writing to the Personal Data Privacy Officer of ALPHA to:
- check whether ALPHA holds any of your personal data;
- access your personal data held by ALPHA (if any);
- require ALPHA to correct your personal data that is inaccurate (if any); and
- ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us;
- withdraw your consent to the use of your personal data for direct marketing purposes (see below).
All such requests will be handled promptly in accordance with the requirements of the PDPO. ALPHA may charge a reasonable fee for processing your data access request.
16. Direct Marketing
We cannot use or provide your personal data for direct marketing purposes without your consent. Subject to your consent, we may use or provide your personal data for direct marketing purposes in accordance with the PICS provided to you upon collection of your personal data. You may withdraw your consent any time in by writing to the Personal Data Privacy Officer of ALPHA at 30th Floor, New World Tower, 18 Queen’s Road Central, Hong Kong or by email at firstname.lastname@example.org
18. Change of Control
In the event of any actual or proposed transfer of business, transfer of shares, re-structuring, amalgamation, merger, sale, transfer, or purchase of us or our business or our affiliates or our affiliates’ businesses, ALPHA may need to transfer your personal data to the new owner in accordance with our PICS. You will be notified of such transfer and you may decide to withdraw your consent to the use of your personal data.
If you have any questions or wish to access or correct your personal data or withdraw your consent to the use of your personal data held by ALPHA for direct marketing, please contact the Personal Data Privacy Officer of ALPHA at:
30th Floor, New World Tower
18 Queen’s Road Central
Personal Data Privacy Officer (Legal Department)
(Marked Confidential, and with the name ALPHA)
or by email at email@example.com.
20. English Version