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Privacy Policy

Bluetop Group Limited, its holding company(ies) and its subsidiary(ies) (including Learning Habitat Kindergarten and Bilingual Nursery and Little Habs) (us, we, our or the Group) respect the privacy rights of our clients, customers, employees, visitors, students, their parents/legal guardians (as applicable), vendors, consultants, service providers and other parties who have provided personal data (as defined in the Ordinance) (Personal Data) to us (collectively, Data Subjects). We are committed to protecting the Personal Data by complying with the requirements under the Personal Data (Privacy) Ordinance (Cap. 486) (the Ordinance). This privacy policy (this Policy) is in compliance with the Ordinance as amended and updated from time to time and is applicable to all Personal Data collected by us, whether through this Website or otherwise. Any changes to this Policy will become effective upon posting of the revised policy on this website (this Website). 

Collection of Personal Data

  • We may collect, retain and use necessary but not excessive Personal Data of the Data Subjects, including but not limited to, names, contact details, residential addresses, email addresses, age, gender, passport details or other identification document details, credit card information, bank account details, marital status, income details, education background, video/audio recordings, photographs, biometric data (such as facial images) and any information provided by such Data Subjects (and/or their relevant persons (as defined in the Ordinance) (Relevant Persons) (as applicable)) or in relation to such Data Subjects pursuant to this Policy.
     
  • For the avoidance of doubt, any questions, comments, suggestions or information (other than Personal Data) posted or otherwise submitted to this Website by the Data Subjects will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company in connection with the development and marketing of products and services.

Use of Personal Data

  • Personal Data are collected from the Data Subjects (and/or their Relevant Persons (as applicable)) and are retained and used for the following purposes only. Please note that provision of Personal Data by the Data Subjects (and/or their Relevant Persons (as applicable)) is voluntary. However, if any Data Subject does not agree with any/all of this Policy, he/she must not use this Website. If a Data Subject is under the age of 18, we recommend that such Data Subject seek prior consent from his/her parents/legal guardians (as applicable) before providing us with any of his/her Personal Data.
     

  • The Data Subject’s Personal Data will be used for the following purposes. We will seek prior voluntary and explicit consent from the Data Subjects (and/or their Relevant Persons (as applicable)) if the Personal Data of the relevant Data Subjects shall be used for any other new purposes:

    1. for operation, protection, enhancement, improvement and optimisation of our services (e.g. provision of classes, courses and products by us);
    2. for provision of employment and/or employment training related services and support;
    3. for our daily operations (e.g. to process application forms and to process payments/refunds);
    4. for our internal control and administration purposes relating to the general operations;
    5. for facilitation of our communication and maintaining relationships with our students, alumni and/or their parents/legal guardians (as applicable) (e.g. organising school and alumni activities, uploading photos/videos containing images of students taking part in school activities, storing information of students and their parents/legal guardians (as applicable) in online portals); 
    6. for promotion of the Group through our website(s), social media accounts and other publication and/or communication platforms (including creation of materials for this purpose);
    7. for security purposes (e.g. protection of safety of students, record keeping and facial verification for school campus access (subject to other arrangements as agreed between any Data Subject and us));
    8. for statistical and research purposes (e.g. to analyse and compile statistical data);
    9. for provision of assistance to third party(ies) for the protection of third party(ies)’ rights;
    10. for our compliance with legal obligations, for resolving legal disputes or otherwise for enforcement and protection of our legal rights;
    11. subject to the prior consent of the Data Subjects and compliance with the Ordinance, for provision of promotion and/or marketing information (e.g. new courses and products provided by us or other third or related parties); and
    12. for any other purposes relating directly to any of the aforementioned purposes.
     

  • Notwithstanding the purposes set out above, we may collect Personal Data (including but not limited to images, footage and sounds) through CCTVs (which will not be installed in places where individuals would have a reasonable expectation of privacy (e.g. bathrooms and changing rooms)) for the following security purposes only:
    1.    for protection of safety of individuals (in particular, our students);
    2.    for prevention and deterrence of criminal or inappropriate activities;
    3.    for investigation of alleged or suspected incidents; 
    4.    for protection of our properties; and
    5.    for any other purposes relating directly to any of the aforementioned purposes.

Transfer of Personal Data

  • We may make certain Personal Data available among the Group for the purposes as stated in this Policy. By accepting this Policy, each Data Subject understands and acknowledges that his/her Personal Data may be disclosed or transferred to any companies within the Group (and their respective employees and representatives (as applicable)) under this Policy.
     
  • Further, we may make Personal Data available to (i) our third party or related service providers, agents or contractors relevant to our products, services, events and activities; (ii) our data storage service providers; (iii) our e-mail service providers for sending promotional and marketing information; (iv) our professional advisors for the safeguarding of our legal and business interests; (v) any purchaser of all or part of the business of the Group and/or (vi) government or regulatory authority (and the respective employees and representatives of the abovementioned (i) to (vi) (as applicable)) for the purposes as stated in this Policy.

Retention of Personal Data

We will take practicable steps to ensure the Personal Data will not be kept longer than it is necessary for the fulfilment of the purposes as mentioned in this Policy. For the avoidance of doubt, we are entitled to retain, process and use for an indefinite term and for any purpose, any information, which albeit derived or processed from the Personal Data, is no longer capable of identifying the Data Subject. 

Data Security

Once we have collected the Personal Data, it will be maintained securely by us. We will take practicable precautions to ensure that the Personal Data held by us or made available to above-mentioned third parties, holding company(ies) or subsidiary(ies) of Bluetop Group Limited are held, stored and protected in compliance with the Ordinance. We will take practicable steps to safeguard Personal Data from unauthorised or accidental access, processing, erasure, loss or use.

Links to other Websites

If any Data Subject clicks on any hyperlink or advertisement linking to other website(s) that is/are provided on this Website, the protection of his/her privacy, Personal Data and his/her exposure to cookies are not our responsibility and such Data Subject is advised to refer to the privacy policy of such other website(s) (if any).

Access and Correction of the Personal Data

  • We will take practicable steps to ensure that the Personal Data are accurate, but it shall be the responsibility of each Data Subject to keep his/her Personal Data updated.
     
  • In accordance with the Ordinance, we provide the Data Subjects (and/or their Relevant Persons (as applicable)) with the right to (i) unsubscribe from all marketing communications; (ii) make a request for removal of their Personal Data from our storage; and/or (iii) request for access and correction of their Personal Data in writing and by sending to our Administrative Executive by email to contact@learninghabitat.org. In order to protect the Personal Data, we will require all Data Subjects (and/or their Relevant Persons (as applicable)) to prove their identities in relation to their requests to remove, access and/or correct their Personal Data. A reasonable administration fee may be charged for any such removal, access and/or correction.

Where there is inconsistency between the English version of this Policy (being the original version) and the Chinese translated version, the English version shall prevail.