Personal Information Privacy Policy

1. Privacy Policy

1.1 This Website www.instalearn.com.hk (" this Website") is owned and operated by Instalearn Education Limited (" the Company", " we" or " us"). We respect personal data and are committed to full implementation and compliance with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486 (" the Ordinance") of Hong Kong as well as the relevant and applicable laws in your country.

1.2 This Privacy Policy is applicable to all users of this Website, including but not limited to all Students and all Tutors, as well as any other persons that their personal data is collected, by whatever means, used and held by us.

1.3 By accessing and/or browsing and/or using and/or logging in and/or signing up and/or requesting any services and/or receiving and experiencing any services and/or dealing in any manners in this Website, you acknowledge that you have read, understood and accepted this Privacy Policy. Should you be under the age of 18, please obtain prior acceptance from your parents or guardians in respect of this Privacy Policy.

2. Kinds of Personal Data Collected, Used and Held

2.1 Only the following personal information and data will be mandatorily collected, used and held by us when signing up in this Website and using the services provided by us, and no data or information other than the following will be collected by us:-

(a)Your name, gender, date of birth, correspondence address, postal code (if applicable), country;
(b)Email address;
(c)Phone number;
(d)Academic institutes you engage(d) in and academic credentials (as a Tutor);
(e)Academic institutes you engage in, your curriculum and grade (as a Student); and
(f)Facebook account and data provided by Facebook (as a Student).

2.2 You may provide us with your personal data at your own will. The above personal data and information are regarding as mandatory. We may refuse your account registration and you will then be unable to have access to the services provided by Instalearn Education Limited

2.3 Other than the above, provision of any other or further data and information is optional, and does not affect your registration or access the services.

3. Purpose of Personal Data to be Collected

3.1 The personal data and information collected from you will be used by the Company for the following purpose: -

(a)Signing Up, Registration and Identification:
(i)To sign in and register a user account on this Website and the mobile application of Instalearn;
(ii)To verify and ascertain your identity; and
(iii)To verify the academic credentials of Tutors.
(b)Payment: To facilitate and process payment from you in respect of your subscription of membership plan(s) (as a Student) and other service(s);
(c)Providing Services: To provide services to you on this Website and/or via the mobile applications of Instalearn Education Limited , and to permit you to participate in other activities on this Website and/or the mobile applications of Instalearn Education Limited , including but not limited to contest, promotions, campaigns, polls and surveys;
(d)For administration, management and technical support: (i)For our internal administration and management, including auditing and internal analysis;
(ii)To communicate with you, provide applicable technical support, receive your comments and handle your complaints; and (iii)To detect, investigate and prevent any fraudulent, prohibited and illegal activities, any misuse of this Website or use of this Website with improper or dishonest motive, and if necessary, to provide or respond to the requests or directions of the courts, enforcement agencies or similar authorities and statutory bodies of your country or elsewhere.
(e)Statistics: to carry out statistics and data analysis to improve and enhance our services and develop our marketing strategies; and
(f)Profiling: To build up your user profile.

4. Transfer of Personal Data within the Group

4.1 For the sake of facilitating us to provide services to you as well as the above purposes, only after obtaining your consent when signing up , may your information and data collected and obtained by Instalearn Education Limited. be used by, shared to and retained by Instalearn Education Limited , which may be situate outside your country. We undertake that all the above subsidiaries, related and/or associated companies will be in strict compliance of this policy and the applicable laws in their countries.

5. Transfer of Personal Data to Third-Party Academic Institutions

5.1 Only after obtaining your consent when signing up , we may provide and share the information and data of Student users under Clause 2 hereinabove on non-personally identifiable, aggregated, statistical and/or anonymous basis to third-party academic institutions, inside and outside your country, for strictly academic, teaching and educational purposes , with or without consideration. Use of the data and information for any otherwise purposes is strictly prohibited.

5.2 At any time, you can check out the list of the third-party academic institutions to which we may share and provide the above data and information on this Website, and their respective privacy policies.

5.3 You have the right to opt out and elect to cease sharing your information and data at any time by informing us of your request by way of email to Info@instalearn.com. We shall effect the cessation of the provision or sharing within 7 days upon receiving your email.

6. Direct Marketing and Promotion

6.1 Only after obtaining your consent when signing up , we may send you by way of email and contact you from time to time to share promotional or marketing information. Promotional and marketing subjects include but not limited to information regarding to promotions and discounts on subscriptions/packages or any new feature introductions.

6.2 Once you have elected to receive marketing and promotional emails, you have the right at any time to elect not to accept by clicking on the "Unsubscribe" link embedded in our marketing and promotional emails received. This does not prejudice you from receiving our other non-marketing and promotional emails to you.

7. Third-Party Marketing and Promotion

7.1 We will not provide or share your information and data to any third parties for marketing or and/or promotional of their own goods and services and/or any other purposes without your prior consent in writing.

8. Retention of Data and Information

8.1 We will retain all your personal data and information so long as is necessary for the fulfilment of (i) the purposes for which they were collected and (ii) of the legal requirements. All your personal data and the transaction records will be destroyed thereafter.

8.2 You hereby acknowledge that your information and data are stored and maintained in our electronic database, facilities, servers and back-up servers which may be located outside your country, where the legal protection and standard of security requirements may not be equivalent to the same provided by and legally required by the applicable laws and regulations of your country.

8.3 At any time, if you desire to erase any of your information or data from our electronic databases, facilities, servers and/or back-up servers, please contact us.

9. Accuracy and Change of Personal Data

9.1 In order to ensure the correctness and accuracy of your personal information and data, particularly your contact details retained by us, you may receive from time to time our request of confirmation, verification and/or update of your information and data.

9.2 You can also from time to time request us to correct and/or change your personal information and data held by us.

10. Handling and Security Measures

10.1 The personal data and information we collect about you will not be disclosed to any other party without your prior approval.

10.2 We have established in place security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data. All personnel that may access to the data will be ensured complying with the requirements of data protection.

10.3 Our security measures are listed below:

(a)Controls on password complexity, re-tries or resets are implemented to prevent passwords from being compromised;
(b)Advanced encryption technology is used to protect the safety of personal data (including names, email addresses, telephone numbers, credit card information and purchase records) during transmission. Our SecureSocketLayer (SSL) system will prevent your data being transmitted from unauthorized interception or access by third parties; (c)Only the personnel that have been trained with the strict privacy guidelines and procedures are authorized to access or handle your personal data. Such personnel are accountable for non-compliance with the related obligations; and
(d)The security system and procedures are reviewed regularly.

11. Third-Party Websites

11.1 After clicking on any advertisements or any hyperlinks on this Website, you may have left this Website and be diverted to websites of our advertising clients, content providers, suppliers, business partners or otherwise. You acknowledge that your visit to these third-party websites is not protected by this Privacy Policy.

11.2 We have not authorized these third-party websites to collect any information or data from you. You acknowledge we are not responsible for any exposure of your data at these websites or losses arising from a third-party website's practice or policy.

11.3 For avoidance of doubt, we do not endorse the contents, the privacy policies or their security measures in respect of personal information and data collected by any third-party websites.

12. Cookies

12.1 We may use "Cookies" to improve this Website and enhance your online experience. Cookie refers to an alphanumeric identifier stored on your hard drive of your device to facilitate us to track your activities in this Website. Cookies may be used to remember you and your preferences when you visit the Website and enable us to tailor this Website to your needs. The information collected by Cookies is anonymous visitor's personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, email or any other means.

12.2 For avoidance of doubt, we will not collect any personal data from you when the cookies are being used. You can disable cookies by changing the settings of your web browser. Cookies cannot be used to run programs or deliver viruses to your computer.

12.3 You acknowledge that we collect, hold, store the following information and data through the cookies when you browse and access to this Website:

(a)Kind and nature of services and activities you engage in;
(b)Your type of subscription of membership plan (as a Student);
(c)Frequency and time of engagement of the services of Instalearn;
(d)Your browsing history of this Website;
(e)Logs of interaction between you and other users on this Website;
(f)Logs of interaction with any of our staff, agents or representative on this Website;
(g)Logs of interaction with any visual, third-party applications, advertising products and services which are offered, linked to, or made available on this Website;
(h)Contents, details and particulars of your queries and/or requests and/or answers made on this Website;
(i)Images, documents, photos and voice records submitted by you to this Website;
(j)The model number, registration number and/or other information and particulars in respect of your device you use when having access to this Website; and
(k)Telecommunication and digital network information and data including IP address of your device, URL information, the particulars and details of your device, the browsers, third-party applications and network you use in assessing this Website.

12.4 We use Google Analytics to analyze website statistics. To understand how Google uses your data, please refer to https://www.google.com/policies/privacy/partners/

13. Limitation of Liability

13.1 We undertake to implement all reasonably practicable procedures, measures and steps to safeguard the security of all your information and data.

13.2 We do not accept responsibility for any unauthorized or unlawful access, alternation, use, destruction, loss, erasure, transmission, disclosure or leakage of any of your information and data, irrespective of whether the same occur in our electronic database, facilities, servers or back-up servers located in your country or elsewhere.

14. Changes in this Privacy Policy

14.1 We may update or amend this Privacy Policy in the future, if necessary. The revised Policy will be posted on this Website with an effective date and by our email to you.

15. Access to Personal Data

15.1 You have the right to request for access to and copy of, and correction and updating of your information and data held by us. Your request should be made by way of email to info@instalearn.com. Your request will be proceeded within 14 days. Administrative fees will be charged.

16. Contact Us

16.1Should you have any requests (including opt-out), enquiries or comments to this Privacy Policy, please email us at info@instalearn.com.hk, telephone us at 2307 0875 or write to our office at 8H, Kim Tak Building, 329 Nathan Road, Kowloon . In general circumstances, your requests or enquiries will be handled within 14 working days after our receipt of the same and our verification of your identity.

17. Governing Law

17.1 This Statement is governed by and shall be construed in all respects in accordance with the laws of the Hong Kong and all the parties hereto hereby submit to the exclusive jurisdiction of the Hong Kong courts in connection with any matters arising hereunder.

18 Direct Marketing

18.1 When we have received your consent or indication of no objection, your name, address, email address and mobile number collected by us will be used for providing you with information in relation to the promotion and direct marketing of our products and/or services.

If you do not wish to receive information on the above, you may change the setting in your account at any time.

19 Transferring Personal Data to Third-Party Academic Institutions

19.1 When we have received your consent or indication of no objection, the following personal data and information will be provided to the third-party academic institutions which use our services:- a)Student Basic Info, namely:
o Class No. ;
o Student ID/name; and
o Grade
b)About questions each one asks:
o --Question itself;
o --Photo of the question taken; and
o --Date/time asked
c)Subjects/Concepts questions are related
2. The following personal data and information will be provided to our Group:-
a)Student Basic Info, namely:
o Class No. ;
o Student ID/name; and
o Grade.
b)About questions each one asks:
o Question itself;
o Photo of the question taken; and
o Date/time asked
c)Subjects/Concepts questions are related
3. The above data will only be used for academic, teaching and educational purposes, and will be destroyed immediately upon fulfilment of these purposes.
4. The provision of the said personal data is for gain.
5. We cannot use or transfer your personal data unless we have received your consent or indication of no objection.

If you do not wish to receive information on the above, you may change the setting in your account at any time.

20. Effective Date

20.1 This Privacy Policy becomes effective from: 1st Oct 2018