Applicants and their parents should provide accurate and complete personal information to RoboCode for the sake of delivering the appropriate services (such as informing about course cancellation) and recommendations (i.e. courses that best suit a child according to his/her ability and development).
RoboCode is committed to providing you with the highest level of service, which includes protecting your privacy. RoboCode respects your privacy and commits to strictly comply with the Personal Data (Privacy) Ordinance.
All information shall be kept confidential. RoboCode shall ensure that all policies and regulations regarding information collection, usage, storage, disclosure, transmission, encryption and examination are to comply with the Hong Kong Ordinance(s).
Please read this statement carefully. Once you provide us with your personal information, it would be regarded as your consent for the methods and purposes when collecting, storing and using, or processing in other ways (including disclosing) your personal information in this Privacy Statement.
Your Personal Data
We may collect and hold a range of different information about you, such as, but not limited to, the following:
- full name as registered on the Hong Kong Identity Card or other travel document;
- contact details, including name, contact number, email address, correspondence address, billing address or proof of address;
- information for the verification of identity, including date of birth, types of identification documents and identification number, for example: Hong Kong Identity Card number or passport/travel document number;
- payment details, including credit card, debit card and banking information;
- student/member account details, including account numbers, student/member numbers, user accounts, login IDs, any linked electronic/educational device numbers;
- information relating to courses or services (i.e. newsletters, membership programs) registered with RoboCode at any time;
- information may be used to further improve our course quality and customize our teaching and recommendations, such as age, gender and ethnicity of child, education, profession, income and employment details of parents, family, as well as family/household demographics and course enrollment history; and/or
- all data requested by applicable government authorities, courts, law enforcement or other authorities or regulatory bodies to enable RoboCode to comply with or in connection with any law, rule, regulation, judgment or court order (whether within or outside of Hong Kong).
Provision of some of the above personal data is optional, especially those listed in clause (7) above. However, failure to provide some requested personal data may prevent us from providing particular assistance, fulfilling some of our responsibilities and/or offering customized teaching and support.
Information Collection Methods
We collect your personal information via various methods, including:
- directly from you, for example, when you provide information by phone, completing an application form or agreement for our course, trial class, day-camp, competition, products and/or services, or when you submit your personal data through our websites or mobile apps; or when you contact us with a query/request or during the ordinary contact for the continuation of our business relationship with you;
- from third parties such as related entities, business partners, other customers, or your representatives with appropriate consent from you;
- from publicly available sources of information;
- from our own records of your enrollment and application to our course, trial class, day-camp, competition, products and/or services;
- when you visit our websites/social media website (see “Web Browsing Information and Cookies” below); or
- when RoboCode is legally required to do so.
Use of Personal Information
The information collected through the mentioned methods and channel are only for the following purposes:
- Registration, to process your enrollment to our courses, classes, competitions, day-camps or acquiring our products/services.
- Student Identity Verification.
- Provision of daily management and operations, such as course transfer, course withdrawal, complaints investigation, refund arrangements, etc.
- Teaching and tutoring, only when the information could facilitate learning directly or indirectly.
- Notification of course updates, student progresses, and invitations to events.
- Processing of billing and payment instruction, debit/credit arrangements.
- Direct marketing & promotions of course discounts and students’ benefits that we think will be of interest to you. This may be carried out by various means (including, but not limited to, in the form of letter, e-mail, SMS, by telephone, social media) and may continue after you complete (or withdraw from) our courses, classes, competitions, day-camps, events, etc.
- Research and analysis conduct internally or by independent parties instructed by us for business & operational planning, improvement of teaching quality & students’ loyalty, generation of statistical reports which may shared with external parties for various reasons. All the analysis and reports are aggregated and will not contain any information that identifies particular person.
- Demands or authorizations to make disclosure under any law or court order, to assist in the prevention, detection or investigation of crime or possible criminal activities.
We shall keep the information you provide confidential and only use to support the customer relationship with RoboCode, or the purposes stated above when collecting the information.
Disclosure of Information
In order to fulfill some of the purposes listed under the “Use Of Personal Information”, we may be required to disclose your personal data to organizations outside of RoboCode (within or outside of Hong Kong), to the extent permissible under applicable laws and regulations. Your personal data is disclosed to these parties or organizations only for necessary purposes, including, but not limited to, handling enquiries, arranging mailing/courier/delivery services, configuring information technology settings, carrying out marketing and telemarketing actions, conducting market research and website usage analysis, providing administrative, payment collection, business, legal and/or operational support, managing our business and corporate strategies.
In most circumstances, we take reasonable actions to ensure that these organizations are bound by confidentiality and privacy obligations in relation to the protection of your personal data and that they use your personal data only for the above purposes, and not for their own or other purposes (including direct marketing).
Any personal information collected through various channels shall not be given or sold to any outside organizations for its use in marketing or solicitation without your prescribed consent.
RoboCode may merge your personal information collected online with information collected by other business partners, in order to recommend courses, products or services customized to you. We may also allow the use of information by our related entities, dealers and other business partners for direct marketing. However, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use and provide your personal data for any of their promotional or marketing purpose unless exemptions from the Ordinance.
In particular, we may disclose your personal data to:
- your authorized representatives or your legal advisers when requested by you to do so; and
- the Government and regulatory authorities and other organizations, as required or authorized by law.
Transfer of personal data outside Hong Kong
At times it may be necessary and/or prudent for us to transfer certain personal data to places outside of Hong Kong for the prevention, detection or investigation of crime or in order to carry out the purposes, or directly related purposes, for which the personal data were collected. Where such a transfer is performed, it will be done in compliance with the prevailing requirements of the Ordinance.
Opt-out of Receiving Further Marketing Materials
RoboCode may send you information about our latest news, upcoming courses, events, products & services that we consider may be of interest to you. Only RoboCode (or agencies and business partners working on behalf of RoboCode and they are under confidentiality consents) shall send you these direct mailings provided that we have obtained your prescribed consent, or as may be required by law.
RoboCode will honour each individual’s request to not use his/her personal data for the purposes of direct marketing. You may opt-out from receiving direct marketing material and/or communications from us or our business partners. At the same time, you may resume receiving the same (if you have previously opted-out of receiving such material and/or communications from us or our business partners) by making a written request to us.
Information Security & Retention
All reasonable efforts are made to ensure that any personal data held by us is stored in a secure and safe place and accessed only by our authorized employees or authorized third parties referred to in this Privacy Statement.
However, you should be aware that no system is impenetrable and no data transmission over the Internet can be guaranteed as completely secure. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or from our Web site, and therefore, please note that you would be responsible for any potential risks. Once we receive your transmission, we shall strive to ensure the security of such information in our systems.
The actual records with personal information shall be stored safely in locked drivers when they are not in use. The data is stored in computer systems and storage media with set access restrictions. Access to information is also subjected to strict supervision. People with no authorization obtained from management are strictly prohibited to use or process the records and data. Management shall only give such authorization to employee(s) on a “need-to-know” basis, and subject to the role and training status of the employee(s). There are sufficient protective procedures to prevent unauthorized and/or accidental disclosures, modifications and/or damage when we save, use and/or send customers’ personal information.
We will destroy your personal data in accordance with our internal policy. Generally speaking, our policies cover the following principles:
- personal data will only be retained for as long as is necessary to fulfill the original or directly related purposes for which it was collected, unless the personal data is also retained to satisfy any applicable legal, regulatory or contractual obligations; and
- personal data are purged from our electronic, manual and other filing systems based on the above criteria and our internal procedures.
Web Browsing Information & Cookies
Our web servers may collect information relating to your online session, the use of which is to provide aggregated, anonymous, statistical information on the server’s usage so that we may better meet the demands and expectations of visitors to our websites. This type of information may include, but is not limited to the browser type and version; operating system; the IP address and/or domain name; or URLs.
You can disable cookies on your web browser, however if you do so you may not be able to access all parts of our websites.
Links to Other Sites
Information Access, Accuracy & Update
You have the right to, at any time, to view, modify or permanently remove all personal information stored by RoboCode Academy, in a form which our access to or processing of is reasonably practicable. We may apply a reasonable administrative fee for providing access to your personal information in response to such request.
We take all reasonable precautions to ensure that the personal data we collect, use and disclose is accurate, complete and up-to-date.
However, the accuracy of that personal data depends to a large extent on the information you provide. You have a right to request correction of your personal data and we recommend that you:
- let us know if there are any errors in your personal data; and
- keep us up-to-date with changes to your personal data, such as your address, contact number or email address.
If you have any of the above requests, please contact us by written.
- By Post: Unit 1412, Telford House, 16 Wang Hoi Road, Kowloon Bay, Hong Kong
- By E-mail: firstname.lastname@example.org
This Privacy Statement may be amended from time to time and all handling of personal data will be governed by the most recent version of this Privacy Statement, available on our website www.robocodeacademy.com/privacy.html.
If there is any inconsistency or conflict between the English and Chinese versions of the Privacy Statement, the English version will prevail.
Update: September 2017