CTF Education Group Limited and its parent, subsidiary, affiliated, associated and/or related companies (collectively, “CTFEG Group”, “we”, “us” and “our”) value the privacy and confidentiality of your personal data. We pledge to comply with the requirements of all applicable data protection laws and regulations. If you are a parent or guardian, this PICS shall apply to both your own personal data and the personal data of your child provided to us, and in such case the term “your personal data” shall be construed accordingly.

Unless your express consent is required by the applicable laws, by providing your personal data to us, you agree to the terms of this PICS and indicate your consent for CTFEG Group to collect, retain, disclose, transfer and use your personal data in accordance with this PICS, as amended from time to time. Further, we will only use and transfer your personal data for direct marketing purposes as specified in this PICS. If you are under the age of 18, you should provide a copy of this PICS and other data privacy related documents provided by us to your parent or guardian and obtain their consent before you provide us with your personal data.

1. What data do we collect and process
   For enquiries, CTFEG Group collects the following data for the purpose of communication:
   • Name
   • Contact number
   • E-mail address

   If you register for CTFEG Group’s services, we may obtain additional data such as the following to facilitate the provision of CTFEG Group’s services:

   • name, contact information (telephone, fax and mobile number, postal and email addresses);
   • applicant information (such as date of birth and other information on identification documents (such as identity card and passport);
   • video/audio recordings and photographs from which you and/or your child may be identified;
   • academic information;
   • billing information, transaction and credit card information;
   • information about your family, personal interests, experiences with our services, programmes or products; and
   • records of correspondence between you and us.
2. Purpose and legal basis of collection
   CTFEG Group collects your data for the purposes of:
   • providing our services, programmes and products to you;
   • processing your application/enrolment of our services, programmes and/or products;
   • responding to your application/enrolment of our services, programmes and/or products;
   • (subject to your consent) offering you our services, programmes and products, including sending you marketing and promotional materials relating to our services, programmes and products;
   • (subject to your consent) conducting joint promotion events, including sending you marketing and promotional materials in relation to education-related products, services and/or businesses of our holding companies, subsidiaries and affiliated organisations and entities operating in education and related services, hospitality, insurance, healthcare services (“Affiliates”);
   • facilitating the enrolment in and managing, and providing services, programmes and products under club membership subscriptions of clubs set up and maintained by CTFEG Group, which allow members to subscribe to various events, seminars and podcasts organised and/or provided by the CTFEG Group and to purchase educational products of the CTFEG Group;
   • responding to your service requests, enquiries and complaints;
   • conducting surveys, research and analysis for improvement of our services, programmes and products and our websites; and
   • making such disclosures as required by law.

   Please note that it is obligatory for you to provide the personal data that we request. If you do not provide such personal data, we may not be able to provide our services, programmes and products to you.

3. Recipients of personal data
   We may disclose and/or transfer your personal data to third parties (within or outside Hong Kong) to fulfil the purpose of collection, including without limitation to:
   • members of CTFEG Group and third parties (within or outside Hong Kong) engaged by us, for or in connection with the purposes specified in paragraph 2 above, including any agent, contractor, or third party service provider who provides administrative, legal, telecommunications, computer, payment, data processing or other services to CTFEG; and
   • any competent court of law, law enforcement agencies and/or regulators and government departments for compliance with applicable laws and regulations and protection of our legal rights.

   We may also disclose and/or transfer your personal data to our Affiliates. If your personal data will be used by our Affiliates for direct marketing purposes, we will obtain your prior consent.

4. Duration of processing
   CTFEG Group will retain any personal data collected for the duration required to fulfil the original purpose of collection. For enquires, if there are no follow-up questions or registration pertaining to CTFEG Group’s services, your personal data will be retained for 3 months. For registration purposes, your personal data will be retained only for so long as is necessary for the fulfilment of the purpose for which the data is or is to be used, and generally speaking, your personal data will be retained for a maximum of 7 years, unless we are under any legal obligation to retain the same for a longer period.
5. Rights of data subject
   Data subjects are entitled to the following rights:
   • The right of access
   • The right to rectification

   If you wish to exercise any of the above-mentioned rights, please make such requests in writing to Group Marketing and Communication Department at CTF Education Group Limited, 24/F, Capital Centre, 151 Gloucester Road, Wan Chai, Hong Kong or email to enquiry@ctfeducation.com. All such requests will be handled promptly in accordance with the requirements of the applicable laws and regulations in relation to personal data protection. CTFEG may charge a reasonable fee for processing your data access request.

6. Privacy policy
   If you wish to know more about CTFEG Group’s privacy policies and practices, please visit Privacy Statement.
7. Use of personal data in direct marketing
   CTFEG Group intends to use your personal data for direct marketing, including without limitation sending you marketing and promotional materials relating to our services, programmes and products. CTFEG Group would also like to provide your personal data to its Affiliates for use in direct marketing, in particular our holding companies, subsidiaries and affiliated organisations and entities operating in education and related services, hospitality, insurance, healthcare services. The types of personal data CTFEG Group intends to use and/or provide for direct marketing purposes include name, contact number and e-mail address.Please note that CTFEG Group may not so use or provide your personal data for direct marketing purposes unless CTFEG Group has received your consent.If you do not consent to the proposed use and/or provision of personal data by CTFEG Group in direct marketing as described above, please tick the box(es) below: