Privacy Statement

CTF Education Group Limited (“CTFEG”, “we”, “us” and “our”) and our parent, subsidiary, affiliated, associated and/or related companies (“our Group”) recognise and value the privacy and confidentiality of your personal data. We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements of Personal Data (Privacy) Ordinance with respect to the management of personal information. We are equally committed to ensuring that all our employees and agents uphold these obligations.

Unless your express consent is required by the applicable laws and regulations in relation to personal data protection, by providing your personal data to us, you are accepting the terms of this Privacy Policy Statement and consenting us to collect, retain, disclose, transfer and use your personal data in accordance with this Privacy Policy Statement, as amended from time to time. Further, subject to your consent, we will only use and transfer your data for direct marketing purposes as specified in this Privacy Policy Statement.

This Privacy Policy Statement should be read together with the applicable personal information collection statement of the relevant service, and website provided by members of our Group (the “PICS”), provided that, in the event of any inconsistency between this Privacy Policy Statement and the PICS concerning matters relating to personal data, the PICS shall prevail.

1. We may collect your personal data on website(s) of School Leadership Academy ("SLA") , or through other media on a voluntary basis for different purposes at different times, including your registration for SLA membership, SLA programmes and services and attendance of our events and communication with us.
2. We may collect from you the following information which may contain personal data as defined under the applicable data protection laws and regulations:
   
   1. name, gender, contact information (such as mobile number and email addresses), biometric data;
   2. company and title/position;
   3. education background and academic information;
   4. billing information, transaction and credit card information; and
   5. records of correspondence between you and us.
3. Personal data provided by you to us will be used for the following purposes:
   
   1. providing services, programmes and products to you;
   2. identifying and verifying your identity and/or as a member holding valid membership of SLA;
   3. organising activities, seminars and workshops;
   4. processing your application/enrolment of our services, programmes and/or products;
   5. responding to your application/enrolment of our services, programmes and/or products;
   6. (subject to your consent) offering you with our services, programmes and products, including sending you school and education-related information and/or marketing and promotional materials relating to our services, programmes and products;
   7. (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”);
   8. (subject to your consent) conducting joint promotion events, including sending you marketing and promotional materials in relation to education-related products and/or services of our partner operating in education and related services, hospitality, insurance, healthcare services (“Marketing Partner”);
   9. facilitating the enrolment in and managing, and providing services, programmes and products under membership or subscriptions of clubs set up and maintained by us, which allow members to subscribe to various events, seminars and podcasts organised and/or provided by us and to purchase our educational products;
   10. responding to your service requests, enquiries and complaints;
   11. conducting surveys, research and analysis for improvement of our services, programmes, products and website(s) and for marketing purposes; and
   12. making such disclosures as required by law.
4. 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:
   
   1. members of our Group and third parties (within or outside Hong Kong) engaged by us, for or in connection with the purposes specified in paragraph 3 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
   2. 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.
5. We may use your personal data for direct marketing purpose as set out in paragraph 3 hereinabove.
   Please note that we may not so use or provide your personal data for direct marketing purposes unless we have received your consent. At the time of collection of personal data, you will be given the opportunity to give your consent/indication of no objection to the proposed use and/or provision of personal data for direct marketing purposes.
   If you have consented to the use and/or provision of your personal data for direct marketing purposes, you may always opt out at a later date by contacting us through our contact details set out in paragraph 9 hereinbelow.

6. When you browse our website(s), cookies will be stored in your computers, mobile phones or other devices for internal navigation and programming only. We may use cookies and other tracking mechanisms described below to track information about your use of our website(s) (“Tracking Data”). We may combine this Tracking Data with other personal data we collect from you, in which case such Tracking Data shall be considered your personal data for the purpose of, and will be used in accordance with, this Privacy Policy Statement and the PICS.
   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 our website(s), 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 our website(s).
   We may also engage third parties to track and analyse non-personally identifiable data from the website(s) or mobile application(s). We use the data collected by such third parties to help us administer and improve the quality of our website(s)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 our website(s).
   If you interact with us on social media platforms, we can interact with you and send you messages via these platforms. We 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.

7. We 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.

8. We will endeavour to ensure that your personal data is kept secure from unauthorized disclosure or access. Only authorized personnel of CTFEG (who are bound by a duty of confidentiality) will have access to these records, or we will procure by contract or use our reasonable endeavours to ensure that those who we share your personal data with act in accordance with this Privacy Policy Statement. However, we cannot guarantee

   the security of your personal data transmitted over the internet or any telecommunications networks.

9. You are entitled to request access to, make a copy of, and request us to make correction of, or demand the cessation of the continued collection, processing and use, or to delete your personal data stored in our records at any time by addressing such requests by email to leadershipacademy@ctfeducation.com All such requests will be handled as soon as practicable in accordance with the requirements of the applicable laws and regulations in relation to personal data protection. We may charge a reasonable fee for processing your data access request.
10. If there is any inconsistency or conflict between the English and Chinese version of this Privacy Policy Statement, the English version shall prevail.
11. The terms of this Privacy Policy Statement may be updated, revised, varied and amended from time to time as we deem necessary and the latest version will be available on SLA’s website. Any such change, update or modification will be effective immediately upon posting without prior notice. We will obtain your consent for changes to the terms of this Privacy Policy Statement if such consent is required by applicable law.