CTF Education Group Limited ("CTFEG", "we", "us" and "our") values the privacy of your personal data. We pledge to comply with the requirements of all applicable data protection laws and regulations.  

Apart from (a) CTFEG Privacy Policy Statement (PPS) and (b) CTFEG Personal Information Collection Statement (PICS), CTFEG will process your personal information according to this addendum and applicable data protection laws in Mainland China. This Addendum is intended to explain to you how we collect, use, retain and share your personal data and other related information. We may update or modify this Addendum from time to time in the future based on the information processing situation and the applicable law.  

Before providing your personal information, please ensure that you have carefully read this Addendum. If you do not agree with the terms of this Addendum, please refrain from using our services immediately. However, under such circumstances, we may be unable to provide you with services, or our services may not be able to achieve the expected service effects. 

This Addendum will help you understand the following: 

A.    Scope 

B.    How do we collect and use your personal information 

C.    How we entrust, share, transfer, and publicly disclose your personal information 

D.    How do we retain and protect your personal information 

E.    How do you access to and manage your personal information 

F.    Update of this Addendum  

G.    Contact us 

H.    Miscellaneous  

A.     Scope 

This Addendum applies to the following: 

an individual located in Mainland China who visits CTFEG’s relevant website(s) or uses relevant mobile application(s) of CTFEG, or otherwise uses CTFEG’s products and/or services (including but not limited to registering/attending events, seminars and/or workshops) by phone or any other means from Mainland China; and/or 

an individual holding a Mainland China passport and/or resident identity card who visits the premises of CTFEG in Hong Kong or otherwise uses CTFEG’s products and/or services (including but not limited to registering/attending events, seminars and/or workshops) by phone or any other means in Hong Kong. 

This Addendum is applicable to the various events, seminars, workshops and services provided by CTFEG in the forms of websites, APPs, Mini Programs, and other new technological formats. Except for the related personal information collection purpose outlined in this Addendum, this Addendum does not extend to additional services offered to you by third parties and the relevant rules regarding personal information collection and processing shall be communicated to you separately.  

For the purpose of this Addendum, “Mainland China” refers to the People’s Republic of China excluding the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”), the Macau Special Administrative Region of the People’s Republic of China and Taiwan. Unless defined otherwise, all defined terms in this Addendum shall have the same meaning as the defined terms in the PICS. 

In the event of any conflict or inconsistency, they shall be resolved in the following order of precedence (from higher to lower) in respect of such conflict or inconsistency: (a) this Addendum; (b) the PICS and (c) CTFEG Privacy Policy Statement. 

B.     How do we collect and use your personal information 

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. 

We will collect your following personal data for the purposes specified in the PICS. Please note that personal data marked with asterisks (*) in relevant personal information collection forms are mandatory. If you do not provide such personal data, we may not be able to process your application and/or provide our services to you. Personal data in bold is classified sensitive in nature. 

In order to assist you on registration and/or enrolment and respond to your enquiries, we need to collect your personal information below: 

Basic personal information: Full name*, contact number*, e-mail address*, WeChat ID (if any), geographical location 

Personal work information: Company/school/organization name*, Title/position*, leadership/mentor experience (if applicable) 

Subject to your consent, we will also use your personal data for the purposes of: 

Offering you our events, services and products, including sending you education-related information and/or marketing and promotional materials relating to our services and products; 

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”); and 

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”). 

Exceptions subject to prior consent 

According to laws, regulations and relevant national standards, in the following circumstances, we may collect and use your personal data in accordance with the law without obtaining your authorization and consent: 

where necessary to conclude or fulfill a contract in which the individual is an interested party; 

where necessary to fulfill statutory duties and responsibilities or statutory obligations; 

where necessary to respond to sudden public health incidents or protect natural persons’ lives and health, or the security of their property, under emergency conditions; 

when handling previously disclosed personal data within a reasonable scope in accordance with the provisions of this Law. 

handling personal information within a reasonable scope to implement news reporting, public opinion supervision, and other such activities for the public interest; 

other circumstances specified by laws, administrative regulations, and national standards. 

C.     How do we entrust, share, transfer and publicly disclose your personal information 

Entrust 

We may entrust authorized partners to process your personal data such that the authorized partners can provide you with certain services or perform functions on our behalf. We will only entrust them to process your data for the lawful, legitimate and necessary purposes stated in this Addendum. Authorized partners may only process the information necessary to perform their duties. We will require them, through formal agreements, that they shall not to use such information for other purposes beyond the authorized scope. If an authorized partner uses your information for purposes not entrusted by us, they will notify you separately and obtain your consent. 

Share 

We will not transfer your personal information to any company, organization or individual outside our company, except in the following circumstances: 

Having obtained your explicit prior consent or authorization (including our authorization based on your agreement to this Addendum); 

Provide it when necessary to comply with applicable laws, regulations, legal procedures, or requirements from competent government departments or judicial departments; 

In line with the relevant agreements (including electronic agreements signed online and corresponding platform rules) or other legal documents signed with you; 

Use it to protect social and public interests in accordance with laws and regulations; 

Share with our affiliates, but we will only share necessary personal information and are subject to the purposes stated in this Addendum. If our affiliated companies want to change the purpose of processing personal information, they will obtain your authorization and consent again. Details are set out in “Index 1 – Affiliates Sharing Details” of this Addendum. 

Authorized partners (including suppliers, service providers and etc.) may process your personal information based on the needs of the relevant services, products and/or activities. Some of the services, products and/or activities may be provided by our authorized partners to achieve the purposes stated in this Addendum. We will only transfer your personal information for lawful, legitimate, necessary, specific and clear purposes, and will only transfer the personal information necessary to provide such services. Details are set out in “Index 2 – Authorized Partners Sharing Details” of this Addendum. 

Scenarios of sharing with our affiliates and authorized partners, including but not limited to: 

Event hosting and management: including location, transportation arrangement, insurance purchase, etc., where personal information may be shared with travel agencies 

Security assurance: ensuring the health and safety of the participants during the relevant event 

Research and improvement: for continuously improving services, events, products activities and websites 

For companies, organizations and individuals with whom we share personal information, we will require them to process your personal information in accordance with legal regulations, this Addendum, and relevant agreements. 

Transfer 

We will not transfer your personal information to any company, organization or individual, unless: 

With your explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties; 

The personal information is provided in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements; 

In line with the relevant agreements (including electronic agreements signed online and corresponding platform rules) or other legal documents signed with you; 

When a merger, acquisition or bankruptcy liquidation is involved. If personal information is transferred, we will require the new company or organization that holds your personal information to continue to be bound by this Addendum, otherwise we will require the company or organization to obtain your consent once more.  

Public Disclosure 

We will only publicly disclose your personal information under the following circumstances and on the premise of adopting security protection measures that comply with industry standards: 

Based on your needs, disclose your designated personal information in a way you explicitly agreed to; 

When we are required to provide your personal information in accordance with the requirements of laws, regulations, mandatory administrative enforcement or judicial requirements, we may publicly disclose your personal information according to the required type of personal information and disclosure method. Subject to complying with laws and regulations, when we receive the above request to disclose information, we will require the issuance of relevant legal documents, such as a subpoena or a letter of investigation. All such disclosure requests will be carefully reviewed to ensure they have a legitimate basis and will be limited to data that law enforcement has a legal right to obtain for specific investigative purposes. 

D.    How do we retain and protect your personal information 

Retention period 

Unless required mandatorily by law, we will only retain your personal information for the period required to achieve the purposes stated in this PICS and allowed by laws and regulations. 

Storage location 

In principle, the personal information we collect and generate in the People's Republic of China will be stored in the People's Republic of China. If we need to transfer relevant personal information collected domestically to an overseas institution or store relevant personal information collected domestically overseas for the purposes stated in this Addendum, we will do so in accordance with laws, regulations and the provisions of relevant regulatory departments.  

Since we provide products or services based on our resources and servers worldwide, therefore, with your consent, your personal information might be transmitted to or accessed from a jurisdiction outside of the country/region where your products or services are located. 

Such jurisdiction might have a different data protection law, or even no relevant laws. Under such circumstances, we will ensure that your personal information will enjoy the same level of protection as it does in the People’s Republic of China. For instance, we will ask you for your consent to the cross-border transmission of your personal information and employ other necessary security measures before the cross-border transmission of data. Details are set out in “Index 3 – Overseas Transfer Details” of this Addendum. 

Storage security 

We have adtopted security measures that meet industry standards to protect your personal information to prevent unauthorized access to, disclosure, use, modification, damage or loss of data. We will take all reasonable measures to protect your personal information.  

We will take all reasonable and feasible measures to ensure that unnecessary personal information is not collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this statement, unless the extended retention is required or permitted by laws. 

The network environment is not 100% secure. We will do our utmost to ensure or guarantee the security of any information you send to us. If your legal rights and benefits are adversely affected due to the unauthorized access to, disclosure, tampering or damage of your personal information resulting from the damage of our physical, technical or management protection facilities, we will assume legal liabilities accordingly. 

In the case of an unfortunate personal information security incident, we will, in a timely manner and in accordance with laws and regulations, inform you of the basic conditions and possible impacts of the security incident, response measures that we have already taken or plan to be take, suggestions for you regarding self-prevention and risk mitigation, our remedial measures for you, etc. We will notify you via email, fax, telephone, push notification, etc.. If it is not feasible to notify each individual directly, we will issue a public notice in an appropriate and effective manner. We will also report the personal data security incidents in accordance with the requirements of the regulatory authorities. 

E.     How do you access to and manage your personal information 

In accordance with relevant laws and regulations, we will ensure that you can exercise the following data subject rights entitled, including access, modify and manage your personal information that we collected through your application/registration form/enquiries by contacting us via sla.contact@ctfeducation.com. We will respond to your requests in accordance with the requirements of relevant laws and regulations. 

Right to access  

You are entitled to ascertain whether or not personal data concerning you are being processed, and access to the personal data and other related information, from us; 

You are entitled to obtain a copy of the personal data relating to your personal data held by us. 

Right to correction and rectification 

You are entitled to request any correction of any inaccuracies contained in such data, pertaining to you.  

Right to object / withdraw 

You are entitled to withdraw any previously provided consents to the collection and the use of the personal data, prevent further processing of the personal data; 

You are entitled to object to the processing of personal data concerning you, where processing is justified on the basis of legitimate interests, including profiling. 

Right to be forgotten 

You are entitled to remove any personal data concerning you collected by us, where we will stop collecting and using your personal information, and delete or anonymize your personal information. 

Right to data portability 

You are entitled to have your personal data transmitted from one data user to another, where technically feasible. 

Right to restriction of processing 

You are entitled to restrict the processing of your personal data. 

Right to object to automated decision making 

You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you;  

You shall have the right to obtain human intervention to express your point of view and to contest the decision. 

For security reasons, we may need you to provide a written request or otherwise prove your identity. We will respond to you within a reasonable period (usually within 15 working days) after receiving your feedback and verifying your identity. In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the circumstances. We have the right to reject requests that are unreasonably repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are extremely impractical. 

In the following circumstances, we will not be able to respond to your request in accordance with legal and regulatory requirements: 

Relevant to our performance of obligations stipulated in laws and regulations; 

Directly related to national security and national defense security; 

Directly related to public security, public health, and major public interests; 

Directly related to criminal investigation, prosecution, trial and execution of judgments; 

There is sufficient evidence that you have subjective malice or abused your rights; 

To protect your or other individuals’ life, property and other major legitimate rights and interests but it is difficult to obtain your authorization and consent; 

Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations; 

Relating to business secrets. 

F.     Update of this Addendum  

In order to provide better products, services, and event experience to you, we will continuously improve our events and products, etc. As new services and new changes of business process occur, we may update the Addendum from time to time and inform you any changes to this Addendum. We will not reduce any of your rights under this Addendum without your explicit consent.  

G.    Contact us 

If you have any questions about this Addendum, or how we process your personal data, or are not satisfied with our handling of a request you have made in relation to your rights, please contact our email sla.contact@ctfeducation.com. We will respond to you within a reasonable period (usually within 15 working days) after receiving and verifying your email. Please note that we may not respond to inquiry unrelated to this Addendum or your personal information rights. 

H.    Miscellaneous  

The interpretation of this Addendum and dispute resolution shall be governed by the laws of the People's Republic of China. Any disputes related to this Addendum shall be resolved through friendly negotiation between the parties; if the dispute cannot be resolved through negotiation, you hereby agree to submit the dispute to the Guangzhou Panyu District People's Court. Should any term of this Addendum be held or held to be invalid by any court of competent jurisdiction, such term will be removed from this Addendum, but the invalidity of such term shall not affect the validity of the remaining terms of this Addendum. The remaining terms of this Addendum will continue to be effective. 

If there is any inconsistency or conflict between the English and Chinese version of this Addendum, the English version shall prevail. 

The titles of this Addendum are designed for ease of reading only and do not affect the meaning or interpretation of any terms of this Addendum.