Privacy Policy

1. Who we are

Bauhinia Ledger Limited is a company incorporated in Hong Kong with its registered office at Unit 1204, Exchange Tower, 33 Wang Chiu Road, Kowloon Bay, Hong Kong. We are the data controller for the personal data collected through this website and our course enrolment process.

For data-related enquiries, contact us at: [email protected]

2. What data we collect and why

We collect personal data in the following circumstances:

• Contact form submissions: name, email address, and optionally phone number and message content. We use this to respond to your enquiry.
• Course enrolment: name, email address, phone number, and payment information (processed by our payment provider — we do not store card details). We use this to administer your enrolment and deliver the course.
• Communications: if you contact us by email or phone, we retain a record of that communication for service continuity.
• Website analytics: anonymous or pseudonymous data about how pages are visited, collected via cookies (subject to your consent). See our Cookie Policy for detail.

3. Legal basis for processing

Under the PDPO, we collect and use your personal data only where we have a lawful basis to do so:

• Contract performance: to provide the course you have enrolled in and manage your account
• Legitimate interest: to respond to enquiries and improve our services
• Consent: for optional analytics and marketing cookies, which you can withdraw at any time via our Cookie Policy page

4. How we use your data

Personal data collected from you may be used to:

• Respond to your enquiry about a course
• Process your enrolment and provide access to course materials
• Send administrative communications relevant to your course
• Improve our courses based on anonymised feedback
• Comply with legal obligations

We do not use your personal data for automated decision-making or profiling.

5. Data retention

We retain personal data for as long as necessary for the purpose for which it was collected:

• Contact enquiries: up to 24 months from last contact
• Enrolment records: seven years from the end of the course, for accounting and legal compliance purposes
• Anonymised feedback data: indefinitely, as no individual can be identified

6. Data sharing

We do not sell, rent, or share personal data with third parties for their own marketing purposes. We may share data in the following limited circumstances:

• Service providers: our payment processor, our course platform provider, and our email service provider, each of whom is bound by appropriate data processing agreements
• Legal requirements: where we are required to disclose information by law, court order, or regulatory authority

No personal data is transferred outside Hong Kong for storage or processing unless subject to appropriate safeguards.

7. Data security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include encrypted data transmission (HTTPS), access controls limiting who within our team can view personal data, and regular review of our security practices.

In the event of a data breach that poses a risk to your rights, we will notify you and the relevant authority as required under applicable law.

8. Cookies

We use cookies on this website. Essential cookies are required for the site to function. Optional analytics and preference cookies are only placed with your consent. For full details of the cookies we use and how to manage your preferences, see our Cookie Policy.

9. Your rights under the PDPO

Under the Personal Data (Privacy) Ordinance, you have the following rights:

• Right of access: to request a copy of the personal data we hold about you
• Right of correction: to request that inaccurate personal data is corrected
• Right to opt out: to request that we cease using your personal data for direct marketing (if applicable)

To exercise any of these rights, write to us at [email protected]. We will respond within 40 days as required by the PDPO. We may ask you to verify your identity before processing your request.

If you believe your data has been handled in a way that violates the PDPO, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.

10. Third-party links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We encourage you to read the privacy policies of any sites you visit.

11. Children's privacy

Our courses are designed for working professionals and are not directed at anyone under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data to us, please contact us and we will delete it promptly.

12. Changes to this policy

We may update this Privacy Policy from time to time. The updated version will be published on this page with a revised "Last updated" date. We encourage you to check this page periodically. Continued use of our website or services after an update constitutes acceptance of the revised policy.

13. Contact

Questions about this policy or our data practices:

Email: [email protected]
Post: Bauhinia Ledger Limited, Unit 1204, Exchange Tower, 33 Wang Chiu Road, Kowloon Bay, Hong Kong