Privacy Policy

1. INTRODUCTION

UNIKEY Academy Limited ("UNIKEY Academy", "we", "us", or "our") is committed to protecting your privacy and complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO"). This Privacy Policy explains how we collect, use, disclose, and protect your personal data when you visit our website or use our services.

This Privacy Policy applies to all personal data collected through our website (unikeyacademy.com), correspondence, enquiry forms, enrolment processes, and any other interactions with UNIKEY Academy.

By providing your personal data to us, you acknowledge that you have read and understood this Privacy Policy and consent to our collection, use, and disclosure of your personal data as described herein.

2. DEFINITIONS

For the purposes of this Privacy Policy:

"Personal Data" means any data relating directly or indirectly to a living individual from which it is practicable for the identity of the individual to be directly or indirectly ascertained.

"Processing" means any operation performed upon personal data, including collection, recording, storage, retrieval, use, disclosure, erasure, or destruction.

"Services" means the education consultancy services and related services provided by UNIKEY Academy.

3. PERSONAL DATA WE COLLECT

We may collect the following categories of personal data from you:

3.1 Information You Provide Directly

• Contact Information: Name, email address, telephone number, postal address
• Educational Information: Academic records, transcripts, examination results, educational background and history
• Identification Information: Identity card number, passport number, date of birth, nationality
• Professional Information: Employment history, career goals, professional qualifications
• Financial Information: Payment information for our services (processed securely through third-party payment processors)
• Communication Records: Correspondence with us via email, telephone, or other means
• Enquiry Information: Information submitted through enquiry forms on our website

3.2 Information Collected Automatically

When you visit our website, we may automatically collect:

• Technical Information: IP address, browser type and version, operating system, device information
• Usage Data: Pages visited, time spent on pages, clickstream data, referring website addresses
• Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar tracking technologies (see Section 10 below)

4. PURPOSE AND USE OF PERSONAL DATA

We collect and process your personal data for the following purposes:

4.1 Service Provision

• To provide education consultancy services to enrolled students
• To assess your suitability for our services
• To communicate with you regarding your enquiries and our services
• To process enrolment applications and maintain student records
• To provide advice, guidance, and recommendations on educational matters
• To liaise with educational institutions on your behalf (where you have enrolled with us)

4.2 Marketing and Promotional Purposes

By providing your contact information to us, you authorise and consent to our use of your personal data (including your name, email address, telephone number, and postal address) for direct marketing purposes, including:

• Sending you information about our services, programmes, events, and educational opportunities
• Notifying you of updates, news, and promotional materials related to our business
• Conducting market research and surveys to improve our services
• Sending newsletters, announcements, and other marketing communications

You have the right to opt-out of receiving marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email we send you
• Contacting us using the details provided in Section 12 below
• Notifying us in writing of your wish to opt-out

Even if you opt-out of marketing communications, we may still send you non-promotional communications relating to your enrolment, services you have requested, or other transactional matters.

4.3 Administrative and Operational Purposes

• To process payments and manage billing
• To maintain accurate records and databases
• To respond to your enquiries and requests
• To improve our website, services, and customer experience
• To conduct internal audits, data analysis, and research

4.4 Legal and Compliance Purposes

• To comply with applicable laws, regulations, and legal obligations
• To enforce our terms and conditions and protect our legal rights
• To detect, prevent, and address fraud, security issues, or technical problems
• To respond to legal process, governmental requests, or court orders

5. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We respect the confidentiality of your personal data. We will not share, sell, rent, or trade your personal data to third parties for their independent marketing purposes without your explicit consent.

However, we may disclose your personal data to third parties in the following circumstances:

5.1 Service Providers and Business Partners

We may share your personal data with trusted third-party service providers who assist us in operating our business and providing our services, including:

• Educational Institutions: Universities, colleges, schools, and other educational institutions (where you have enrolled with us and we are providing consultancy services)
• Payment Processors: Third-party payment gateway providers for processing payments
• IT Service Providers: Web hosting companies, cloud storage providers, email service providers, and IT support services
• Professional Advisors: Lawyers, accountants, auditors, and other professional advisors
• Marketing Service Providers: Companies that assist with marketing campaigns, email distribution, and analytics

These third parties are contractually obligated to protect your personal data and may only use it for the specific purposes for which it was disclosed and in accordance with our instructions.

5.2 Legal Requirements

We may disclose your personal data if required or permitted by law, including:

• In response to lawful requests by public authorities, regulatory bodies, or governmental agencies
• To comply with legal obligations, court orders, or legal proceedings
• To protect and defend our rights, property, or safety, or that of our students, employees, or the public
• To enforce our terms and conditions or investigate potential breaches

5.3 Business Transfers

In the event of a merger, acquisition, reorganisation, sale of assets, or bankruptcy, your personal data may be transferred to the successor entity or acquiring party, subject to the same privacy protections outlined in this Privacy Policy.

6. DATA RETENTION

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law.

• Enquiry Records: Retained for up to 2 years from the date of last contact
• Enrolled Students: Retained for up to 7 years following completion or termination of services
• Marketing Records: Retained until you opt-out or withdraw consent, or for up to 3 years from the date of last engagement
• Financial Records: Retained for at least 7 years in accordance with Hong Kong tax and accounting regulations

When personal data is no longer required, we will securely delete, destroy, or anonymise it in accordance with the PDPO.

7. DATA SECURITY

We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Secure Socket Layer (SSL) encryption for data transmission on our website
• Access controls and authentication mechanisms to restrict access to personal data
• Regular security audits and vulnerability assessments
• Employee training on data protection and confidentiality obligations
• Secure storage and backup systems

However, please note that no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal data, we cannot guarantee absolute security.

8. YOUR RIGHTS UNDER THE PDPO

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

8.1 Right to Access

You have the right to request access to the personal data we hold about you. We will provide you with a copy of your personal data within 40 days of receiving your written request (subject to payment of a reasonable fee for processing).

8.2 Right to Correction

You have the right to request correction of any inaccurate, incomplete, or out-of-date personal data we hold about you. We will make the necessary corrections within 40 days of receiving your written request.

8.3 Right to Opt-Out of Marketing

You have the right to opt-out of receiving direct marketing communications from us at any time (see Section 4.2 above).

8.4 Right to Withdraw Consent

Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time by contacting us using the details in Section 12 below.

To exercise any of these rights, please submit a written request to our Data Protection Officer using the contact details provided in Section 12.

9. INTERNATIONAL DATA TRANSFERS

Your personal data may be transferred to, stored, or processed in locations outside Hong Kong, including servers located in other jurisdictions. When we transfer personal data outside Hong Kong, we will ensure that appropriate safeguards are in place to protect your personal data in accordance with the PDPO, including:

• Entering into data transfer agreements with adequate contractual protections
• Ensuring the recipient jurisdiction has adequate data protection laws
• Obtaining your consent where required by law

10. COOKIES AND TRACKING TECHNOLOGIES

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit our website. They help us recognise your device and remember information about your visit.

10.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the website to function properly (e.g., session management, security)
• Performance Cookies: Collect information about how visitors use our website (e.g., page views, navigation patterns)
• Functionality Cookies: Remember your preferences and settings (e.g., language preference)
• Marketing Cookies: Track your browsing activity to deliver targeted advertisements and measure the effectiveness of marketing campaigns

10.3 Managing Cookies

You can manage or disable cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website. For more information on how to control cookies, visit: www.aboutcookies.org

By continuing to use our website, you consent to our use of cookies as described in this Privacy Policy.

11. THIRD-PARTY WEBSITES

Our website may contain links to third-party websites, social media platforms, or external resources. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party websites you visit.

12. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal data, please contact us:

13. COMPLAINTS

If you believe that we have not handled your personal data in accordance with the PDPO, you have the right to lodge a complaint with:

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this Privacy Policy periodically.

Your continued use of our website or services following the posting of changes constitutes your acceptance of those changes.

15. LANGUAGE

This Privacy Policy is provided in English. In the event of any inconsistency or conflict between the English version and any translation, the English version shall prevail.