Privacy Policy (Last updated on  January 23, 2017)

GT Academy Holdings Limited (“GROWHOUSE”) intends to collect and use your personal data as set out in paragraph 3.1 of the Personal Information Collection Statement (“PICS”) for direct marketing of the services, facilities or products referred in paragraph 3.2 of the PICS but GROWHOUSE will not do so unless we have received your consent.

PERSONAL INFORMATION COLLECTION STATEMENT

GT Academy Holdings Limited (referred to hereinafter as “GROWHOUSE”) recognizes its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and all applicable laws and regulations in force from time to time. Personal data will be collected only for lawful and relevant purposes and all practicable steps will be taken to ensure that personal data held by GROWHOUSE is accurate. GROWHOUSE will take all practicable steps to ensure security of the personal data and to avoid unauthorized or accidental access, erasure or other use.

Please note that if you do not provide us with your personal data, we may not be able to provide the information, products or services you need or process your request.

1.      Purpose: From time to time it is necessary for GROWHOUSE to collect your personal data which may be used, stored, processed, transferred, disclosed or shared by GROWHOUSE for purposes, including:

1.1.   offering, providing and marketing to you the products/services of GROWHOUSE, other companies of the GROWHOUSE (“our affiliates”) or our business partners (see “Use and provision of personal data in direct marketing” below), and administering, maintaining, managing and operating such products/services;

1.2.  processing and evaluating any registration, subscription orders, deliveries, uses, enquiries, feedbacks or requests made by you for products/services offered by GROWHOUSE and our affiliates;

1.3.  processing your subscriptions and related-billing and payment in relation to any products/services offered by GROWHOUSE and our affiliates;

1.4.   providing subsequent services to you, including but not limited to administering the policies issued;

1.5.   running competitions, prize draws and promotions;

1.6.   designing products/services for you;

1.7.   conducting market research for statistical or other purposes;

1.8.   matching any data held which relates to you from time to time for any of the purposes listed herein;

1.9.   any purposes in connection with any claims made by or against or otherwise involving you in respect of any products/services provided by GROWHOUSE and/or our affiliates, including investigation of claims;

1.10.  making disclosure as required by any applicable law, rules, regulations, codes of practice or guidelines or to assist in law enforcement purposes, investigations by police or other government or regulatory authorities in Hong Kong or elsewhere;

1.11.   contacting you about specific recruitment opportunities if you register search criteria information on our recruitment sites;

1.12.   carrying out other services in connection with the operation of GROWHOUSE’s business; and

1.13.   all other incidental and associated purposes relating to any of the above, including seeking professional advices.

2.      Transfer of personal data: Personal data held by GROWHOUSE relating to an individual will be kept confidential but may be provided to the following parties within Hong Kong for the purposes set out in paragraph 1 above EXCEPT that any transfer of data to another party for sales and marketing purpose will be subject to paragraph 3 below:

2.1.   any of the GROWHOUSE’s affiliates;

2.2.   delivery agents of GROWHOUSE for delivering the products in respect of your subscription or free trial;

2.3.   any agent, contractor or third party who provides administrative, technology or other services (including direct marketing services) to GROWHOUSE and/or our affiliates in Hong Kong and who has a duty of confidentiality to the same;

2.4.   any actual or proposed assignee, transferee, participant or sub-participant of our rights or business; and

2.5.   any government department or other appropriate governmental or regulatory authority in Hong Kong or elsewhere.

3.      Use and provision of personal data in direct marketing: GROWHOUSE intends to use your personal data in direct marketing and GROWHOUSE requires your consent (which includes an indication of no objection) for that purpose. In this connection, please note that:

3.1.    use your name, age, date of birth, home address, home telephone number, mobile telephone number and email address held by GROWHOUSE from time to time be used by GROWHOUSE for direct marketing;

3.2.    conduct direct marketing (including but not limited to providing reward, loyalty or privilege programmes) in relation to the following classes of products and services that GROWHOUSE, our affiliates, our co-branding partners and our business partners may offer products and services on arts and gallery, literature, children, career education, publishing and authorship, charity, education and similar activities.

3.3.    the above products and services may be provided by GROWHOUSE and/or:

(a)    any of our affiliates;

(b)   the business partners or co-branding partners of GROWHOUSE and/or affiliates providing the products and services set out in paragraph 3.2 above;

(c)    third party reward, loyalty or privilege programmes providers supporting GROWHOUSE or any of the above listed entities

3.4.    in addition to marketing the above products and services, GROWHOUSE also intends to provide the data described in paragraph 3.1 above to all or any of the persons described in paragraph 3.3 above for use by them in marketing those products and services, and GROWHOUSE requires your written consent (which includes an indication of no objection) for that purpose;

3.5.    GROWHOUSE may receive money or other property in return for providing the data to the other persons in paragraph 3.4 above and, when requesting your consent or no objection as described in paragraph 3.4 above, GROWHOUSE will inform you if it will receive any money or other property in return for providing the data to the other persons. If you do not wish GROWHOUSE to use or provide to other persons your personal data for use in direct marketing as described above, you may exercise your opt-out right by notifying GROWHOUSE at any time and without charge. To opt-out, please inform us in writing to the address in the section on “Access and correction of personal data”.

4.      GROWHOUSE-LGT.com Website:  We use website browser software tools such as cookies and Web server logs to gather information about the GROWHOUSE-LGT.com website users’ browsing activities in order to constantly improve the GROWHOUSE-LGT.com website and better serve our customers. This information assists us to design and arrange our web pages in the most user-friendly manner and to continually improve the GROWHOUSE-LGT.com website to better meet the needs of our customers and prospective customers.

Cookies help us collect important business and technical statistics. The information in the cookies lets us trace the paths followed by users of our website as they move from one page to another. Web server logs allow us to count how many people visit the GROWHOUSE-LGT.com website and evaluate the GROWHOUSE-LGT.com website’s visitor capacity.

Generally speaking, we use personal data for purposes of administering our business activities, providing customer service and making available other products and services to our customers and prospective customers. Occasionally, we may also use the personal data we collect to notify you about important changes to the GROWHOUSE-LGT.com website, new services and special offers we think you will find valuable. The lists used to send you product and service offers are developed and managed under our traditional corporate standards designed to safeguard the security and privacy of our customers’ personal data. You will be given the opportunity to notify us of your desire not to receive these offers.

5.      Other Websites Linked to the GROWHOUSE-LGT.com:  Please note that the GROWHOUSE-LGT.com website contains links to other sites and occasionally allows other sites to be co-branded with the GROWHOUSE-LGT.com name. Please remember that when you use a link to go from our Website to another website or when you use a co-branded site, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites that have a link to the GROWHOUSE-LGT.com website, is subject to that Website’s own rules and policies which may differ from that of the GROWHOUSE-LGT.com website. We are not responsible for the practices employed by websites linked to or from our Website nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Website.

By using the GROWHOUSE-LGT.com Website you consent to our collection and use of your personal data as described in this Privacy Policy. If we change our privacy policies and procedures, we will post those changes on the GROWHOUSE-LGT.com Website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it.

6.      Registration:  We may collect additional personal data from you through optional contests, surveys, or special offers. You agree that we may store and deal with any information you provide as part of the registration process or in connection with optional contests, surveys or special offers in accordance with this Privacy Policy.

7.      Protection of Personal Data:  Periodically, our operations and business practices are reviewed for compliance with corporate policies and procedures governing the security, confidentiality and quality of our information. This policy may be updated from time to time so please check this statement periodically as it is your responsibility to make sure you are aware of our latest policies. Our corporate values, ethical standards, policies and practices are committed to the protection of customer information. In general, our business practices limit employee access to confidential information, and limit the use and disclosure of such information to authorized persons, processes and transactions. Employees designated to handle personal data will be instructed to do so only per this Privacy Policy.

8.      Access and correction of personal data: Under the PDPO, you have the right to ascertain whether GROWHOUSE holds your personal data, to obtain a copy of the data, and to correct any data that is inaccurate. You may also request GROWHOUSE to inform you of the type of personal data held by it. Requests for access and correction or for information regarding policies and practices and kinds of data held by GROWHOUSE should be addressed in writing to our “Marketing Department” at:

GT Academy Holdings Limited

Room 501 – 502, 5/F, Printing House

6 Duddell Street, Central, Hong Kong

A reasonable fee may be charged to offset GROWHOUSE’s administrative and actual costs incurred in complying with your data access requests.

Copyright © 2017 GT Academy Holdings Limited. All rights reserved.