PRIVACY POLICY

Bluetop Group Limited and its subsidiaries (including Learning Habitat Kindergarten, Little Habs and Qurio) (us, we or our) respect the privacy rights of our clients, customers, visitors, students and their parents/legal guardians (as applicable) (collectively, Data Subjects). We are committed to protecting the personal data (as defined in the Ordinance) (Personal Data) by complying with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) (the Ordinance). This privacy policy (the Policy) is in compliance with the Ordinance as amended and updated from time to time. Any changes to this Policy will become effective upon posting of the revised policy on this website (the Website).

Collection of Personal Data

We may collect, retain and use necessary but not excessive Personal Data of the Data Subjects, including but not limited to, names, contact details, residential addresses, email addresses, age, gender, passport details or other identification document details, credit card information, marital status, income details, education background, biometric data and any information provided by such Data Subjects (and/or their relevant persons (as defined under the Ordinance) (Relevant Persons) (as applicable)) or in relation to such Data Subjects pursuant to this Policy.

For avoidance of doubt, any questions, comments, suggestions or information (other than Personal Data) posted or otherwise submitted to this Website by the Data Subjects will be deemed voluntarily provided to us on a non-confidential and non-proprietary basis. We reserve the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company in connection with the development and marketing of products and services.

Use of Personal Data

The Personal Data are collected from the Data Subjects (and/or their Relevant Persons (as applicable)) and are retained and used for the following purposes only. Please note that provision of Personal Data by the Data Subjects (and/or their Relevant Persons (as applicable)) is voluntary. However, if you do not agree with any/all of this Policy, you must not use this Website. If you are under the age of 18, we recommend that you seek prior consent from your parents/legal guardians before providing us with any of your Personal Data.

The Data Subject’s Personal Data will be used:

for operation, protection, enhancement, improvement and optimization of our services (e.g. provision of classes, courses and products by us);
for our daily operations (e.g. to process application forms, to maintain contact lists for communication, to organise events and activities);
for our internal control and administration purposes relating to the general operations;
for security purposes (e.g. for identity verifications and record keepings);
for statistical and research purposes (e.g. to analyse and compile statistics data);
for our compliance with legal obligations, for resolving legal disputes or otherwise for enforcement and protection of our legal rights;
subject to the prior consent of the Data Subjects and compliance of the Ordinance, for provision of promotion and/or marketing information (e.g. new courses and products provided by us or other third and related parties); and
for any other purposes relating directly to any of the aforementioned purposes.

We will seek prior voluntary and explicit consent from the Data Subjects (and/or their Relevant Persons (as applicable)) if the Personal Data of the relevant Data Subjects shall be used for any other new purposes.

Transfer of Personal Data

Bluetop Group Limited may make certain Personal Data available to its subsidiaries for the usage purposes as stated in this Policy. By accepting this Policy, you understand and acknowledge that your Personal Data may be disclosed or transferred to any and/or all our subsidiaries and/or any such third party (and their respective employees and representatives) under this Policy.

Further, we may make Personal Data available to (i) our third party or related service providers relevant to our products, services, events and activities; (ii) our data storage service providers; (iii) our e-mail service providers for sending promotional and marketing information; and (iv) our professional advisors for the safeguarding of our legal and business interests.

Retention of Personal Data

We will take practicable steps to ensure the Personal Data will not be kept longer than it is necessary for the fulfilment of the purposes as mentioned in this Policy. For the avoidance of doubt, we are entitled to retain, process and use for indefinite term and any purpose, any information, which albeit derived or processed from the Personal Data, are no longer capable of identifying the Data Subject.

Data Security

Once we have collected your Personal Data, it will be maintained securely by us. We will take practicable precautions to ensure that the Personal Data held by us or made available to above-mentioned third parties or subsidiaries of Bluetop Group Limited are held, stored and protected in compliance with the Ordinance. We will take practicable steps to safeguard Personal Data from unauthorized or accidental access, processing, erasure, loss or use.

Links to other websites

This Policy only applies to this Website. If you click on any hyperlink or advertisement linking to other website(s) that is/are provided on this Website, the protection of your privacy, Personal Data and your exposure to cookies are not our responsibility and you are advised to refer to the privacy policy of such other website(s) (if any).

Access and Correction of the Personal Data

We will take practicable steps to ensure that the Personal Data are accurate, but it shall be the responsibility of each Data Subject to keep his/her Personal Data updated.

In accordance with the Ordinance, we provide Data Subjects (and/or their Relevant Persons (as applicable)) with the right (i) to unsubscribe from all marketing communications; (ii) to make a request for removal of their Personal Data from our storage; and/or (iii) request for access and correction of their Personal Data in writing and by sending to our Data Privacy Officer by email to unsubscribe@qurioed.com or by post to: 19/F, Worldwide House, 19 Des Voeux Road Central, Hong Kong. In order to protect the Personal Data, we will require all Data Subjects (and/or their Relevant Persons (as applicable)) to prove their identities in relation to their requests to remove, access and/or correct their Personal Data. A reasonable administration fee may be charged for any such removal, access and/or correction.

Where there is inconsistency between the English version of this Policy (being the original version) and the Chinese translated version, the English version shall prevail.