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.
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
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 firstname.lastname@example.org 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.
Photo and Video Taking Policy
Unless otherwise agreed by Qurio Education Co. Ltd (we, us or our), all students, parents, guardians, caregivers and visitors (you) of our centre(s) (the Centre(s)) must abide with the following photo/video taking guidelines, which are in place with the interest/protection of our students in mind:
1. You shall not take photos/videos which include other people’s child(ren) and/or our teacher(s)/staff member(s) without permission(s) from the relevant child(ren)’s parents/guardian/caregivers and/or the relevant teacher(s)/staff member(s).
2. You shall not take any photo/video in the Centre(s) which could cause embarrassment or distress to others. You must be considerate of others when taking photos/videos in the Centre(s) (e.g. do not disrupt the course, lesson or event taking place and not disrupt participants’ or spectators’ view).
3. You must immediately stop taking photos/videos in the Centre(s) at the request of our teacher(s)/staff member(s) (with or without reasons provided).
4. You must not take any photo/video in the Centre(s) for commercial purpose/gain.
5. We shall have a right to request for copies of any photo/video taken in the Centre(s).
6. You must not post photos/videos and personal details of other people’s child(ren) on social media. Only group photos of our students should be posted. Individual and close-up photos of our students (other than your child(ren)) should not be posted. All students (other than your child(ren)) appearing in photos/videos posted should not be identified by name(s).
7. You must ensure all persons featuring in photos/videos taken in the Centre(s) posted on social media are in compliance with the laws of Hong Kong (including any requirements relating to COVID-19).
8. You must not post on social media any photo/video taken in the Centre(s) which contains identifiable logos/materials of our competitors.
9. You shall hide/delete any photo/video taken in the Centre(s) posted on social media immediately at our request (with or without reasons provided).
10. It is the responsibility of parents/guardians to ensure that any caregivers or visitors involved in the care of their child(ren) and/or who visit the Centre(s) comply with these guidelines.
11. Failure to meet any of these guidelines will result in discussion with us relating to the relevant student(s)’ continue and/or future enrolment status at the Centre(s). We reserve the right to take appropriate action(s) depending on the degree/severity of such failure on a case-by-case basis (including without limitation the termination of the relevant student(s)’ enrolment, reporting to law enforcement and/or commence proceedings to recover losses and damages suffered or incurred by us relating to such failure).