Privacy Policy

1. Introduction

Compass Rose ("we", "us", or "our") is committed to protecting the privacy of the individuals who interact with our website and programmes. This Privacy Policy explains how we collect, use, store, and protect personal data in connection with the operation of our educational programmes and website.

We are the data controller for the personal data we process. Our registered place of business is 8/F, The Wellington, 198 Wellington Street, Sheung Wan, Hong Kong.

If you have questions about this policy or how we handle your personal data, please contact us at [email protected].

2. Data We Collect

We collect the following categories of personal data:

• Contact and identity data: name, email address, telephone number, and general location (district/city).
• Enquiry data: the content of messages submitted through our contact form, including any details about your financial situation you choose to share.
• Enrolment data: information provided at the time of programme registration, including payment records.
• Website usage data: IP address, browser type, pages visited, and session duration — collected via analytics cookies where consent has been given.

We do not collect sensitive personal data, financial account details, or any data from individuals we know to be under the age of 18.

3. How We Collect Data

We collect personal data through the following means:

• Contact forms submitted on our website
• Email and telephone correspondence
• Programme enrolment and payment processes
• Analytics cookies (where consent is given)

4. Legal Basis and How We Use Your Data

We process personal data on the following legal bases under Hong Kong's Personal Data (Privacy) Ordinance, Cap. 486 (PDPO):

• Contractual necessity: to administer programme enrolments, process payments, and deliver programme materials.
• Legitimate interests: to respond to enquiries, manage our relationship with participants, and improve our programmes.
• Consent: for analytics cookies and any marketing communications you have expressly agreed to receive.

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

5. Data Sharing

We do not sell, rent, or share your personal data with third parties for their commercial purposes. We may share data in limited circumstances:

• Service providers: payment processors and email delivery services, under contractual obligations to protect your data.
• Legal requirements: if we are required to disclose data under applicable Hong Kong law or regulation.

We do not share participant data with financial product providers, advertisers, or referral partners.

6. Data Retention

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

• Enquiry data: up to 12 months from last contact, unless enrolment follows.
• Enrolment and payment data: up to 7 years in compliance with Hong Kong tax and record-keeping requirements.
• Programme participation records: retained for up to 5 years to allow participants to request copies of materials or certificates.
• Website analytics data: up to 26 months from collection.

7. Data Protection Measures

We take reasonable steps to protect personal data from unauthorised access, disclosure, alteration, or destruction. Measures include:

• Encrypted transmission of data via HTTPS
• Access controls limiting who within our team can access personal data
• Secure storage of enrolment and payment records
• Regular review of data handling practices

In the event of a data breach that poses a risk to individuals, we will notify affected parties and the relevant authorities as required under applicable law.

8. Cookies

Our website uses cookies to understand how visitors use the site and to remember preferences. Full details are set out in our Cookie Policy. You can manage your cookie preferences using the controls on that page.

9. Your Rights

Under the PDPO, you have the right to:

• Access the personal data we hold about you
• Correct inaccurate or incomplete personal data
• Request erasure of data we no longer have a legal basis to hold
• Object to processing where we rely on legitimate interests
• Withdraw consent at any time where processing is based on consent
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days as required under the PDPO.

10. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites and recommend you read their policies directly.

11. Children's Privacy

Our programmes and website are intended for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe a minor has submitted personal data to us, please contact us so we can delete it.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of our website or programmes after any update constitutes acceptance of the revised policy.

13. Contact

For any questions about this policy or your personal data, please contact:

Compass Rose
8/F, The Wellington, 198 Wellington Street, Sheung Wan, Hong Kong
[email protected]
+852 2172 6938