PRIVACY POLICY  
 

  1. Introduction

    Bearing Consultancy & Academy Limited (“we”, or “Bearing Academy”) are committed to protecting personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance(the“PDPO”).


    We will only collect, use or disclose personal data in accordance with the PDPO and this Privacy Policy. This Privacy Policy is intended to explain our privacy practices.


    We may amend this Privacy Policy at any time and for any reason. The updated version will be available by following the “Privacy” link on our website homepage at www.bearing-academy.com. You should check our Privacy Policy regularly for changes.


    In this Privacy Policy, “personal data” means any data:

     
    1. relating directly or indirectly to a living individual;
       
    2. from which it is practicable for the identity of the individual to be directly or indirectly ascertained; and
       
    3. in a form in which access to or processing of the data is practicable.
       

    Your continued use of our website shall indicate your agreement and consent with this Privacy Policy.
     
  2. When and what personal data do we collect?  

    The types of personal data we collect from you will depend on the circumstances in which that information is collected.

     
    We collect and use personal data that we believe to be relevant and necessary to conduct our business or dealing with you. The types of personal data we collect may include, but not limited to:
     
    1. Contact information such as your name, date of birth, place of residence, mailing address, telephone and mobile number, email address and fax number;
       
    2. Unique identifiers such as your identity card, passport number and details;
       
    3. School and university records such as your diplomas and historical grades; and
       
    4. Billing information such as your credit card number, bank account information, and billing address.
       
     
    We may collect personal data about you when you:
     
    1. use our online website or apply to register with us for the services offered to you via our online website – including, but not limited to, your identity and contact details and other information relevant to our compliance obligations; or
       
    2. send us correspondence – including your contact details in order to respond to you.
       
  3. What do we use personal data for?  

    The purpose(s) for which your personal data will be used depends on the circumstances in which that personal data is collected and is set out in the Personal Information Collection Statement (“PICS”) at the time we collect your personal data.


    Generally, we may use your personal data for:

     
    1. the purpose for which you provided it to us;
       
    2. purposes which are directly related to the purpose for which you provided it to us; and
       
    3. any other purposes to which you have consented.
       
    For example, we may use your personal data when you:
     
    1. purchase our products/services via our online website;
       
    2. receive marketing products and/or services of Bearing Academy and/or any affiliates, subsidiaries or agents of Bearing Academy and/or selected companies or business partners and all other incidental and associated purposes directly relating thereto; and
       
    3. send us correspondence – to respond to you.
       
  4. Our use of cookies

    By accessing our online website, you acknowledge that you have been informed of the practice of using cookies and authorise us to use any information collected through our use of cookies in connection with the purpose set out in this Privacy Policy. “Cookies” are data files stored on your electronic devices (such as your computer or mobile phone) after you access certain websites or mobile applications.


    Cookies are primarily used to identify visitors when they return to a site, so that certain information already provided by the visitor to a site is not required to be provided again. Cookies are also used to gather data on which areas of a site or app are visited frequently and which are not. Keeping data on which areas of a site are most popular allows a site operator to better plan and enhance the site.


    We acknowledge that you may wish to disable cookies. This can be done by changing your web browser settings, but may result in more limited functionality. However, if you do so, you may not be able to utilize or activate certain functions available on our online website.
     
  5. Do we use personal data for direct marketing?  

    We do use some of the personal data we collect to send marketing material and special offers to the intended recipients via telemarketing, electronic means, direct mail or such other appropriate means as we deem appropriate, but only in accordance with the rules about direct marketing contained in the PDPO.


    If we intend to use your personal data for direct marketing purposes or provide your personal data to third parties for direct marketing purposes, we will inform you of that in the PICS at the time we collect your personal data. We will provide you with an opportunity to opt-out of that direct marketing at that time.

     
    If you do not opt-out of direct marketing at that time, but you later decide that you no longer wish to receive direct marketing, you may ask us to cease any further direct marketing by contacting the Data Protection Officer at the email address below.
     
  6. To whom do we disclose personal data?

    The third parties to whom your personal data will be disclosed will depend on the purposes for which that personal data is used.


    We will inform you of the third parties to whom your personal data will be disclosed in the PICS at the time we collect your personal data.


    Generally, we may disclose your personal data as necessary for:
     
    1. the purpose for which you provided it to us;
    2. purposes which are directly related to the purpose for which you provided it to us; and
    3. any other purposes to which you have consented.
     

    For example, we may disclose your personal data to:
     
    1. third party agents, contractors and advisors who provide administrative, communications, computer, payment, security, clerical or other services which assist us to carry out the above purposes (including telemarketers, mailing houses, IT service providers and data processors);
    2. our legal and professional advisors;
    3. our related companies (as that term is defined in the Hong Kong Companies Ordinance) or business partners;
    4. government agencies and authorities as required by any law, regulation, rule or codes binding on us or our related companies; and
    5. any other person to whom you have consented.
     

    Where personal data is transferred to place(s) outside of Hong Kong in connection with such purposes, such place(s) may or may not offer the same or a similar level of personal data protection as in Hong Kong.

     
  7. How is personal data secured?  

    We will take all reasonable and practicable care and steps to ensure that your personal data is protected against unauthorised access, disclosure, processing, erasure, loss or use.
     
  8. Accessing and correcting / enquiring about your personal data  

    You may contact us to seek access to or seek to correct or enquire about the personal data which we hold about you. There are certain exemptions under the PDPO which may apply to personal data access and correction requests. We may require that you the person requesting access or correction provide suitable identification and we may charge a reasonable administration fee for complying with a data access request.


    Requests for access to, to correct or to enquire about the personal data held by us should be addressed to:


    The Data Protection Officer
    johnny.cheung@bearingacademy.com

     

 

PERSONAL INFORMATION COLLECTION STATEMENT (“PICS”)
 

Bearing Consultancy & Academy (“we” or “Bearing Academy”) may, from time to time, use the personal data we collect about you for the following purposes:
 

 

  1. processing and evaluating your application or any related service;
  2. providing our advice to you;
  3. assisting your application to schools, universities or any institutions;
  4. contacting you for any of the above purposes;
  5. making disclosure under the requirements of any law, regulation, rule or codes binding on us or our related companies;
  6. other ancillary purposes which are directly related to the above purposes; and
  7. any other purpose to which you have consented.

 

With your consent, we may also use your contact details and demographic information to contact you with marketing communications regarding products or services by mail, email, telephone, SMS, instant messaging or push notification. By accepting these terms your consent is deemed to be stated, collected and received by us. You may indicate that you do not consent to receive such marketing communications by using any available opt-out option.

With your consent, we may also provide your contact details and demographic information to our related companies or business partners who may contact you with marketing communications regarding products or services by mail, email, telephone, SMS instant messaging or push notification. By accepting these terms your consent is deemed to be stated, collected and received by us. You may indicate that you do not consent to us providing your personal data to third parties (other than our related companies or business partners) or do not wish to receive marketing communications from these third parties by using any available opt-out option.

We also intend to use your name, contact details, products and services and demographic data, from time to time, for direct marketing (including providing reward, loyalty or privileges programmes) in relation to the following classes of products and services that we, our related companies and our business partners may offer: health, wellness and medical, food and beverage, media, online shopping, e-commerce, logistics, sporting activities, memberships and related products and services.

We may disclose your personal data for the above purposes to:
 

  1. third party agents, contractors and advisors who provide administrative, communications, computer, payment, clerical or other services which assist us to carry out the above purposes (including telemarketers, mailing houses, IT service providers and data processors);
  2. our legal and professional advisors;
  3. our related companies (as that term is defined in the Hong Kong Companies Ordinance) or business partners;
  4. our business partners and/or related companies providing the products and services set out above, third party reward, loyalty or privileges programme providers; external service providers supporting us or any of the above listed entities in providing the products and services set out above;
  5. on us or our related companies; and
  6. any other person to whom you have consented.

 
In addition to marketing the above products and services, we also intend to provide and/or transfer the personal data described above to all or any of the entities or persons described above who may contact you with marketing communications by mail, email, telephone, SMS, instant messaging or push notification. By accepting these terms your consent is deemed to be stated, collected and received by us. You may indicate that you do not consent to us providing your personal data to these third parties or do not wish to receive marketing communications from these third parties by using any available opt-out option. In some cases, we or third parties we disclose your personal data to may process and store your personal data outside of Hong Kong.

With respect to the online website including any mobile application and websites, some fields may indicate where it is optional to provide personal data. If you do not provide the personal data required in the mandatory fields, we will be unable to provide services to you.

You may seek access to and request correction of any personal data we hold about you by contacting:

 

The Data Protection Officer
johnny.cheung@bearingacademy.com