Bright from the Start

Bright from the Start

Privacy Policy

Latest Update: 30 September 2024

Victoria Playpark (“VPP”, “we”, “us” and “our”) recognises and understands that parents, students, staff and website visitors are concerned about the privacy of personal data. VPP pledges to comply with the requirements of all applicable data protection laws and regulations in relation to personal data protection.

The terms of this Privacy Policy Statement may be updated, revised, varied and amended from time to time as we deem necessary and the most current version will be the one available on our website https://www.victoriaplaypark.com/privacy-policy/ . We will obtain your consent for changes to the terms of this Privacy Policy Statement if such consent is required by applicable law.

Unless your express consent is required by the applicable laws and regulations in relation to personal data protection, by providing your personal data to us, you agree to the terms of this Privacy Policy Statement and indicate your consent for VPP to collect, retain, disclose, transfer and use your personal data in accordance with this Privacy Policy Statement, as amended from time to time. Further, we will only use and transfer your data for direct marketing purposes as specified in this Privacy Policy Statement.

If you are a parent or guardian, this Privacy Policy Statement shall apply to both your own personal data and the personal data of your child provided to us, if you are a job applicant or employee, this Privacy Policy Statement shall apply to both your own personal data and the personal data of your family members, and in such case the term “your personal data” shall be construed accordingly.

If you are under the age of 18, or under the age that is regarded as a child or minor under applicable laws, you should provide a copy of this Privacy Policy Statement and other data privacy related documents provided by us to your parent or guardian and obtain their consent before you provide us with your personal data.

This Privacy Policy Statement should be read together with the applicable personal information collection statement (the “PICS”) of the relevant service and website provided by us and/or our Affiliates (as defined below), provided that, in the event of any inconsistency between this Privacy Policy Statement and the PICS concerning matters relating to personal data, the PICS shall prevail.

1. We may collect your personal data on our website(s), or through other media on a voluntary basis for different purposes at different times, including your registration for attendance of our events and communication with us.

2. We may collect from you and/or your child aged under 18 the following information which may contain personal data as defined under the applicable data protection laws and regulations:

(a.) name, contact information (telephone, fax and mobile number, postal and email addresses);
(b.) applicant information (such as date of birth and other information on identification documents, such as identity card and passport);
(c.) video/audio recordings and photographs from which you and/or your child may be identified;
(d.) academic information;
(e.) billing information, transaction and credit card information;
(f.) information about your family, personal interests, experiences with our services, programmes or products; and
(g.) records of correspondence between you and us.

3. Purpose of collection of personal data

Admission and/or studying at VPP: We collect, retain and use your personal data for the following purposes:
(a.) processing your application/enrolment of our services, programmes and/or products;
(b.) responding to your application/ enrolment of our services, programmes and/or products;
(c.) development and delivery of our services, programmes, activities, facilities and benefits;
(d.) performing our administrative, education, academic and research functions;
(e.) health and safety;
(f.) organising centre, parents and alumni activities;
(g.) maintaining your child’s learning records and providing references;
(h.) responding to your enquiries and complaints;
(i.) conducting surveys, research, analysis and internal trainings for improvement of our programmes, services and/or websites;
(j.) making disclosure when required by law, regulation, or court order of any jurisdiction, and/or as requested by any court, governmental, supervisory or regulatory authority or administrative organisation or entity, whether in or outside Hong Kong (including the Education Bureau and the Centre for Health Protection in Hong Kong);
(k.) (subject to your consent) offering you our services, programmes and products, including sending you marketing and promotional materials relating to our services, programmes and products;
(l.) (subject to your consent) conducting joint promotion events, including sending you marketing and promotional materials in relation to education-related products, services and/or businesses of our holding companies, subsidiaries and affiliated organisations and entities operating in education and related services, hospitality, insurance, and health care services, etc. (“Affiliates”);
(m.) facilitating the enrolment in and managing, and providing services, programmes and products under the membership or subscriptions of us and/or our Affiliates, which allow members to subscribe to various events, seminars and podcasts organised and/or provided by us and/or our Affiliates and to purchase educational products of us and/or our Affiliates; and
(n.) any other incidental or associated purposes relating to the above, or any other purpose which you may from time to time agree.

Job application and/or staff employment: We collect, retain and use your personal data for the following purposes:
(a.) processing your application and issues during the course of employment with us;
(b.) responding to your application and issues during the course of employment with us;
(c.) development and delivery of our services, programmes, activities, facilities and benefits;
(d.) our performance of administrative, education, academic and research functions;
(e.) health and safety;
(f.) organising centre activities;
(g.) facilitating the provision of benefits, compensation and payroll, including MPF contributions and medical insurance;
(h.) responding to your enquiries and complaints;
(i.) conducting surveys, research, analysis and internal trainings for improvement of our programmes, services and/or websites;
(j.) making disclosure when required by law, regulation, or court order of any jurisdiction, and/or as requested by any court, governmental, supervisory or regulatory authority or administrative organisation or entity, whether in or outside Hong Kong (including the Education Bureau and the Centre for Health Protection in Hong Kong); and
(k.) any other incidental or associated purposes relating to the above, or any other purpose which you may from time to time agree.

4. We do not sell, rent or trade your personal data to or with third parties, but may, for or in connection with the aforesaid purposes, disclose and/or transfer your personal data to:

(a.) our Affiliates (including CTF Education Group Limited);
(b.) third parties (within or outside Hong Kong) engaged by us, for or in connection with the purposes specified in paragraph 3 above, including any agent, contractor, or third party service provider who provides administrative, legal, telecommunications, computer, payment, data processing or other services to our centre; and
(c.) any court, governmental, supervisory or regulatory authority or administrative organisation or entity, whether in or outside Hong Kong.

5. We would like to use your and/or your child’s personal data in direct marketing, including without limitation sending you information regarding our products, services, events and promotions. We would also like to provide your personal data to our Affiliates for use in direct marketing, in particular the education programmes, courses, learning materials and children’s related products and services (including but not limited to newsletters, photos, videos, publications, media), information, products, services, events and/or business. The types of personal data we intend to use and/or provide for direct marketing purposes include name, contact number and e-mail address.

Please note that we may not so use or provide your and/or your child’s personal data for direct marketing purposes unless we have received your consent. At the time of collection of personal data, you will be given the opportunity to give your consent/indication of no objection to the proposed use and/or provision of personal data for direct marketing purposes.

If you have consented to the use and/or provision of your and/or your child’s personal data for direct marketing purposes, you may always opt out at a later date by contacting us through our contact details at paragraph 9.

6. When you browse our website(s), cookies will be stored in your computers, mobile phones or other devices for internal navigation and programming only. We may use cookies and other tracking mechanisms described below to track information about your use of our website(s) (“Tracking Data”). We may combine this Tracking Data with other personal data we collect from you, in which case such Tracking Data shall be considered your personal data for the purpose of, and will be used in accordance with, this Privacy Policy Statement.

Cookies are alphanumeric identifiers that we transfer to your computers, mobile phones or other devices through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our website(s), while others are used to enable a faster log-in process, or to allow us to store and track information about your interests and preferences at our website(s).

We may also engage third parties to track and analyse non-personally identifiable data from the website(s). We use the data collected by such third parties to help us administer and improve the quality of our website(s) and to analyse usage of the same. This is unrelated to and separate from your personal data. Such third parties may combine the non-personally identifiable data that we provide about you with other information that they have collected. You can edit your browser settings to disable cookies but if you do so you may not be able to utilise certain functionality of our website(s).

If you interact with VPP on social media platforms, we can interact with you and send you messages via these platforms. We will interact with you in accordance with the social media platform’s rules but we are not responsible for how the platform operators collect and handle your personal data. We are not responsible for what third parties post on our social media accounts.

7. VPP will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are or are to be used. Generally speaking, the personal data will be retained for so long as it is necessary for the fulfilment of the purpose for which the data is collected or for a maximum of 7 years, unless we are under any legal obligation to retain the same for a longer period.

8. VPP will endeavour to ensure that your personal data is kept secure from unauthorised disclosure or access. Only authorised personnel of VPP (who are bound by a duty of confidentiality) will have access to these records, or we will procure by contract or use our reasonable endeavours to ensure that those who we share your personal data with act in accordance with this Privacy Policy Statement. However, we cannot guarantee the security of your personal data transmitted over the internet or any telecommunications networks.

9. You are entitled to request access to, make a copy of, and request us to make correction of, or demand the cessation of the continued collection, processing and use, or to delete your personal data stored in our records at any time by addressing such requests in writing to us at Victoria Playpark, 24/F, Capital Centre, 151 Gloucester Road, Wanchai, Hong Kong or email to pr@victoriaplaypark.com. All such requests will be handled promptly in accordance with the requirements of the applicable laws and regulations in relation to personal data protection. We may charge a reasonable fee for processing your data access request.

10. If there is any inconsistency or conflict between the English and Chinese version of this Privacy Policy Statement, the English version shall prevail.