Bright from the Start

Bright from the Start

Privacy Policy

We are committed to protecting your privacy.

We are committed to complying with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong.  In doing so, we will ensure that our staff will comply with appropriate standards of privacy, security and confidentiality.

This Privacy Policy (the “Privacy Policy”) sets out our policies and practices regarding how your personal information will be collected, stored and used. The Privacy Policy applies to all registered and unregistered users of the [*] website ([website address]) (the “Website”) and may from time to time be updated or revised.  These updates and changes form part of the Privacy Policy.

By using this website, you consent to our collection and use of your personal data in accordance with the Privacy Policy.

In the event that there is any inconsistency between the English and the Chinese version of the Privacy Policy, the English version shall prevail.

Minimal Collection of Personal Data

“Personal data” means any identifying information or sensitive data (including but not limited to name, identity card number, gender, date of birth, contact details, occupation, email address and credit card information, etc) of a person.

We collect your personal data when you register as a user or at times when you are requested to furnish us with your personal data. We always aim to collect the minimum amount of personal information necessary for us to complete the purposes for which we are collecting the personal data.

If you are under the age of 18, please seek prior consent from your parent or guardian before providing us with any of your personal data.

The purposes for which we may use your personal data include but are not limited:

(a) to provide and download content to you;

(b) to process your orders, send billing to and receive payment from you;

(c) to handle and follow up your service calls, enquiries and complaints;

(d) to better understand the demographics of our users and members to enable us to provide better services tailored to your needs;

(e) to verify your identity;

(f) for our future marketing purposes and those of third parties; and

(g) for such purposes as would enable us or our affiliates or the transferees of such personal data to provide website or other electronic services verification of your identity.

Disclosure to Third Parties

In cases where we do collect personal data from you, we will :

(a) inform you that we are doing so and provide the use that we will make of such personal data;

(b) where required by applicable laws, give you the opportunity to “opt out” of our use of such personal data.  However, we may not be able to provide certain (or any) services or content to you if you do opt out of such use.

We agree to take all practicable steps to keep your personal data confidential but we may transfer/assign such personal data to the following parties :

(a) any actual or proposed assignee, transferee or successor of our rights in respect of our users;

(b) any party as required by law;

(c) our affiliate companies; and

(d) third party service providers.


Except as expressly mentioned in the Privacy Policy, we will not disclose your personal data unless we are required to do so by law or we reasonably believe that such action is necessary to :

(a) comply with the laws or applicable regulations;

(b) protect and defend our rights and property;

(c) protect against misuses or unauthorised use of our website; or

(d) protect the personal safety or property of our users or members or the public.

Links to Other websites

The Privacy Policy only applies to the Website. If you click on any hyperlink or advertisement linking to another website that is provided on the Website, you will leave the Website for another location. At any other 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 that other location (if any).

Web Logs

When you come to the Website, our server software may record the domain name of your computer. We may also track the pages you visit. We do these recordings and tracings so that we can measure the traffic, gauge the popularity of various parts of the Website, gain some general knowledge about our visitors, and market the Website to advertisers with whom we may share traffic data. This information will not identify you as an individual.


Once we have collected your personal data, it will be maintained securely in our system. Your personal data, however stored, will be accessed only by our employees or contractors who are authorised to do so in accordance with the Privacy Policy. We shall take every step to ensure that your personal data is properly protected. However, despite our efforts, no data security measures can guarantee absolute security at all times. We do not warrant or guarantee the security of any information you provide to us.

Use of Personal Data in Legal Proceedings

If it becomes necessary to take action against you for any reason whatsoever including recovering from you any money you owe us, you expressly agree that the personal data provided by you can be relied upon in identifying and taking legal action against you.


Retention of Your Personal Data

We will retain your personal data for as long as necessary to complete the purposes for which we collected that personal data, except where we are otherwise required to retain such data in accordance with law. Should you or we terminate your account for any reason, we will take steps to ensure that your personal data is no longer available through the Website, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.


Your Rights to Access, Correct and Update Your Personal Data

You may at any time request access to, correct and update personal data relating to you in any of our records. You may also ask us to delete you from any active mailing or distribution list kept by us. To exercise any of your aforesaid rights, please contact us at our email address below . In response, we may ask you to provide certain details about yourself so that we can be sure you are the person to whom the personal data refers.

How to Contact Us

If you have any questions about our Privacy Policy, please contact us at