PERSONAL INFORMATION COLLECTION STATEMENT-USER ACCOUNT REGISTRATION (PICS-UAR) OF PTI PROFESSIONAL DEVELOPMENT LIMITED (version 2.0)
Last updated: 15 February, 2020
This PERSONAL INFORMATION COLLECTION STATEMENT FOR USER ACCOUNT REGISTRATION of PTI Professional Development Limited (“PERSONAL INFORMATION COLLECTION STATEMENT-USER ACCOUNT REGISTRATION” or “PICS-UAR”) describes practices and policies regarding data collected at time of registration of an user account (User Account) with PTI, used by, data access, data integrity, update of data, correction, maintenance, security, opting out rights, potential transfer of data etc. of PTI Professional Development Limited (PTI). After registering a User Account, the customer will become a “User” or “Registered User” of PTI’s User Accounts.
This PERSONAL INFORMATION COLLECTION STATEMENT-USER ACCOUNT REGISTRATION applies to both Users and non-Users of PTI for registration of User Account &/or visiting our website(s).
Your use of products, services, User Account, and website(s) of PTI, including those products & services offered in collaboration with our pure distance learning courses partners (PDLCs Partners), &/or our business partners (Our Business Partners), will be governed by this PICS. This PERSONAL INFORMATION COLLECTION STATEMENT-UAR is related to the Personal Data (Privacy) Ordinance of Hong Kong Special Administrative Region (HKSAR).
THE PICS-UAR is an integral part of the agreements between you and PTI.
This PICS-UAR is subject to revisions, amendments or updates by PTI and at PTI’s sole & absolute discretion from time to time, and is deemed to have served required notice to you when the new version is posted on our website(s), and shall be binding on you with immediate effect.
By using your User Account &/or our products &/or services &/or our website(s), you agree to this PICS-UAR of PTI.
A. Definitions
“We” refer to PTI Professional Development Limited (PTI).
“You”, “User(s)”, “Registered User(s)”, “candidate(s)”, or “customer(s)” refer to the same party, meaning those persons who have registered a User Account with PTI, &/or those who visit our website(s), whether or not you have purchased products &/or services from PTI. “You”, “User(s)”, “Registered User(s)”, “candidate(s)”, or “customer(s)” only refer to individual person(s) but not company(ies) or entity(ies), since only individual persons are allowed to register a User Account with us.
“Member Companies of The PTI Group” refer to PTI, its parent companies, subsidiaries and affiliated companies of PTI.
“Our Business Partners” refer to business partners and other partners collaborating with PTI from time to time including both on an on-going basis and one-off basis, including but not limited to those companies or organisations whose products &/or services are offered through or on PTI’s website(s).
“Our Pure Distance Learning Courses Partners” or “Our PDLCs Partners” collectively refer to professional associations, universities, institutions, or other entities (including their parent companies, subsidiaries, associated companies, affiliated companies, their respective shareholders, directors, management, faculties, committee members, staff, officers, professors, instructors, tutors, representatives, contractors, suppliers, agents, assignees or successors) collaborating with PTI in providing pure distance learning courses, including but not limited to accreditation, validating course content &/or materials &/or certification of relevant qualification, awarding the certificates etc.
“Pure Distance Learning Courses”, “Pure Distance Learning Programmes”, or “PDLCs” refer to courses and programmes offered on the internet by or through PTI in collaboration with Our PDLCs Partners through study materials, audio training materials or other means through internet, without any face to face delivery of the course content by PTI &/or any of Our PDLCs Partners, &/or any of our agents.
Upon passing required online exams AND fulfilment of the required working experiences AND meeting other qualification requirements, a candidate would be awarded a certificate for the relevant PDLC. The certificate may be awarded by a professional body, university, institution, or organisation with relevant accreditation and award-granting authorities as authorised by its home country regulator.
B. Information Collected By PTI – Statement of Practices
1. Personal Data
At time of your registration as a User, please note that it is mandatory to provide below data:
- Title
- Name (including First Name, Middle Name, and Surname)
- Contact Phone Number
- Email address (i.e. login account)
- Address
- Country
- Password
In the event you do not provide such personal data, we may not be able to provide you with our products &/or services &/or to process your order. In addition, since products &/or services of Member Companies of The PTI Group, Our PDLCs Partners and Our Business Partners may be sold on PTI’s website(s), failure to supply any of the required information, would result in Member Companies of The PTI Group, &/or Our PDLCs Partners, &/or Our Business Partners to be unable to provide the requested services &/or products, &/or to process your order.
These types of personal data collected and maintained by us are mainly for delivery of our products &/or services, management of Users Accounts, processing of purchase orders, facilitation of website(s) access, compilation of aggregate statistics on website(s) usage, answering enquiries of our Users regarding our products &/or services etc.
In addition to data provided by you directly, we also collect your following data:
- your transaction data,
- your purchase orders, including those under promotion campaigns,
- results of our analysis or your transaction behavior/preference,
- your purchase data relating to marketing & sales,
- aggregate summary transaction information relating to products &/or services of PTI, Members of The PTI Group, Our PDLCs Partners, and Our Business Partners,
- our website(s) visitors information & cookies as mentioned below,
- data from questionnaires sent to you, such as purchase behavior, preferences, attitudes or other data relating to or will facilitate sales & marketing of products &/or services of PTI, our parent companies, subsidiaries, associated companies, affiliated companies, Our PDLCs Partners, & Our Business Partners
Details of the above data collected are elaborated below:
2. Purchase History & Transaction Data
We will maintain data of your purchase history of products &/or services of PTI, and purchase history of products &/or services of our parent companies, subsidiaries, affiliated companies or business partners sold through our website(s), including:
- your transaction data,
- your purchase orders, including those under promotion campaigns.
- results of our analysis or your transaction behavior/preference, and
- your purchase data relating to marketing & sales.
Purposes of maintaining above data are for us to keep a record of your purchase history, performing our sales analysis, and for marketing and sales of our products and services, and of our parent companies, subsidiaries and associated companies.
However, PTI does not maintain data of your credit card information.
3. Other Products and Services Sold Through Our Website(s)
Products &/or services of our parent companies, subsidiaries, affiliated companies, or business partners may be sold on PTI’s website or website(s) linked to PTI’s website. PTI will share aggregate summary transaction information relating to products &/or services of PTI, Members of The PTI Group, Our PDLCs Partners, and Our Business Partners.
However, no personal data of our Users will be shared or disclosed with our parent companies, subsidiaries, associated companies, affiliated companies, business partners, or any third party. All email or correspondences relating to promotion of products &/or services (whether of PTI, Users of The PTI Group, or our business partners) will be sent by PTI directly.
4. Visitors’ Information & Cookies
When you visit our website(s) we will record your visit as a “hit”. We also collect information relating to your use of our website through use of various technologies, including cookies, and other data including your internet protocol (IP) addresses and domain name, type and configurations of browsers, full Uniform Resource Locator (URL), language settings, geo-location, operating systems and version, clickstream information such as page viewed and links clicked, our products viewed, searched for or purchased, previous sites visited, and time/durations and pages visited. (collectively “the visitors’ information).
Purposes of collecting such information are to provide our products and services to you, and for compiling aggregate statistics on how our Users, customers, and visitors browse our website(s). Such statistics are collected for purposes of analysing visitors’ activities, marketing intelligence information, managing and improving our website(s).
For cookies, session cookies are used. When a User logs off from his/her account or closes the browser, session cookies will lose effect.
Most web browsers are initially set up to accept cookies. You can choose to ‘not accept’ cookies by changing settings but if you do so you may find certain features on website would not work properly.
5. Other Data
We may also collect data from questionnaires sent to you, such as purchase behavior, preferences, attitudes or other data relating to or will facilitate sales & marketing of products &/or services of PTI, our parent companies, subsidiaries, affiliated companies, Our PDLCs Partners, or Our Business Partners, or to facilitate strategies formulation, internal planning, or other researches PTI, our parent companies, subsidiaries, associated companies, affiliated companies, Our PDLCs Partners, or Our Business Partners, or third parties which plan to advertise on our website(s) from time to time.
Such questionnaires for market research may be sent by PTI to you directly or by third party(ies) consultant(s) engaged by PTI, whether the engagement is on free-of-charge or paid basis by us. We will not share or transfer any of your personal data collected but may only share the aggregate summary data with our parent companies, subsidiaries, associated companies, affiliated companies, Our PDLCs Partners, Our Business Partners, or third parties.
6. Direct Marketing
Under Personal Data (Privacy) Ordinance of Hong Kong, where data user uses data subject’s data in direct marketing with prescribed information either orally or in writing, data subject has to reply to data user indicating his or her consent, or no objection.
We will use your name, your phone number, email, address, country, education information, professional qualification, employment information, year of passing one or more online exams &/or assessments, year of being certified for a qualification of PDLC, for direct marketing of PTI’s (or in collaboration with our partners) PDLCs, professional trainings, consulting services, data services, books, e-books, as well as products and services of banks, investment banks, private equity firms, private equity funds, finance companies, &/or other products/service providers etc.
At User Account registration, application, registration or enrolment of our PDLCs and online exams, please tick “Yes” box for EACH of question to indicate your consent, if you would like to receive such information:
Are you interested to receive newsletters, communications, market updates, and analysis etc. of PTI relating to financing & capital raising, debt & capital markets, and finance sector etc.?
Do you agree we will use your personal information as mentioned in the relevant PICS for marketing PTI’s (or in collaboration with our partners) PDLCs & other products?
Do you agree we will use your personal information as mentioned in the relevant PICS for marketing products and services of banks, investment banks, private equity firms, private equity funds, finance companies?
Do you agree we will use your personal information as mentioned in the relevant PICS for marketing products and services of other products/ service providers?
If you only tick a certain box, only information in that specific category as mentioned in the respective questions will be sent to you.
If you do not want to receive such communications from PTI, you must indicate your consent. If you select the “No” box or if you fail to indicate “Yes” for the question, PTI will take it as you do not want to receive the relevant communication(s) from PTI.
Please note all promotion emails for information relating to products &/or services of The PTI Group will be sent by PTI directly. No personal data of our Users will be transferred to other Member Companies of The PTI Group or Our PDLCs Partners, or Our Business Partners, unless with your prior written consent.
After registration, application or enrolment process, you may exercise your opt-out rights if you choose not to receive such type(s) of information from PTI by emailing pdc@the-pti.com, together with: (1) your account login information, (2) your registered User number, (3) your name, and (4) type of information you would like us to cease using your personal information.
C. Statement of Purposes for Data Collected
The Statement of Purpose captures purposes for which personal data collected by PTI will be used.
Upon registration as a User, please note that it is mandatory to provide:
- Title
- Name (including First Name, Middle Name, and Surname)
- Contact Phone Number
- Email address (i.e. login account)
- Address
- Country
- Password
In the event you do not provide such personal data, we may not be able to provide you with our products &/or services.
The information collected from our Users will be used for purposes of processing your purchase orders, in identifying your login information, and in managing your User account with us.
The telephone number collected is one data to verify your User Account. In addition, in case we need to contact you regarding your purchase or enquiries &/or comments on our products &/or services, we can contact you quickly. However, we will contact you by phone only if necessary.
We use “visitor information” (as defined above) for purpose of maintaining and improving our website(s), which pages have been most frequently visited etc. We use such data only for website(s) enhancement and optimization, for tracking of customers’ visit to our website(s), and as marketing intelligence information, for us to improve our services to you. We do not use, and have no intention to use visitor data to personally identify anyone.
The information collected by means of cookies on our website about you will be used only for compiling aggregate statistics on how visitors browse the website. Such statistics are collected for purpose of managing and improving website design, as marketing intelligence information, and to improve our products &/ services to you.
Data collected on aggregate basis, such as visitor information of our website or our business partners’ website(s), and aggregate purchase summary for customers as a whole may be shared or disclosed to our parent companies, subsidiaries, associated companies, affiliated companies, Our PDLCs Partners and Our Business Partners. The purpose of collecting such aggregate data in summary form is to facilitate marketing or promoting products &/or services of PTI, our parent companies, subsidiaries, associated companies, affiliated companies, and where relevant, Our PDLCs Partners, and Our Business Partners. However, we will not share or disclose personal data of any individual candidates to our parent companies, subsidiaries, associated companies, affiliated companies, Our PDLCs Partners or Our Business Partners.
Other purposes of collecting your personal data include: providing and maintaining services in connection with your User Account; performing our internal marketing, and sales or analysis, including but not limited to statistical, or transaction behavior analysis; researching, designing and innovating new products or services; planning, designing or implementing our current or future business, marketing or other strategies; complying with or performing obligations, requests, requirements for disclosing data due to or as required by laws in HK, laws of other relevant jurisdictions, regulations, guidelines, or policies etc. issued by government authorities (such as regulators, government departments, or tax authorities etc. of HK or other relevant jurisdictions).
Newsletters, Communications, Market Updates and Analysis
We intend to use your name, contact phone number, email, address, and country to send newsletters, communications, market updates, and analysis etc. of PTI relating to financing & capital raising, debt & capital markets, and finance sector etc. If you are interested to receive, pls. tick yes to below question:
Are you interested to receive newsletters, communications, market updates, and analysis etc. of PTI relating to financing & capital raising, debt & capital markets, and finance sector etc.?
Direct Marketing
We intend to use your name, contact phone number, email, address and country for direct marketing. If you are interested to receive information &/or emails relating to directing marketing of below 3 categories, pls. tick respective yes box:
Do you agree we will use your personal information as mentioned in the relevant PICS for marketing PTI’s (or in collaboration with our partners) PDLCs & other products?
Do you agree we will use your personal information as mentioned in the relevant PICS for marketing products and services of banks, investment banks, private equity firms, private equity funds, finance companies?
Do you agree we will use your personal information as mentioned in the relevant PICS for marketing products and services of other products/ service providers?
Please note all promotion emails for information relating to products &/or services of The PTI Group will be sent by PTI directly. No personal data of our Users will be transferred to other Member Companies of The PTI Group or Our PDLCs Partners, or Our Business Partners, or third parties, unless with your prior written consent.
If you only tick a certain box, only information in that specific category as mentioned in the respective questions will be sent to you.
If you do not want to receive such communications from PTI, you must indicate your consent. If you select the “No” box or if you fail to indicate “Yes” for the question, PTI will take it as you do not want to receive the relevant communication(s) from PTI.
Requests to Cease to Use Personal Data for Direct Marketing or “Opt-out” Requests
Users may at any time request to cease to use his/her personal data in direct marketing without any charge by sending an email to us at the following email address. THE REQUEST MUST BE SENT USING THE EMAIL REGISTERED WITH US to the following email address:
pdc@the-pti.com
In your request to cease using your personal data for direct marketing, please provide:
- your name,
- your registered User number,
- your login account, and
- the type(s) of communications or direct marketing information you would like us to cease using your personal information or sending to you.
D. Statement of Policy
We are committed to protecting privacy, confidentiality and security of personal data we collect and maintain by complying with requirements of Personal Data (Privacy) Ordinance of Hong Kong. We are also committed to ensuring all our employees uphold these obligations.
We undertake to protect security of data you have provided to us, and seek to prevent unauthorized access, use or disclosure of your data.
For direct marketing of products and services of Member Companies of The PTI Group, Our PDLCs Partners, Our Business Partners, we would like to disclose that we may receive fees for direct marketing their products and services.
We will not transfer your personal data to Member Companies of The PTI Group, or Our PDLCs Partners, or Our Business Partners only if necessary AND with your prior written consent, such as certification of your qualification, regarding approval or renewal etc. of your membership with Our PDLCs Partners &/or Our Business Partners.
However, we will not transfer (other than as mentioned above), sell, lease or rent any of our Users’, candidates’ or customers’ personal data to any third party, including Member Companies of The PTI Group, or Our PDLCs Partners, or Our Business Partners, unless with your prior written consent.
F. Statement of Possible Transferees
Data on aggregate basis in summary form, including visitors’ data of our website or our business partners’ website(s), aggregate purchase summary for all the customers as a whole may be shared or disclosed to our business partners &/or third parties. However, no personal data of individual Users will be disclosed or transferred to any third parties.
In addition, we will not directly sell your personal data to any company or organization, including Member Companies of The PTI Group, Our PDLCs Partners, and Our Business Partners. We also will not transfer your personal data to third parties for direct marketing or other unrelated purposes without your prior written consent.
All correspondences to promote products &/or services for direct marketing will be sent by PTI directly, whether for products &/or services of PTI, Member Companies of The PTI Group, Our PDLCs Partners, Our Business Partners or third-parties. However, no personal data of our Users will be disclosed or transferred outside PTI, without your prior written consent.
In direct marketing of products and services of Member Companies of The PTI Group, Our PDLCs Partners, Our Business Partners or third-parties, we may receive fees.
G. Statement of Rights of Access & Correction of Contact Detail
Data Access Request (DAR)
A User can access his or her personal data any time by logging in his or her User account maintained with PTI. If a User would like to request a copy of his or her own data, i.e. data access request (DAR), please send an email to:
pdc@the-pti.com
In your DAR, please provide:
- your name,
- your registered User number,
- your login account, and
- written authorization, if requestor is not data subject of the request
For DAR, we only accept written requests, and oral requests would not be acceptable. If requestor is not our Registered User, written authorization must be provided to prove requestor has authority to send such Data Access Request.
According to the Data Privacy Ordinance, a Data Access Request (DAR) refers to a written request made by an individual or a “relevant person” on behalf of an individual, to request the data user (i.e. PTI):
- to inform him/her whether the data user holds personal data of which the individual is the data subject, and
- if data user holds such data, to supply him with a copy of such data.
Prior to PTI fulfilling your DAR, we reserve our rights to require you to provide proof of your identity and after your identity has been verified to our satisfaction.
For each request to User’s own data, PTI shall within 40 calendar days after receipt of your DAR send such data to User’s email account as shown in our record only, and no hardcopy will be sent to requestor. Each User can only request access of his or her own data and will not be allowed to access data of another User or Users, unless with proper written authorization.
Each request of a User to access his or her own data is chargeable at nominal fees. To check the current fees, please email:
pdc@the-pti.com
We reserve our rights to withhold personal data if the User does not provide proof of identity to our satisfaction, or if it will disclose personal data of a third party.
If we do not hold the personal information you have requested, we will also inform you within 40 calendar days after date of receipt of the DAR.
Data Correction Request (DCR)
If a User would like to update his or her personal data, he or she can log into her or her User Account at our website(s) and update his or her personal data himself or herself.
Since a User has to login in with his or her password, Users are required to keep his or her password in a safe manner and not to disclose the password to any other party.
However, if Users would like us to perform correction of his/her personal data (i.e. Data Correction Request or DCR), please send an email to:
pdc@the-pti.com
In your DCR, please provide:
- your name,
- your registered User number,
- your login account,
- written authorization, if requestor is not the data subject,
- personal data that needs to be corrected, and
- proof of personal data that needs to be corrected
For DCR, we only accept written requests, and oral requests would not be accepted by us.
Each DCR should be preceded by a DAR, i.e. a User should first make a DAR to obtain a copy of his/her personal data and check accuracy of such data, before sending a DCR. If a DAR has been refused by PTI lawfully, the User would not be entitled to make a DCR.
If requestor is not data subject of the request, written authorization must be provided to prove requestor has authority for such Data Correction Request.
Under the Personal Data (Privacy) Ordinance of Hong Kong, if personal data to which a DCR is an expression of opinion, and PTI is not satisfied the opinion is inaccurate, PTI would make a note of such expression of opinion considered as inaccurate by the requestor, and that such data cannot be used by a person without the note being drawn to attention of, and being available for inspection by that person. PTI will also attach a copy of such note to the notice of refusal to such DCR.
If there is/are no valid ground(s) for refusal lawfully, PTI would send a copy of the corrected data within 40 calendar days upon receipt of a DCR to User’s email account as per our record, and no hardcopy will be sent to requestor.
If PTI is unable to comply with a DCR within 40 calendar days, PTI would notify the requestor in written and provide reasons within 40 calendar days.
In case of refusal of a DCR, PTI will also provide written notification and reasons for refusal to requestor within calendar days from receipt of the DCR.
As required under the Personal Data (Privacy) Ordinance of HK, a log entry containing particulars of reasons for refusal of DCR will be kept by PTI for four years.
H. Other PICSs of PTI
According to the “Guidance on Preparing Personal Information Collection Statement and Privacy Policy Statement” issued by the Office of the Privacy Commissioner for Personal Data of HK, “specific PICS to be used for specific collection purposes: If a website has more than one online form for collection of personal data each serving a different purpose, the PICS used for each form should be tailored to the particular purpose”.
In addition to the PICS-UAR, there may be other PICS of PTI for data collection for purpose other than User Account registration. Please read carefully the different PICSs of PTI prior to providing your personal data. For instance, for registration, application and enrolment of our PDLCs and online exams, THE PERSONAL INFORMATION COLLECTION STATEMENT FOR PURE DISTANCE LEARNING COURSES (PICS-PDLCs) applies.
I. Our Business Partners’ or Third Parties’ Websites Linked to Our Website
As products &/or services of our business partners are sold on or via website(s) linked to or referenced from website(s) of PTI, such website(s) will be governed by the Privacy Policy Statement (PPS) or its equivalent and where applicable, PERSONAL INFORMATION COLLECTION STATEMENT (PICS) or its equivalent of the relevant website.
Where Our PDLCs Partners, &/or Our Business Partner(s) &/or third party(ies) website(s) is/are involved, our customers may also be subject to PPS (or its equivalent, such as Privacy Policy) and PICS of Our PDLCs Partners, &/or Our Business Partner(s) &/or third party(ies).
While PTI endeavours to maintain high level of standard of security for our Users’ data, however, Users need to understand PTI has no control over websites of Our PDLCs Partners, or Our Business Partner(s) or third party(ies). Our Users are advised to study respective PPS and PICS of Our PDLCs Partners, &/or Our Business Partner(s) &/or third party(ies) carefully, before directly providing any personal data.
PTI expressly disclaim any responsibility or any liability of any kind for any loss, claims, penalty, or compensation arising from our Users providing data directly to Our PDLCs Partners, &/or Our Business Partner(s) &/or third party(ies).
I. Enquiries
In case a User has any enquiry regarding our PPS or our PICS, please email us at: pdc@the-pti.com
J. Governing Laws
The PICS-UAR of PTI is construed and governed by the laws of the Special Administrative Region of Hong Kong (HKSAR).