Privacy Policy – PRIVACY POLICY STATEMENT (PPS)

PRIVACY POLICY STATEMENT (PPS) OF PTI PROFESSIONAL DEVELOPMENT LIMITED (version 3.0)

Last updated: 18 March, 2020

 

This PRIVACY POLICY STATEMENT OF PTI PROFESSIONAL DEVELOPMENT LIMITED (The PRIVACY POLICY STATEMENT) describes practices and policies regarding data collected, 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).

This PRIVACY POLICY STATEMENT is related to the Personal Data (Privacy) Ordinance of Hong Kong Special Administrative Region (HKSAR). This PRIVACY POLICY STATEMENT applies to both customers who have registered an user account (User Account) with us (i.e. “Users” or “Registered Users”) and non-Users of PTI visiting our website(s), including but not limited to course participants of our pure distance learning courses (PDLCs) and online examinations (online exams).

You understand that your use of the products &/or services &/or User Account &/or website(s) of PTI will be governed by this PRIVACY POLICY STATEMENT and shall be deemed an integral part of the agreements entered between you and PTI.

This PRIVACY POLICY STATEMENT is subject to revisions, amendments or updates at PTI’s sole and absolute discretion from time to time, By posting the revised PRIVACY POLICY STATEMENT on PTI’s website(s), PTI is deemed to have served the required notice to our Users, and customers, and such revised version shall be effective immediately.

By visiting our website(s), &/or using your User Account with us &/or using our products &/or services (including but not limited to PDLCs and online exams), you agree to this PRIVACY POLICY STATEMENT 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, associated 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 collaborating with PTI in providing pure distance learning courses, including but not limited to accreditation, validating course content &/or materials &/or certification of the relevant qualification, awarding the certificates etc.

Upon passing the required online exams, 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 the relevant accreditation and award-granting authorities as authorised by its home country regulator.

Our “online exams” may or may not be part of a PDLC. If a PDLC consists of more than one online exams, a candidate can choose to sit for one or more online exams for each online exam session and sitting, subject to restrictions on sequence of sitting for any specific online exam(s).

“Pure Distance Learning Courses”, “Pure Distance Learning Programmes”, or “PDLCs” refer to courses and programmes offered online by or through PTI in collaboration with Our PDLCs Partners through e-study materials, audio training materials or other means through the internet, without any face to face delivery of the course by PTI &/or any of Our PDLCs Partners, or any of our agents.

 

B. Information Collected By PTI – Statement of Practices

 

  1. Personal Data

For Registration of a User Account

At the time of your registration as a User, please note that it is mandatory for you to provide the following data:

  • Title
  • Name (including First Name, Middle Name, and Surname)
  • Contact Phone Number
  • Email address (i.e. login account)
  • Address
  • Country
  • Password

 

For Registration and Enrolment of a PDLC &/or Online Exam

At the time of your registration and enrolment of a PDLC &/or an online exam, please note that it is mandatory for you to provide the following ADDITIONAL data:

  • title
  • name (including first name, middle name, and surname)
  • age group
  • identity document* number (ID card or passport)
  • email address (i.e. login account)
  • address
  • country
  • zip code
  • professional qualifications (including designation, country, and awarding association)
  • education information (including level, university/institution, country where completed, and programme)
  • employment information (including employer, industry, job title, job field, years of experience in different areas, e.g. debt & capital markets, financing, etc. , source you know the exam, and major reason for enrolling for the PDLC)
  • country/jurisdiction for taking the online exam
  • upon passing an online exam of our PDLCs, we will put your name in the pass list of the online exam for that online exam session to be published on our website(s)
  • upon certification for the relevant qualification of any of our PDLCs, we will put your name, and qualification year in a register which is open to the public on our website(s)

*Note: Except China and HK (where ID card numbers should be given), course participants in all other countries/jurisdictions should provide passport number.

Besides the above personal data, we also collect your below information regarding EACH of the PDLCs and online exams you have registered and enrolled:

  • online exam answer scripts
  • online exam marks and results
  • if any, remarked exam answer scripts
  • if any, change in online exam marks and results
  • history of registration, enrolment of PDLCs and online exams
  • history of all PDLCs and online exams passed or failed

 

General Information

In addition to the above 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, or 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, associated companies, 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.

However, PTI does not maintain any data of your credit card information. For each payment you make on our website(s), you will be automatically diverted to the website of PayPal, on which you will enter your credit card information directly.

 

3. Other Products and Services Sold Through Our Website(s)

Products &/or services of our parent companies, subsidiaries, associated companies, affiliated companies, or business partners may be sold on PTI’s website(s), or website(s) linked to or referenced from PTI’s website(s). 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(s) through the use of various technologies, including cookies, and other data including your internet protocol (IP) addresses and domain name, the type and configurations of browsers, full Uniform Resource Locator (URL), language settings, geo-location, operating systems and version, clickstream information such as the page viewed and the links clicked, our products viewed, searched for or purchased, previous sites visited, and time/durations and the pages visited. (collectively “visitor information”).

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 the settings but if you do so you may find that certain features on the website would not work properly.

During an online exam, we may also collect visitor information & cookies as mentioned above for tracking & monitoring whether course participants & any suspected online exam misconduct behaviour.

 

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, associated companies, 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.

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 the Personal Data (Privacy) Ordinance of Hong Kong, where the data user uses data subject’s data in direct marketing with the prescribed information, either orally or in writing, the data subject has to reply to the 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 an online exam, year of being certified for a qualification of a PDLC for direct marketing of PTI’s (or in collaboration with our partners) PDLCs, online exams, 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, environmental &/or corporate governance &/or other products/ service providers etc.

At User Account registration, course application, or enrolment of our PDLCs and online exams, you will be asked the questions shown below.

If you would like to receive such information, please put a tick in EACH of the respective “Yes” box to indicate your consent for questions (2) to questions (4) below under Section “C. Communications to Users” in our website(s):

 

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 want to receive such communications from PTI, you must indicate your consent on your preference. If you only tick certain “Yes” box(es), only information in that specific category as mentioned in the respective questions will be sent to you.

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 the registration process, you may exercise your opt-out rights if you choose not to receive such type(s) of information from PTI by sending an email to pdc@the-pti.com, together with: (1) your account login information, (2) your registered User number, (3) your name, and (4) type of direct marketing information you would like us to cease using your personal information.

 

 C. Statement of Purposes for Data Collected

 

The Statement of Purposes captures the purposes for which the personal data collected by PTI will be used.

Data Collected for User Registration

At the time of your registration as a User, please note that it is mandatory for you to provide the following 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 that 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.

 

For Registration and Enrolment of a PDLC &/or Online Exam

At the time of your registration and enrolment of a PDLC &/or an online exam, please note that it is mandatory for you to provide the following ADDITIONAL data:

  • title
  • name (including first name, middle name, and surname)
  • age group
  • identity document* number (ID card or passport)
  • email address (i.e. login account)
  • address
  • country
  • zip code
  • professional qualifications (including designation, country, and awarding association)
  • education information (including level, university/institution, country where completed, and programme)
  • employment information (including employer, industry, job title, job field, years of experience in different areas, e.g.debt & capital markets, PE, and bank financings etc., years of management experience, source you know the exam, and major reason for enrolling for the PDLC)
  • country/jurisdiction for taking the online exam
  • upon passing an online exam of our PDLCs, we will put your name in the pass list to be published on our website(s)
  • upon certification for relevant qualification of any of our PDLCs, we will put your name, and qualification year in a register which is open to public on our website(s)

*Note: Except China and HK (where ID card numbers should be given), course participants in all other countries/jurisdictions should provide passport number.

These types of personal data collected and maintained by us are mainly for processing of PDLCs registration and enrolment orders, online exam enrolment orders, sitting online exams, verification of course participants identity, delivery of our PDLCs, online exams, and our products &/or services, facilitation of website(s) and study materials access (if any), performing analysis on our course participants profile, compilation of aggregate statistics on website(s) usage, for direct marketing as elaborated in sections below etc.

In particular, the collection of identity document number is to verify course participants identity, and it is also to protect your interests, so we can verify your identity, as well as for fairness to other course participants, i.e. to reduce chances of cheating of a candidate by asking someone else to sit an online exam.

If you do not provide your identity document number, we would not be able to verify your candidate identity, and in fairness to other course participants, your online exam results will become void in such cases.

In the event that you do not provide other personal data mentioned above, we may not be able to process your orders for registration &/or enrolment of our PDLCs &/or online exams &/or viewing or accessing our study materials (if any) &/or unable to allow you to sit for our online exams, or to provide you with our products &/or services. 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.

 

Information Relating to Registration &/or Enrolment of PDLCs &/or Online Exams

We also collect your below information regarding EACH of the PDLCs and online exams you have registered and enrolled:

  • online exam answer scripts
  • online exam marks and results
  • if any, remarked exam answer scripts
  • if any, change in online exam marks and results
  • history of registration, enrolment of PDLCs and online exams
  • history of all PDLCs and online exams passed or failed

Your online exam answer scripts would be passed to Our PDLCs Partners for moderation of the marking process, approval and as our quality assurance process.

By registering &/or enrolling for a PDLC &/or online exam, you agree we would transfer your answer script to our relevant PDLCs Partner for moderation of marking process, approval and as our quality assurance process. However, no personal information of you will be transferred, or disclosed to Our PDLCs Partners.

The above information regarding your registration &/or enrolment of PDLCs &/or online exams and PDLC & online exam answer scripts, and exam results are for moderation and approval of the exam paper marking process, to keep records for your online exam results and PDLCs, as records in your User Account, reference for your request(s) for remarking of your answer scripts, for other administrative purposes regarding our PDLCs and online exams registration and enrolment, and as reference for your fulfillment of the qualification requirements for the relevant PDLC or online exam, and approval for membership with our relevant PDLCs Partner.

 

General Information

In addition to above 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, or Our Business Partners

 

Details of the above data collected are elaborated below:

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, associated companies, 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 the 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 any data of your credit card information. For each payment you make on our website(s), you will be automatically diverted to the website of PayPal, on which you will enter your credit card information directly.

 

Other Products and Services Sold Through Our Website(s)

Products &/or services of our parent companies, subsidiaries, associated companies, affiliated companies, or business partners may be sold on PTI’s website(s), or website(s) linked to or referenced from PTI’s or third party website(s). 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 with Members of The PTI Group, Our PDLCs Partners, and Our Business Partners.

However, no personal data of our Users will be transferred 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 PDLCs Partners, or Our Business Partners, will be sent by PTI directly.

 

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(s) 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 the page viewed and links clicked, our products viewed, searched for or purchased, previous sites visited, and time/durations and pages visited. (collectively “visitor information”).

The 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 the purposes of analysing visitors’ activities, marketing intelligence information, managing and improving our website(s).

During an online exam, we may also collect visitor information as mentioned above for tracking & monitoring whether any suspected or actual exam misconduct behaviour.

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 the settings but if you do so you may find that certain features on website would not work properly.

 

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, associated companies, 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 or business partners from time to time.

 

Direct Marketing

Under Personal Data (Privacy) Ordinance of Hong Kong, where data user uses data subject’s data in direct marketing with the prescribed information, either orally or in writing, the data subject has to reply to data user indicating his or her consent, or no objection.

For Users, we will use your name, your phone number, email, address, country. For course participants who have enrolled for our PDCLs &/or online exams, we will use your name, your phone number, email, address, country, zip code, education information, professional qualification, employment information, year of passing an online exam, year of being certified for a qualification of a PDLC for direct marketing of PTI’s (&/or in collaboration with our partners) PDLCs, online exams, professional trainings, consulting services, data services, books, as well as products and services of banks, investment banks, private equity firms, private equity funds, finance companies, other products/ service providers etc. However, we can not use your personal data without your consent.

At User Account registration, application, registration or enrolment of our PDLCs &/or online exams, you will be asked the questions shown below.

If you would like to receive such information, please put a tick in EACH of the respective “Yes” box to indicate your consent for questions (2) to questions (4) below under Section “C. Communications to Users” in our website(s):

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 want to receive such communications from PTI, you must indicate your consent on your preference at the time of your User Account registration, course application, registration or enrolment. If you only tick certain “Yes” box(es), only information in that specific category will be sent to you.

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, or third parties, unless with your prior written consent.

After the User Account &/or course application, &/or registration &/or enrolment of our PDLCs &/or enrolment process, you may exercise your opt-out rights if you choose not to receive such type(s) of information from PTI by sending an email to pdc@the-pti.com, together with: (1) your account login information, (2) your registered User number, and (3) your name, and (4) type of direct marketing information you would like us to cease using your personal information.

 

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 that all our employees uphold these obligations.

We undertake to protect security of the 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, and third parties, 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’, course participants’ 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.

 

E. Statement of Possible Transferees

 

Data on aggregate basis in summary form, including visitors’ data of our website(s), Our PDLCs Partners’, 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 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.

We may need to transfer your personal data to Member Companies of The PTI Group, or Our PDLCs Partners, or Our Business Partners only if necessary, and we foresee the purposes of such cases would be for certification of your qualification, regarding approval or renewal etc. of your membership with Our PDLCs Partners &/or Our Business Partners &/or maintenance of our IT system &/or continuation of offering of our services. Without your personal data, it would not be possible for our PDLCs Partners &/or Business Partners to process your certification or membership application &/or renewal. However, we will first obtain your prior written consent, BEFORE transfer of your individual personal data.

 

F. Statement of Rights of Access & Correction of Contact Details

 

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 the data subject of the request

For DAR, we only accept written requests, and oral requests would not be acceptable. If the requestor is not our Registered User, written authorization must be provided to prove the requestor has the 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 the 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 the 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(s), 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 would result in disclosure of personal data of a third party.

If we do not hold 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 person or party, in order to prevent unauthorized amendment(s) of personal data of him/her.

However, if a User 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 the following information:

  • 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 the 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. 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 the requestor is not data subject of the request, written authorization must be provided to prove the requestor has authority for such Data Correction Request.

Under Personal Data (Privacy) Ordinance of Hong Kong, if personal data to which a DCR is an expression of opinion, and if 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 corrected data within 40 calendar days upon receipt of a DCR to the 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 DCR.

As required under the Personal Data (Privacy) Ordinance of HK, a log entry containing particulars of the reasons for the refusal of DCR will be kept by PTI for four years.

 

G. 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 Personal Information Collection Statement (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”.

Currently, PTI has so far issued two PICSs as follows:

  1. THE PERSONAL INFORMATION COLLECTION STATEMENT-USER ACCOUNT REGISTRATION (PICS-UAR) which is applicable when our customers register for a User Account, and
  2. THE PERSONAL INFORMATION COLLECTION STATEMENT FOR PURE DISTANCE LEARNING COURSES (PICS-PDLCs), which applies when a candidate registers and enrols for a Pure Distance Learning Course &/or online exam.

 

H. Statement of Security Measures

 

The information you submit in completing an online registration order form in our website(s). For order you place, you will be diverted to the website of PayPal to enter your payment information like credit card information. PTI does not collect any of your credit card information.

PTI strives to protect our Users’ privacy. PTI has adopted protective measures such as collecting data from customers/Users only if necessary, and restricting access of personal data to relevant employees on a “need-to-know” basis.

 

I. Opt-out Rights

 

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:

pdc@the-pti.com

In your request to cease using your personal data for direct marketing, please provide the following information:

  • your name,
  • your registered User number,
  • your login account, and
  • the type of direct marketing information you would like us to cease using your personal information.

 

J. Data Retention Policy

 

After you have registered as our Users, your data will be maintained by PTI.

The personal data of our Users will be maintained by PTI on on-going basis, unless we receive a request from a User to cancel and close his or her User Account.

Request for canceling/closing your account should be sent to the following e-mail address, together with (i) your login account number, (ii) your name, and (iii) registered User number:

pdc@the-pti.com

Users should note such cancellation request is irreversible and irrevocable. However, if such User would like to make new purchase or would like to re-join, he or she would have to register as User all over again.

In general, after we have received request from a User to cancel his or her User Account, or for personal data which has been deleted as a result of the User’s request (but with exceptions where User deleted his/her own personal data himself/herself), his/her personal data will be maintained for seven years after effective date of User Account cancellation or deletion, and after which personal data of such member will be deleted permanently.

Where User deletes his/her own personal data himself/herself, his/her personal data will be maintained for seven years after date of our most recent back-up files, and after such date personal data of User will be deleted permanently.

 

K. Data Integrity

 

You undertake to keep your personal data maintained with us current and up-to-date. If there is any change in your personal data, you also undertake you will login to your account and update the data yourself accordingly, or send a DCR to us as mentioned above as soon as practicable.

 

L. Security of Login Information and Password

 

You are responsible for maintaining confidentiality of your User Account and password, in order to help prevent unauthorized access &/or amendment of your personal data. You agree to accept responsibility for all activities that occur under your User Account and password.

You undertake to keep your password in safe manner, and not to disclose to any person. If you really have to write it down, you undertake to make sure that it is kept in safe manner or properly locked.

 

M. Our Business Partners` or Third Parties` Websites Linked to Our website(s)

 

Our PDLCs Partners &/or Our Business Partners may be sold on or via website(s) linked to or referenced from website(s) of PTI, such website(s) will be governed by Privacy Policy Statement (PPS) and where applicable, Personal Information Collection Statement (PICS) of the relevant website.

In using our products &/or services &/or User Account &/or our website(s), you may be directed to third party website(s) linked to or referenced from our website(s).

While PTI will endeavour to maintain a 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. Please note PTI will not take 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).

 

N. Enquiries Regarding Our PRIVACY POLICY STATEMENT

 

In case of enquiry regarding our PPS or our PICS, please email to:

pdc@the-pti.com

 

O. Governing Laws

 

The PPS of PTI is construed and governed by laws of the Hong Kong SAR.