Privacy Policy

1. Introduction

Growth Education Limited ("we," "our," or "the Company") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data, as well as your rights in relation to that data.

This policy complies with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and applies to personal data collected through our website, applications, and related services (collectively, the "Service").

2. Data Collection

2.1 Types of Data We Collect

We may collect the following types of personal data:

• Identity Data: Name, email address, phone number, postal address
• Account Data: Username, password, account settings
• Educational Data: School, grade level, learning progress, test results
• Transaction Data: Purchase records, payment details
• Technical Data: IP address, browser type, device information, access times
• Usage Data: Page visits, clicks, interaction patterns

2.2 Collection Methods

We collect personal data through:

• Direct Interactions: When you register for an account, purchase products, fill out forms, or communicate with us
• Automated Technologies: When you use our Service, through cookies, server logs, and similar technologies
• Third Parties: We may receive data from business partners, technology providers, and analytics providers

3. Data Use

We use your personal data for purposes including:

• Providing and managing our Service
• Processing and completing transactions
• Personalizing your learning experience
• Improving our Service and developing new features
• Communicating with you about service updates, promotions, and events
• Preventing fraud and ensuring the security of the Service
• Complying with legal obligations

3.1 Legal Basis

Our legal bases for processing your personal data include:

• Performance of a Contract: Processing necessary data to fulfill our contract with you
• Legitimate Interests: For our legitimate business interests, such as improving the Service and marketing
• Consent: In certain cases, we seek your explicit consent
• Legal Obligation: To comply with requirements under applicable laws and regulations

4. Data Sharing

We may share your personal data with:

• Service Providers: Third parties that assist us in providing the Service, such as payment processors, cloud storage providers, and analytics services
• Business Partners: Organizations that collaborate with us to provide services or promotions
• Legal Requirements: When we have a legal obligation to disclose your data, such as in response to a court order or government request
• Corporate Transactions: If we are involved in a merger, acquisition, or sale of assets, your data may be transferred

4.1 International Transfers

Your personal data may be transferred to countries or territories outside of Hong Kong. In such cases, we will ensure that appropriate safeguards are in place to protect your data and comply with applicable data protection laws.

5. Data Security

We have implemented appropriate technical and organizational measures to protect your personal data against accidental loss, unauthorized access, use, alteration, or disclosure. These measures include encryption, access controls, and regular security assessments.

While we strive to protect your personal data, please note that no method of transmission or storage is 100% secure.

6. Data Retention

We will retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by law.

In determining the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process the data, and whether we can achieve those purposes through other means.

7. Your Rights

Under the Personal Data (Privacy) Ordinance of Hong Kong, you have the following rights:

• Right of Access: You have the right to request access to the personal data we hold about you
• Right to Correction: You have the right to request correction of inaccurate or incomplete personal data
• Right to Object to Processing: In certain circumstances, you have the right to object to the processing of your personal data
• Right to Erasure: In certain circumstances, you have the right to request the deletion of your personal data
• Right to Withdraw Consent: If we process data based on your consent, you have the right to withdraw consent at any time

If you wish to exercise these rights, please contact us using the contact information provided below. We may request specific information to help us confirm your identity and ensure your right to access the data requested.

8. Cookies and Similar Technologies

We use cookies and similar technologies to collect and store information about how you use our Service. Cookies are small text files stored on your device that allow us to recognize your browser or device.

We use cookies to:

• Remember your preferences and settings
• Understand how you use our Service
• Improve our Service and user experience
• Provide personalized content and advertisements

You can control cookies through your browser settings. However, please note that disabling cookies may affect certain features of our Service.

9. Children's Privacy

Our Service is directed to students and parents and may include children (under 18 years of age). We only knowingly collect personal data from children with parental or guardian consent.

If you are a parent or guardian and believe your child has provided us with personal data without your consent, please contact us, and we will take steps to delete such information.

10. Policy Updates

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will post the updated policy on our website and notify you of significant changes.

We encourage you to review this policy periodically to stay informed about how we protect your personal data.

11. Contact Us

If you have any questions, comments, or requests regarding this Privacy Policy or our handling of your personal data, please contact us at:

Growth Education Limited
Email: info@geledtech.com

If you are not satisfied with our response to your request, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data in Hong Kong.