This policy sets out the basis on which AfterSchool Education Limited (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called “AfterSchool” or “we”) collects personal data from you and how we process such data.
By visiting our website afterschool.com.hk (our “Site”) or using AfterSchool or any other applications or software we provide from time to time (collectively our “App”), you accept and consent to the practices set out below.
- Information You Provide to Us Directly
AfterSchool may collect different information from or about You depending on the manner in which You use the Services. The following examples are provided to help You better understand the information We may collect through Your use of the Services. Please note, AfterSchool is not responsible for how others use information that is publicly available or otherwise accessible to others who have access to the Services. When You sign up for and use the Services (including through a Third Party Platform) We will collect any information You provide to Us directly such as the following:
- Registration Information:
In order to use certain features of the Services, such as purchasing or registering for a Course, You are required to register for an Account, and in that case, We will collect and store any registration information You provided to Us, such as e-mail address, password, Your date of birth, and age, and we will assign You a unique identifying number (“Registration Information”).
- Profile Information:
You may also have the option of providing additional information about Yourself, including but not limited to a photo, headline, website link, social media profiles, or other information you may choose to enter (“Profile Information”) to create a profile (“Profile”). Your Profile and Profile Information will be publicly viewable to others.
- Public Posting / Shared Content:
Some of the Services may allow You to interact with other Users and/or post, share, communicate or otherwise transmit content publicly, such as by posting comments in a Course page, sending messages to others, or posting photos (collectively “Shared Content” or “Public Posting”). We may collect and store Public Postings and Shared Content. Shared Content or Public Postings may be publicly available or viewable by others depending on where such content is posted. You hereby grant AfterSchool a non-exclusive right and license to reproduce, distribute, publicly perform, offer, market and otherwise use and exploit the Public Postings and Shared Content.
- Course Information:
AfterSchool allows You to enroll in and take online Courses on a variety of topics which are taught by Instructors where, among other things, You will see reviews for Courses by others. We collect information relating to taking Courses, including, without limitation, course, assignment, and quiz completion activity, interchanges with the Course Instructors, teaching assistants and other Students, answers to questions, essays and other items submitted to satisfy the Course requirements, (“Course Information”).
You hereby consent to Our sharing of Registration Information (except for your email address), Profile Information, and Course Information to Instructors and teaching assistants. AfterSchool does not provide Students’ email addresses to Instructors or teaching assistants. AfterSchool does not control how Instructors or teaching assistants treat Registration Information, Profile Information, or Course Information and is not liable for Instructors’ or teaching assistants’ use of such information.
- Payment Information:
If You make any purchases through our Services, such as for Courses, We may collect certain information regarding Your purchase (such as Your name and zip code) as necessary to process Your order. You will be required to provide certain payment and billing information directly to our payment processing partners, including but not limited to Your name, credit card information, billing address and zip code. We do not access, store or collect Your credit card information.
If You are an Instructor, We may enable You to link Your PayPal account or other payment account to the Services so that We can pay You. When You link such account, You allow Us to collect and use certain information from such accounts to provide those payments, such as Your payment account email address or account ID, physical address, and other information necessary for Us to send payment to such account. We do not access, store, or collect Your payment card or bank account information. The collection, use, and disclosure of Your information will also be subject to the privacy policies and other terms of the payment account providers. You should review such privacy policies, terms, and other agreements.
- Information Received Through Your Third Party Platform:
The Services may contain third party links or allow You to access the Services through Third Party Platforms, such as Facebook. If You use Our Services on or through a Third Party Platform, including via any any mobile and/or other Internet connected devices (“Wireless Devices”), or click on third party links, the collection, use, and disclosure of Your information and Your use of the Services will also be subject to the privacy policies and other terms of such third parties or Third Party Platforms. You should review such privacy policies, terms, and other agreements.
- Sweepstakes, promotions, and Surveys:
1.8. Communications, Support Requests, Potential Abuse:
- Information We Collect Through Automated Means
- Technical and Usage Data
When You access the Services, including browsing Our Courses, We collect certain information by automated means. This information may include without limitation: (a) technical information about Your computer or Wireless Device, such as Your IP address, device type, operating system type and version, unique device ID, browser, browser language, domain and other systems information, platform types (collectively, “Technical Information”); and (b) usage statistics about Your interaction with the Services, including Courses accessed, time spent on pages or the Services, pages visited, search queries, click data, portions of the Services used, date and time, and other information regarding Your use of the Services (collectively, “Usage Data”).
Geolocation Information: IP addresses received from Your browser or device may be used to determine Your approximate location, such as the city, state and/or country associated with an IP address.
- Cookies and Data Collection Tools
We may also employ web beacons or other technology for a variety of reasons such as: (i) allowing Us to know if a certain page was visited or whether an e-mail was opened; (ii) allowing Us to advertise more efficiently by excluding our current Users from certain promotional messages or identifying the source of a new installation.
AfterSchool uses the following types of cookies:
Preferences. We use preferences cookies to remember information about Your browser and how You prefer to use Our Service, i.e. to remember Your preferred settings that affect the experience of how Our Services look to You or behave when You access and/or use them, such as Your preferred language. Preference cookies make Your experience of interacting with Our Services more functional and customized to suit Your preferences.
Security. We use security cookies to enable You to log-in and access Our Service, to protect Your Account against fraudulent log-ins by others, and help detect, fight, and protect against abuse or unauthorised usage of Your Account.
Functional. We use functional cookies to make the experience of using Our Services better, like remembering the volume at which You like Your videos to play.
Session State. We use session cookies to collect information about how You interact with Our Services, to help Us improve Our Services, as well as improve Your browsing experience. We also use session cookies to remember Your log-in details and to be able to process Your purchases of Courses. These are deemed strictly necessary to the working of the Services. If these are disabled, then various functionalities of our Services will be broken.
We may use third-party browser and mobile analytics services on our Service, including but not limited to Google Analytics, Full Contact, Hotjar, and Intercom. These service providers use the sort of technology described above to help us analyze how users use the Services, including by noting the third-party website from which you arrive, how often You use the Services, the events that occur within the Service, usage data, performance data, and where the application was downloaded from.
The information collected will be disclosed to or collected directly by these service providers, and We use this information to improve the Services, to better understand the functionality of the Services on a computer or other device, and to provide information that may be of interest to You.
- Online Advertising
We may use third-party advertising technologies that allow for the delivery of advertising about our Services on other websites You visit and other applications You use. The ads may be based on various factors such as the content of the page You are visiting, information You enter such as Your age and gender, Your searches, demographic data, user-generated content, and other information we collect from You. These ads may be based on Your current activity or Your activity over time and across other websites and online services and may be tailored to Your interests.
We use third parties (e.g., ad networks and ad servers such as Google Analytics, DoubleClick and others) to help deliver these tailored advertising on other websites and in mobile applications. These third parties may place cookies or other tracking technologies on Your computer, mobile phone, or other device to collect information about Your use of the Services as discussed above and may access these cookies or other tracking technologies on Your computer, mobile phone, or other device You use to access the Services in order to serve these tailored advertisement. We also may share with third-party advertisers a hashed version of Your email address that is anonymized and cannot be used to identify you, solely in non-human readable form and content that You share publicly when using the services (e.g, user-generated content) for purposes of delivering tailored advertising.
When using a mobile application you may also receive tailored in-application advertisements. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems in order to opt-out of tailored in-application advertisements. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.
Please note that to the extent advertising technology is integrated into the Services, You may still receive advertisements on other websites and mobile applications even if You opt-out. In that case, the advertising will not be tailored to Your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices You make using these mechanisms or the continued availability or accuracy of these mechanisms.
- How We Use the Information We Collect
- We use information held about you for the following purposes:
- providing, improving and developing our services;
- researching, designing and launching new features or products;
- presenting content and information in our Site and our App in the most effective manner for you and for the device you use;
- providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
- collecting overdue amounts;
- complying with laws and regulations applicable to us in or outside of Hong Kong;
- responding or taking part in legal proceedings, including seeking professional advice;
- for direct marketing purposes (please see further details in Clause 2.2 below);
- communicating with you and responding to your questions or requests; and
- purposes directly related or incidental to the above.
- We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose andyou may opt out any time. For the purpose of this clause:
- the personal data that may be used in direct marketing are those that you provide to us or we collect from you;
- the type of services or products that may be offered or advertised will be our online courses;
- the relevant information may be sent to you by email, in-app message, sms or WhatsApp message;
- you may opt out any time by WhatsApp us at +852 69717813. We will cease to send you marketing information without charge.
- We use information held about you for the following purposes:
- When and How We May Share/Disclose Your Information with Third Parties
We will keep your personal data we hold confidential but you agree we may provide information to:
- any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Schedule 1 of the Securities and Futures Ordinance (Cap. 571) of the Law of Hong Kong;
- personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);
- our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);
- persons under a duty of confidentiality to us;
- persons to whom we are required to make disclosure under applicable laws and regulations in or outside of Hong Kong; or
- actual or proposed transferees of our operations (or a substantial part thereof) in or outside of Hong Kong.
- About You with other Users
As mentioned above your Profile Information may be publicly viewable, including to other Users. In addition, if you ask a question to an Instructor or Teaching Assistant, information about you, such as your name, may be publicly viewable by other Users.
- Analytics and Data Enrichment Services
As discussed above, We use third-party analytics such as Full Contact, Google Analytics, Mixpanel, and Hotjar to help understand Your usage of our services and to improve our Service. We also use data enrichment services such as Clearbit, Intercom, and InsideView. We may provide Your contact information, Registration Information, Technical Information, Usage Data, or de-identified data or to data enrichment services to such third party analytics and data enrichment service providers, which match such information with publicly available database information, including contact and social information from other sources, such as Your email address, gender, company, job title, photos, website URLs, social network handles and physical addresses. We use this combined information to communicate with You in a more effective and customized manner.
- Business Transfers, Sales, Mergers, or Divestitures
In the event that AfterSchool undergoes a business transition, such as a merger, acquisition, corporate divestiture or dissolution (including bankruptcy), or a sale of all or a portion of its assets, We may share, disclose or transfer all of Your information to the successor organization in such transition or during steps in contemplation of such activities (e.g., due diligence).
- With Your Permission
- Aggregate or De-identified Information
We may disclose or use aggregate or de-identified information for any purpose.
We may share Your information in connection with any Promotion You enter on or through the Services, as necessary to administer, market, sponsor, or fulfill the Promotion or as required by applicable laws, rules or regulations (for example, to provide winners’ lists or make required filings as appropriate) or in accordance with the applicable rules of the Promotion. We may share Your information with a third party assisting us in administering the Promotion.
- Advertising of Third Party Products/Services
While we do not currently offer advertising on the Services, if we do offer advertising in the future, we may use and share with third party advertisers (and other third parties) certain Technical Information, Usage Information and/or Aggregate Information to show general demographic and preference information among our Users. We may also allow advertisers to collect Technical Information or Aggregate Information, which they may share with Us, through the use of tracking technologies like cookies and web beacons. The information collected may be used to offer You targeted ad-selection and delivery in order to personalize Your User experience by increasing the likelihood that advertisements for products and services You see will appeal to You, a practice known as behavioral advertising, and to undertake web analytics (i.e. to analyze traffic and other end User activity to improve Your experience).
- Social Media Features
Safety, Security, Cooperation with Law Enforcement, & Compliance with Legal Obligations
- All information you provide to us is stored on our secure servers.
- Any payment transactions will be encrypted using TLS/SSL technology.
- Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
- We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
- We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
- Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
- Your Choices Regarding the Use of Your Information
You can always choose not to provide certain information to Us but You may not be able to use certain features of the Services. If You do not wish to receive promotional communications from Us, You can opt-out by: (i) following the unsubscribe instructions provided in the promotional communication You receive; or (ii) managing Your e-mail preferences by signing into Your Account, clicking on the Account Settings link under the Your Profile button in the site header, and navigating to the Notifications tab.
Please note that despite Your opt-out choice or indicated email preferences, We will still send You transactional and/or relationship messages regarding the Services, including, for example, administrative confirmations, order confirmation, important updates regarding the Services, and notices regarding our policies.
The browser You use may provide You with the ability to control cookies or other types of local data storage. Your Wireless Device may provide You with choices around how and whether location or other data is collected and shared. AfterSchool does not control these choices, or default settings, which are offered by makers of Your browser or mobile device operating system.
You may also have other choices as descried in the Advertising of Third Party Products/Services section. If You have any questions about Your information, our use of this information, or Your rights when it comes to any of the foregoing, contact us a firstname.lastname@example.org.
We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our App after the changes come into effect means that you agree to be bound by the revised policy.
- Contact us
If you have any questions, comments or requests regarding personal data, please address them to: Tse Chi Fung Ronald, Manager, email@example.com