OnMyGrad Limited and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”; if the context requires or permits, “Company” may refer to any one of OnMyGrad Limited and/or its subsidiary(ies) and/or affiliate(s)) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via OnMyGrad.com, its sub-domains, any other websites, media platforms or applications including mobile applications operated/developed by the Company (hereinafter collectively referred to as the "Channels" ) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (“User(s)”) except to the authorized persons listed under paragraph 3 below.
This Privacy Statement is applicable to both registered and unregistered Users, and the terms herein may be updated, revised, varied and/or amended from time to time as OnMyGrad Limited may deem necessary and/or appropriate.
- Purpose of Collection of Personal Data
In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so. The Company’s purposes for collection of information and data on the Channels include but not limited to the following:
- for the daily operation of the services provided to Users;
- to identify Users who have posted views or comments or such other information (collectively “ Information”) on the Channels;
- to identify Users who have viewed the Information posted on the Channels;
- to provide the Users career coaching service or other related services offered by the Company;
- to handle and follow up service calls, enquiries, requests and complaints;
- to provide Users with event information, marketing and promotional materials for their enjoyment of benefits as members of the Channels (for further details, please refer to paragraph 4 headed “ Subscription of Newsletter/Promotional Materials/Marketing Materials” below);
- to identify Users who have enjoyed their benefits as members of the Channels by receiving and using marketing and promotional materials;
- to allow members of the Channels to enjoy their benefits as members by enrolling for special events hosted by the Company;
- to contact Users regarding administrative notices and communications relevant to the Users’ membership account maintained with the Company (if any) and/or the services offered by the Company;
- to design and provide products and services to Users in relation to the above purposes;
- to compile and analyze aggregate statistics about the Users’ use of the Channels and service usage by the Users for the Company’s internal use; and
- to facilitate the Company to use the Users’ personal data for purposes relating to the provision of services offered by the Company and marketing services, special events and/or promotions of the Company and/or its clients.
The Company strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove. If the Company requires the use of Users’ personal data for a purpose other than those set out hereinabove, the Company may request the Users’ prescribed consent to the same. Collection of Personal Data The Company may collect personal information and/or data about a User such as his/her name, log-in ID and password, address, email address, phone number, sex, education history, work history, and other personal information that is/are not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from a User in connection with contests, surveys, or special offers. Only duly authorized staff of the Company will be permitted to access the Users’ personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Paragraph 3 entitled “Disclosure or Transfer of Data”. Disclosure or Transfer of Data The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following. Generally speaking, the Company will only disclose and/or transfer Users’ personal information and/or data to the Company’s personnel and staff for the purpose of providing services to Users. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances: where the information and/or data is disclosed and/or transferred to any third party suppliers or external service providers who have been duly authorized by the Company to use such information and/or data. where the information and/or data is disclosed and/or transferred to any agents or associates of the Company who have been duly authorized by the Company to use such information and/or data; where the Company needs to protect and defend its rights and property; where the Company considers necessary to do so in order to comply with the applicable laws and regulations, including without limitation compliance with a judicial proceeding, court order, or legal process served on the Channels; and where the Company deems necessary in order to maintain and improve the services on the Channels.
Personal data collected via the Channels may be transferred, stored and processed in any country in which the Company operate. By using the Channels, Users are deemed to have agreed to, consented to and authorized the Company to disclose and/or transfer their personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the Users’ country.' Subscription of Newsletter/Promotional Materials/Marketing Materials The Company may from time to time send to members and Users of the Channels, by way of emails and/or short message service (SMS) notifications, newsletters, marketing and promotional materials and information regarding the Company or its third-party advertisers’ products, services and the like based on the personal information and data that the Users have provided to the Company. The Company may use Users’ data in direct marketing and the Company requires the Users’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that: the name, log-in ID and password, contact details, age, sex, date of birth, country of residence, nationality, education level and work experience of Users held by the Company from time to time may be used by the Company and/or its authorised personnel or staff in direct marketing; the following classes of services, products and subjects may be marketed: career related information and services; job related products and services; special events hosted by the Company for members and Users, including but not limited to courses, workshops, and competitions; reward, loyalty or privileges programmes and related products and services; special offers including coupons, discounts nad discounts products and services offered by the Company and its advertisers (the names of such entities can be found in the relevant advertisements and/or promotional or marketing materials for the relevant products and services, as the case may be); donations and contributions for charitable and/or non-profit making purposes;
The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or: third party service providers providing the products, services and subjects listed in paragraph (b) above; and charitable or non-profit marking organizations; in addition to marketing the above services, products and subject itself, the Company also intends to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products and subjects, and the Company requires the Users’ written consent (which includes an indication of no objection) for that purpose; the Company may receive money or other property in return for providing the data to the other persons in paragraph (d) above and, when requesting the Users’ written consent as described in paragraph (d) above, the Company will inform the Users if the Company receives any money or other property in return for providing the data to the other persons. Suitable measures are implemented to make available to such members the options to “opt-out” of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the membership registration or user account maintenance webpage, or clicking on the automatic link appearing in each newsletter/message, or contact the Customer Human Resource Department of the Company, whose contact details are set out under Paragraph 13 entitled “Enquiries” below.