Last updated: March 2025
This policy is written in plain language. We have tried to explain each section clearly. If anything is unclear, please contact us at [email protected] and we will do our best to help.
Harbour Atrium operates from 9/F, Tower 535, 535 Jaffe Road, Causeway Bay, Hong Kong. We offer property investment education programmes for Hong Kong residents. When we refer to "Harbour Atrium", "we", "us", or "our" in this policy, we mean the business operating under that name.
This Privacy Policy applies to personal data collected through our website at harbour-atrium.live, through our contact and enrolment processes, and in the course of delivering our educational programmes.
This policy has been prepared with reference to the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "PDPO"). The PDPO governs the collection, use, and handling of personal data in Hong Kong and sets out the rights of individuals whose data is held by organisations.
We are committed to handling personal data responsibly and in a manner consistent with the six Data Protection Principles set out in Schedule 1 of the PDPO.
We collect personal data only where it is necessary for a specific, defined purpose. The types of data we may collect include:
We do not collect sensitive personal data such as identification documents, financial account details, or health information through our website.
We use the personal data we collect for the following purposes:
We will not use your data for purposes materially different from those listed above without first informing you and, where required, obtaining your consent.
From time to time, we may wish to send you information about upcoming programmes, changes to our curriculum, or educational content we think may be relevant to your interests. We will only do this with your agreement, and only by the channels you have indicated are suitable.
Under the PDPO, you have the right to require us to stop using your personal data for direct marketing purposes at any time. You can do so by contacting us at [email protected] or by using any unsubscribe mechanism included in communications we send you.
We collect the minimum amount of personal data needed for each purpose. Where we ask for information, we aim to make clear which fields are required and which are optional. Providing optional information is entirely at your discretion.
We do not acquire personal data from commercial data brokers or compile profiles of individuals beyond what they have provided to us directly.
We retain personal data only as long as is necessary for the purpose for which it was collected, or as required by law. Our general retention periods are as follows:
After the relevant retention period, data is deleted or anonymised in a manner that prevents re-identification.
We do not sell, rent, or share your personal data with third parties for their own commercial purposes. We may share data in limited circumstances:
Any third-party providers we work with are required to handle personal data in a manner consistent with the PDPO.
We take reasonable steps to protect personal data from unauthorised access, loss, or disclosure. These include technical measures such as using encrypted connections (HTTPS) for data transmitted through our website, and organisational measures such as limiting access to personal data to staff who need it to perform their responsibilities.
No method of electronic transmission or storage is completely without risk. While we take the protection of your data seriously, we cannot warrant absolute security.
The PDPO gives individuals certain rights regarding their personal data held by organisations. These include:
To exercise these rights, please contact our Privacy Officer using the details in the section below. We will respond within 40 days as required by the PDPO. Where we decline a request, we will explain the reason in writing.
We may charge a reasonable fee for processing a data access request if permitted under the PDPO.
Our primary operations and data storage are in Hong Kong. If any data is processed outside Hong Kong (for example, through a cloud service provider whose infrastructure spans multiple jurisdictions), we take steps to ensure that an appropriate level of protection is maintained, consistent with our obligations under the PDPO.
Our courses and website are directed at adults, and we do not knowingly collect personal data from anyone under the age of 18. If you believe a minor has provided personal data through our website, please contact us and we will take steps to remove it promptly.
We may update this Privacy Policy from time to time, for example to reflect changes in our practices or in applicable law. When we do so, we will update the "Last updated" date at the top of this page. We encourage you to read this policy periodically. Where changes are material, we will take reasonable steps to bring them to your attention.
If you have questions about this policy, wish to exercise your rights, or have a concern about how we handle personal data, please contact our Privacy Officer:
If you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD). Further information is available at www.pcpd.org.hk.
You may also wish to read our Cookie Policy and Terms & Conditions.