Privacy Policy & Personal Information Collection Statement

Privacy Policy

Broad Gain Trading Limited ("Broad Gain") and our parent, subsidiary affiliated, associated and/or related companies ("Affiliates") value your personal data and privacy. We know how important it is to protect your personal data and we are committed to comply with the requirements of Personal Data (Privacy) Ordinance.

If you are a parent or guardian, this Privacy Policy shall apply to both your own personal data and the personal data of your child provided to us, and in such case the term “your personal data” shall be construed accordingly.

Unless your express consent is required by applicable law and regulations in relation to personal data protection, by providing us with your personal data, you are accepting the terms of this Privacy Policy and consenting to our collection, retention, disclosure and use of your personal data in accordance with this Privacy Policy, as amended from time to time. Further, subject to your consent, we will only use and transfer your data for direct marketing purposes as specified in this Privacy Policy. 

If you are under the age of 18, you should provide a copy of this Privacy Policy and other data privacy related documents provided by us to your parent or guardian and obtain their consent before you provide us with your personal data.

The terms of this Privacy Policy may be updated, revised, varied and amended from time to time as we deem necessary and the latest version will be available on our website: https://www.k12buddies.com/ ("Website"). Any such change, update or modification will be effective immediately upon posting. We will obtain your consent for changes to the terms of this Privacy Policy if such consent is required by applicable law. Any reference in these terms to "we", "us" and "our" is a reference to Broad Gain and our Affiliates. Please read this Privacy Policy carefully to understand how we will handle your personal data.

This Privacy Policy should be read together with the Personal Information Collection Statement in this Website (the “PICS”), provided that, in the event of any inconsistency between this Privacy Policy and the PICS, the PICS shall prevail. In the event of any discrepancy or inconsistency between the English and Chinese versions of this Privacy Policy, the English version will prevail.

1. How do we collect personal data and what do we collect?

1. Sources of personal data
   We may collect personal data from you by the following channels:
   1. when you register for membership via the Website;
   2. when you register to use, or enter information into, any of our interactive services;
   3. when you purchase goods and services via the Website;
   4. when you correspond with us; and
   5. when you use this Website.
2. Types of personal data we collect
   We may collect from you and your child under 18 the following information which may contain personal data as defined under applicable data protection laws and regulations:
   1. account registration information, including name, date of birth, contact number and email address;
   2. the class and campus where your child is enrolled;
   3. billing information, transaction and credit card information (if you make a purchase from us);
   4. shipping information (where applicable); and
   5. records of correspondence between you and us.

All information we collect about you may be combined with other information we hold about you.

2. How do we use personal data?

Personal data provided by you to us will be used for the following purposes:

1. to process your purchase of our goods and/or services;
2. to process your application for membership of K12 Buddies and maintaining and managing your membership;
3. to identify and verify your identity and/or as a member holding valid membership of Website;
4. (subject to your consent) to offer you with our goods and services, including sending you goods and services-related information and/or marketing and promotional materials relating to our products, services and programmes;
5. (subject to your consent) to conduct joint promotion events, including sending you marketing and promotional materials in relation to education-related goods and services and/or businesses of Affiliates operating in education and related services, hospitality, insurance, and health care services, etc;
6. (subject to your consent) to conduct joint promotion events, including sending you marketing and promotional materials in relation to education-related goods and/or services of our partner operating in education and related services (“Marketing Partner”);
7. daily management, operation and maintenance of this Website;
8. to handle and follow up with customer service calls, enquiries and complaints;
9. to send you administrative notices and communications relevant to your use of our Website and to respond to your enquiry or request;
10. to perform research or statistical analysis in order to improve our goods and services;
11. to obtain statistics about users of our Website to analyse site usage in order to help its further development;
12. to provide you with a log-in ID for our Website; and
13. to make such disclosures as required by law.
    
    

Please note that we may not so use or provide your and/or your child’s personal data for direct marketing purposes unless we have received your consent. At the time of collection of personal data, you will be given the opportunity to give your consent/indication of no objection to the proposed use and/or provision of personal data for direct marketing purposes.

If you have consented to the use and/or provision of your and/or your child’s personal data for direct marketing purposes, you may always opt out at a later date by contacting us through our contact details set out in paragraph 7 hereinbelow.

You are not obliged to provide the personal data as may be required by us. However, we may not be able to provide you with our goods and services or our Marketing Partners' information, sales and marketing materials if you do not provide us with the requested data.

3. Will your personal data be given to other persons?

We may disclose and/or transfer your personal data to the third parties (within or outside of Hong Kong) to fulfil the purpose of collection, including but not limited to:

1. our Affiliates and third parties (within or outside Hong Kong) engaged by us, for or in connection with the purposes specified in paragraph 2 above, including any supplier, agent, contractor, or third party service provider who provides administrative, legal, telecommunications, computer, payment, data processing or other services to Broad Gain; and
2. any competent court of law, law enforcement agencies and/or regulators and government departments for compliance with applicable laws and regulations and protection of our legal rights. 

4. Retention of your personal data

We will retain your personal data for a period no longer than necessary for the fulfillment of the purposes for which they are or are to be used.

5. Security

Protection of your personal data collected is a priority for us. We will always strive to ensure that your personal data will be protected against unauthorised access. We are based in Hong Kong. Your personal data may be accessed by us or transferred by us to and accessed by the third parties listed in paragraph 3, in Hong Kong or elsewhere in the world. Such personal data are only accessible by us or the personnel of the third parties for the purposes listed in paragraph 2, who will be instructed to observe confidentiality duty and the terms of this Privacy Policy when accessing such personal data.

Although we will do our best to protect and secure your personal data, we cannot guarantee the security of your personal data transmitted over the internet or any telecommunications networks.

6. Use of cookies and links to other websites

Cookies

1. We do not collect any personally identifiable information from you while you visit and browse our Website (unless you provide such information to us) but we do use cookies to keep track of how often you visit our Website, tailor our services to your needs, estimate our audience size, gauge the popularity of various parts of our Website, track users' progress, track number of entries in our sales and marketing activities and measure our Website users' traffic patterns. Information and data collected by means of cookies will not be disclosed to anyone save and except for the third parties listed out in paragraph 3.
2. Most web browsers are automatically set to accept cookies, but you can usually alter the settings of your browser to prevent automatic acceptance. If you choose not to use cookies you may not be able to take full advantage of our Website. For more information on cookies and how to disable them, please refer to www.allaboutcookies.org.

Pixel Tags

When you visit this Website or view one of our emails, we may use pixel tags (also called "clear gifs"), tracking links, and/or similar technology to note some of the pages you visit on our Websites and to personalise your experience. We may also use pixel tags to determine what types of email your browser supports. We may use the information collected through pixel tags, tracking links, and similar technology in combination with your personally identifiable information.

Links to other websites

1. To provide you with more information, our Website may provide links to other websites. Your personal data may be collected on these other websites when you visit them or make use of their services. Where and when you decide to click on any advertisement or hyperlink on our Website which grants you access to another website, your personal data may be exposed in these other websites.
2. This Privacy Policy is only applicable to our Website and we are not responsible for the third party websites or for any personal data you submit to such other websites via our Website. Please ensure that you read the privacy policies of such other websites.

7. Data access and correction

1. You have the right to, at any time, request access to, make a copy of, and request us to make correction of, or demand the cessation of the continued collection, processing, and use, or to delete your personal data stored in our records. To exercise your rights, please email us at [email protected].
2. In the event that you wish to exercise your right as set out above, we may request you to provide personal details in order to verify your identity. We will endeavour to respond to your request in accordance with requirements under applicable data protection laws and regulations, and we may charge you a reasonable fee for complying with your access request as permitted under applicable law.

8. Enquiry

If you have any queries about our Privacy Policy, please email us at [email protected].

Personal Information Collection Statement (“PICS”)

Broad Gain Trading Limited (“Broad Gain”) and our parent, subsidiary, affiliated, associated and/or related companies (“Affiliates”) value your personal data and privacy. If you are a parent or guardian, this PICS shall apply to both your own personal data and the personal data of your child provided to us, and in such case the term “your personal data” shall be construed accordingly.

This website ("Website") is an on-line shopping platform operated by Broad Gain ("K12 Buddies"). It provides you with the goods and services related to education. By collaborating with ecosystem partners, K12 Buddies will also provide additional education resources and exclusive learning opportunities to support you and your child. 

Unless your express consent is required by the applicable laws, by providing your personal data to us, you agree to the terms of this PICS and indicate your consent for us to collect, retain, disclose, transfer and use your personal data in accordance with this PICS, as amended from time to time. Further, subject to your consent, we will only use and transfer your personal data for direct marketing purposes as specified in this PICS.   If you are under the age of 18, you should provide a copy of this PICS and other data privacy related documents provided by us to your parent or guardian and obtain their consent before you provide us with your personal data.

Any reference in these terms to "we", "us" and "our" is a reference to Broad Gain and our Affiliates.

1. What data do we collect and process

Broad Gain collects the following data for the purpose of processing your purchase of goods and services and communication:

1. Name 
2. Contact number 
3. E-mail address 

If you register via this Website, we may collect data relating to you and/or your child (if applicable) such as the following to facilitate the provision of services via the Website: 

1. account registration information, including name, date of birth, contact number and email address;
2. the class and campus where your child are studying;
3. billing information, transaction and credit card information (if you make a purchase from us); 
4. shipping information (where applicable); and
5. records of correspondence between you and us.

2. Purposes of collection

Personal data provided by you to us will be used for the following purposes:

1. to process your purchase of our goods and/or services;
2. to process your application for membership of K12 Buddies and maintaining and managing your membership;
3. to identify and verify your identity and/or as a member holding valid membership of Website;
4. (subject to your consent) to offer you with our goods and services, including sending you goods and services-related information and/or marketing and promotional materials relating to our products, services and programmes;
5. (subject to your consent) to conduct joint promotion events, including sending you marketing and promotional materials in relation to education-related goods and services and/or businesses of Affiliates operating in education and related services, hospitality, insurance, and health care services, etc;
6. (subject to your consent) to conduct joint promotion events, including sending you marketing and promotional materials in relation to education-related goods and/or services of our partner operating in education and related services (“Marketing Partner”);
7. daily management, operation and maintenance of this Website;
8. to handle and follow up with customer service calls, enquiries and complaints;
9. to send you administrative notices and communications relevant to your use of our Website and to respond to your enquiry or request;
10. to perform research or statistical analysis in order to improve our goods and services;
11. to obtain statistics about users of our Website to analyse site usage in order to help its further development;
12. to provide you with a log-in ID for our Website; and
13. to make such disclosures as required by law.

Please note that it is obligatory for you to provide the personal data that we request and marked with “*”. If you do not provide such personal data, we may not be able to provide our goods and services to you.

We will retrieve your child's and your personal information collected by our schools when you using the token provided by the school to pre-fill or auto-fill your registration form for the Website to facilitate the registration process of membership. 

3. Recipients of personal data 

We may disclose and/or transfer your personal data to third parties (within or outside Hong Kong) to fulfil the purpose of collection, including without limitation to:

1. our Affiliates and third parties (within or outside Hong Kong) engaged by us, for or in connection with the purposes specified in paragraph 2 above, including any supplier, agent, contractor, or third party service provider who provides administrative, legal, telecommunications, computer, payment, data processing or other services to Broad Gain; and
2. any competent court of law, law enforcement agencies and/or regulators and government departments for compliance with applicable laws and regulations and protection of our legal rights.

We may also disclose and/or transfer your personal data to our Affiliates and/or our Marketing Partners. If your personal data will be used by our Affiliates and/or our Marketing Partners for direct marketing purposes, we will obtain your prior consent. 

4. Duration of processing 

We will retain any personal data for a period no longer than necessary for the fufillment of the purposes for which they are or they are to be used.

5. Rights of data subject 

Data subjects are entitled to the following rights: 

1. The right of access 
2. The right to rectification 

If you wish to exercise any of the above-mentioned rights, please make such requests by email to our customer service representative at [email protected]. All such requests will be handled as soon as practicable in accordance with the requirements of the applicable laws and regulations in relation to personal data protection. We may charge a reasonable fee for processing your data access request.

6. Privacy policy 

If you wish to know more about our privacy policies and practices, the most updated version can be found on this Website.

7. Use of personal data in direct marketing

We intend to use the personal data relating to you and your child (if applicable) for direct marketing, including without limitation sending you marketing and promotional materials relating to our goods and services. We would also like to provide your personal data to its Affiliates and/or Marketing Partners for use in direct marketing, in particular our holding companies, subsidiaries and affiliated organisations and entities operating in education and related services, hospitality, insurance, healthcare services. The types of personal data we intend to use and/or provide for direct marketing purposes are set out in Clause 2 hereinabove.

Please note that we may not use or provide your personal data for direct marketing purposes unless we has received your consent. 

8. If there is any inconsistency or conflict between the English and Chinese version of this PICS, the English version shall prevail.