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Privacy Notice

PRIVACY NOTICE

Welcome to our privacy notice. REDed (”we”, “our”) is committed to protecting and respecting your privacy. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide directly through this website.

Please read the following carefully to understand our views and practices regarding your personal data and how we will use it.

For the purpose of the Data Protection Act 2018 (the Act), we are the data controller.

You may contact us to find out more about the way we use personal data via email at info@red-ed.com.

You have the right to make a complaint at any time to the Office of the Privacy Commissioner for Personal Data (the PCPD) in Hong Kong for data protection issues. https://www.pcpd.org.hk/

We would, however, appreciate the chance to deal with your concerns before you approach the PCPD so please contact us in the first instance.

IF YOU DO NOT PROVIDE PERSONAL DATA

If we need to process the data you provide us with to fulfil our service, and you fail to provide that data when requested, we may not be able to perform the service, in which case, we may have to cancel a service you have with us. We will of course notify you if we need to cancel a service.

WHAT INFORMATION DO WE USE?

We will collect and process the following information about you:

  • Personal Information. You give us this information by filling in forms on our website (www.reded.com) that you may access directly or through another website, or by corresponding with us by e-mail. It only includes basic personal data required for us to communicate with you if you become a customer, for you to be able to use our site, purchase our services, subscribe to our services, and report a problem with our website. The information you give us may include your full name, email address, physical address, phone number, photographs, geo-location, video introductions, nationality, your proficiency in the English language, educational qualifications, identification (i.e. passport or driver’s licence), professional experience, and email addresses of referees and referrals.
  • Information we collect about you.With regard to each of your visits to our website we will automatically collect the following information:
  • our communications with you or between you and other users on the website;
  • content statistics (e.g. your input on the website);
  • technical information, including device identifiers, device type, geo-location information, connection information, statistics on page views, traffic to and from the website, the Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, ad data and platform; and
  • information based on your activities on the website, including the mobile network information, full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
  • Information we receive from other sources. This is information we receive about you if you use any of the other websites we operate or the other services we provide. We are working closely with third parties (e.g. business partners, sub-contractors in technical, payment and delivery services, search information providers, credit reference agencies). We will notify you when we receive personal data about you from other sources and the purposes for which we intend to use that information.
COOKIES

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and allows us to improve our website. This website uses a cookie control system which you accept on your first site visit. For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

HOW DO WE USE THIS INFORMATION?

We will only use personal data when the law allows us to. You will not be subject to decisions based on automated data processing without your prior consent. Most commonly, we will use your personal data in the following circumstances:

  • where we need to perform the contract we are about to enter into or have entered into with you;
  • to provide you with our email notifications, newsletters and marketing communications at either your request or with your consent when completing a registration form for the service;
  • where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests;
  • to ensure that our service is delivered efficiently, including where we wish to notify you of any changes to the service, generate relevant content, tailor the website to your interests, and improve your visibility to potential collaborators;
  • to provide customer service to you in relation to your use of the service, to deal with inquiries and complaints relating to the use of the service and to notify you about any changes to our service;
  • to administer, support, improve, optimise and develop our service;
  • for internal record keeping, marketing and demographic studies to improve the services that we provide;
  • for security purposes;
  • where we need to comply with a legal or regulatory obligation; and
  • to investigate potential breach of our terms and conditions.

We will ask for your consent before using information for a purpose other than those that are set out in this privacy notice.

AUTOMATED DECISION MAKING

We may use automated decision making in processing your personal information for some services and products. You can request a manual review of the accuracy of an automated decision if you are unhappy with it.

MARKETING

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your contact details and technical data that we collect about you, such as your IP address and the way you browse our website to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services through us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time at info@red-ed.com.

THIRD-PARTY MARKETING

We will get your express opt-in consent before we share your personal data with any external company for marketing purposes.

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to know how the processing for the new purpose is compatible with the original purpose, please email us at info@red-ed.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

HOW DO WE SHARE YOUR INFORMATION?

Upon registration, your username and user ID will be linked to your activity on the website.

You acknowledge and agree that from time to time we have the right to share your personal information with:

Selected third parties including:

  • Paypal for processing payments; 
  • Wechat pay for processing payments; 
  • Ali pay for processing payments; 
  • PayMe for processing payments; 
  • Layerstack Cloud Server Service in Hong Kong, for website hosting and Private Email for contacting you by email;
  • select business partners, suppliers and sub-contractors for the performance of any contract we enter into with you.

Other than as expressly set out in this Privacy Notice or as otherwise required or permitted by law, we will not share, sell, or distribute any of the information you provide us without your consent.

We will disclose your personal information (i) to any third party to whom disclosure is necessary to enable us to fulfil your orders and provide you with any service which you have subscribed to; (ii) where required to do so by law or court order; and (iii) to any person to whom disclosure is necessary to enable us to enforce our rights under this privacy notice or under our Terms and Conditions.

This includes when:

  • We sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
  • We or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets.
  • If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms and Conditionsand other agreements; or to protect our rights, property, or safety, our customers, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
WHERE DO WE STORE YOUR INFORMATION?

All personal data we process is processed by our remote teams within Hong Kong and the USA.

For the purposes of IT hosting and maintenance this information is located on servers in Hong Kong.

Our external third parties, Paypal, Wechat, Alipay and PayMe are based outside of Hong Kong so their processing of your personal data will involve transferring your data outside of Hong Kong.

Whenever we transfer your personal data out of Hong Kong, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • When we use certain service providers, we may use specific contracts approved by the PCPD which gives personal data the same protection it has in Hong Kong.
  • When we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Hong Kong and the US.
  • Appropriate security measures will be adopted to protect your information from access by unauthorised persons and against unlawful processing, accidental loss, destruction and damage.

Please contact us atinfo@red-ed.com if you want further information on the specific mechanism used by us when transferring your personal data out of Hong Kong.

Once we have received your information, we have a Data Protection regime in place to oversee the effective and secure processing of your personal data and we will use strict procedures and security features to try to prevent unauthorised access.

Unfortunately, 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 website at transmission stage; any transmission is at your own risk.

HOW LONG DO WE KEEP YOUR DATA FOR?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We generally retain your data for 6 months.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

We are required under Hong Kong tax law to keep basic personal data about our customers (name, address, contact details) for a minimum of seven (7) years after which time it will be destroyed.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

You can ask us to delete your data in some circumstances. See below for further information.

CHILD USERS

Safeguarding the privacy of young children is of the utmost importance to Red Education. Due to the latter, we have developed specific elements created to help safeguard personal information relating to children who are under 18 years of age. Red Education does not allow a minor to register for Red Education courses and services unless the child’s parent or guardian has provided consent for such registration and use of the services and lessons provided by our site. If Red Education discovers that personal information of persons under 18 years of age has been logged on the Red Education site without parental consent, then Red Education will implement stringent appropriate measures to ensure this information is deleted. If you are a parent or guardian and learn that your child under the age of 18 has an account with Red Education without your consent, please contact Red Education at info@red-ed.com and request that Red Education remove that child’s personal information from its systems and servers.

During the registration process, if we detect the User is under the age of 18, we do not keep or make use of data collected from the Child User apart from the parent’s email address.
When a child under the age of 18 (“Child User”) seeks to register on the Website, Red Education will seek consent from the child’s parent or guardian (“Parent”). During the initial registration process, if we detect the User is under the age of 18, we do not keep or make use of data collected from the Child User apart from the parent’s email address.

In order to provide consent for a child if you are a parent and guardian you must first register on the site. Once you have completed registration, you may set up an account for your child, monitor its data on an ongoing basis and delete your child’s account as you wish.

Red Education attempts to prevent a Child User’s access to specific elements that could result in the Child User revealing personal information that would be visible to other Users. If you are the Parent of a Child User, please warn your Child User of the dangers of posting personal information on the Red Education site or other online services.

WHAT ARE YOUR RIGHTS?

Under certain circumstances, you have rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of processing your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.
EXERCISING YOUR RIGHTS

If you wish to exercise any of your rights set out above, please email us at info@red-ed.com

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

CHANGES TO OUR PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this page and notified to you by e-mail. By continuing to use this website, you are agreeing to the changes that have been made, and any future changes, to the policy.

THIRD-PARTY LINKS

Our website may contain links to websites or access to plug-ins and applications. We do not control and accept any liability or responsibility for third-party websites. This privacy notice is not applicable to other websites. Please consult the terms and conditions and privacy policies of third-party websites to find out how they collect and use your personal data.

SOCIAL MEDIA PLATFORM

All communications and actions carried out on third-party social media platforms will be subject to the terms and conditions and privacy policies of those websites. Please note that we will never ask for your personal or sensitive information through social media platforms. Please only discuss sensitive information through email.

This website may use social sharing buttons which allow you to share web content quickly on a social media platform. Please use such buttons at your discretion as the third-party platform may track and save your request.

CHANGES TO OUR PRIVACY NOTICE

Any changes we make to our privacy notice in the future will be posted on this page and notified to you by e-mail. By continuing to use this website, you are agreeing to the changes that have been made, and any future changes, to the policy.