Privacy Policy

Effective Date: 14 April 2026

1. Introduction and Company Information

This Privacy Policy explains how Harbourview Learning Centre (“we”, “us”, “our”) collects, uses, discloses, stores, and protects personal data in connection with our educational services, admissions, student support, communications, website, and related operations.

We are committed to protecting personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and, where applicable, the guidance and codes issued by the Office of the Privacy Commissioner for Personal Data, Hong Kong.

Business Name: Harbourview Learning Centre
Address: Harbourview Learning Centre, 18/F, Tower 2, One Harbour Square, 181 Hoi Bun Road, Kwun Tong, Hong Kong
Email: [email protected]
Phone: +852 2867 4931

2. Data Collection and Processing

We may collect and process personal data from students, parents, guardians, applicants, visitors, staff, contractors, and other individuals who interact with us. The types of personal data we may collect include:

Identification and contact details, such as name, gender, date of birth, address, email address, and telephone number;
Student and educational records, such as enrolment information, class placement, attendance, academic progress, assessment results, learning support needs, and disciplinary records;
Parent or guardian details, including relationship to the student and emergency contact information;
Payment and billing information, such as invoice details, transaction records, and payment status;
Health, safety, and welfare information relevant to student care, including allergies, medical conditions, special educational needs, and emergency information, where necessary and appropriate;
Images, audio, or video recordings captured during classes, events, activities, or on our premises, where permitted by law and/or consented to;
Communications with us, including enquiries, feedback, complaints, and correspondence;
Technical data, such as IP address, browser type, device information, and website usage data when you use our website or digital services;
Any other information you voluntarily provide to us or that is required for the provision of our services.

We may collect personal data directly from you, from your authorised representatives, from schools or educational partners, from payment processors, from publicly available sources, or from other third parties where lawful and appropriate.

Where you provide personal data relating to another person, you confirm that you have the authority to do so and that the other person has been informed of this Privacy Policy where required.

3. Purpose of Data Processing

We process personal data for the following purposes:

To provide educational, training, tutoring, enrichment, and student support services;
To process admissions, registrations, enrolments, and class administration;
To assess learning needs, monitor progress, maintain academic records, and support student development;
To communicate with students, parents, guardians, and other authorised contacts;
To manage fees, invoices, payments, refunds, and related financial administration;
To ensure student welfare, health, and safety, including emergency contact and incident management;
To organise events, activities, outings, and school-related programmes;
To maintain internal records, business operations, quality assurance, and service improvement;
To comply with legal, regulatory, accounting, tax, safeguarding, and reporting obligations;
To respond to enquiries, complaints, and requests;
To prevent, detect, and investigate misconduct, fraud, security incidents, or misuse of our services;
To conduct marketing and promotional communications, where permitted by law and subject to your preferences;
To operate and secure our website, systems, and premises;
For any other purpose directly related to the above or for which you have given consent.

4. Legal Basis for Processing

Under the PDPO, we process personal data in a manner consistent with the Data Protection Principles, including the requirement that personal data be collected for a lawful purpose directly related to our functions or activities and that the data collected be adequate but not excessive.

Depending on the context, our processing is based on one or more of the following grounds:

Performance of a contract or steps taken before entering into a contract, such as enrolment and service delivery;
Compliance with legal obligations, including statutory, regulatory, accounting, safeguarding, and record-keeping requirements;
Legitimate interests in operating, securing, improving, and administering our educational services, provided such interests are not overridden by your rights and interests;
Consent, where required or appropriate, particularly for optional activities, marketing communications, or the use of images and recordings in certain contexts;
Protection of vital interests, such as in emergencies involving health or safety;
Public interest or lawful authority, where applicable under Hong Kong law.

Where we rely on consent, you may withdraw it at any time, subject to legal or contractual restrictions and reasonable notice.

5. Data Sharing and Third Parties

We do not sell personal data. We may disclose personal data to third parties only where necessary and lawful for the purposes described in this Privacy Policy.

Recipients may include:

Parents, guardians, or authorised representatives of students;
Teachers, tutors, administrative staff, and management personnel on a need-to-know basis;
Service providers supporting our operations, such as IT hosting, cloud storage, communication tools, payment processing, accounting, printing, and document management;
Professional advisers, including lawyers, auditors, accountants, insurers, and consultants;
Educational partners, activity providers, venues, or transport providers involved in programme delivery;
Government authorities, regulators, law enforcement agencies, courts, or other persons where disclosure is required or permitted by law;
Emergency services or medical personnel where necessary to protect health or safety;
Any other party with your consent or at your direction.

We require third-party service providers to handle personal data in accordance with applicable data protection obligations and to use it only for authorised purposes.

6. Data Transfer to Third Countries

Some of our service providers, systems, or collaborators may be located outside Hong Kong. As a result, personal data may be transferred to, stored in, or accessed from jurisdictions outside Hong Kong.

Where such transfers occur, we will take reasonable steps to ensure that the recipient provides a standard of protection comparable to that required under the PDPO, including through contractual safeguards, access controls, and security measures where appropriate and practicable.

By using our services or providing personal data to us, you acknowledge that cross-border transfers may occur as part of our operations. Where required by law, we will obtain your consent or take additional measures before such transfer.

7. Storage Duration

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, to resolve disputes, and to enforce our agreements.

Retention periods may vary depending on the type of data and the purpose for which it is held. In general:

Student and enrolment records are retained for the period necessary for educational administration and for a reasonable period thereafter;
Financial and accounting records are retained for the period required by applicable law and tax/accounting standards;
Health, safety, and incident records are retained for as long as necessary for safeguarding and legal purposes;
Communications and enquiry records are retained for a reasonable period to manage follow-up and service quality;
Marketing contact details are retained until you opt out or withdraw consent, where applicable.

When personal data is no longer required, we will securely delete, anonymise, or destroy it in accordance with our retention procedures and applicable law.

8. User Rights

Subject to the PDPO and any applicable exceptions, you may have the following rights in relation to your personal data:

Access: request access to personal data we hold about you and information about how it is used;
Rectification: request correction of inaccurate, incomplete, or outdated personal data;
Erasure: request deletion of personal data where it is no longer necessary or where deletion is otherwise appropriate and lawful;
Restriction: request that we limit the processing of your personal data in certain circumstances;
Data portability: request a copy of certain personal data in a structured, commonly used format, where applicable and technically feasible;
Objection: object to processing based on legitimate interests or to direct marketing, where applicable.

To exercise any of these rights, please contact us using the details provided below. We may need to verify your identity before responding. We will respond within a reasonable time and in accordance with applicable law.

Please note that certain rights may be limited where the PDPO or other laws permit or require us to retain or process the data.

9. Withdrawal of Consent

Where we rely on your consent to process personal data, you may withdraw that consent at any time by contacting us using the details below or by following any opt-out instructions provided in our communications.

Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal. If you withdraw consent, we may no longer be able to provide certain optional services or participate in certain activities, where consent is necessary for those purposes.

10. Right to Complain

If you believe that we have handled your personal data in a way that does not comply with the PDPO or this Privacy Policy, please contact us first so that we can investigate and address your concerns.

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong:

Website: https://www.pcpd.org.hk
Telephone: +852 2827 2827
Address: 12/F, 248 Queen’s Road East, Wan Chai, Hong Kong

11. Data Security

We implement reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, disclosure, or misuse.

These measures may include:

Access controls and role-based permissions;
Password protection and authentication measures;
Encryption or secure transmission methods where appropriate;
Physical security controls for premises and records;
Staff confidentiality obligations and privacy training;
Regular review of systems, procedures, and security practices;
Backup and recovery measures;
Incident response procedures for suspected data breaches.

While we take reasonable steps to protect personal data, no method of transmission or storage is completely secure. We cannot guarantee absolute security, but we will act promptly and in accordance with applicable law if a data breach occurs.

12. Contact Information

If you have any questions, requests, or concerns regarding this Privacy Policy or our handling of personal data, please contact us:

Harbourview Learning Centre
Harbourview Learning Centre, 18/F, Tower 2, One Harbour Square, 181 Hoi Bun Road, Kwun Tong, Hong Kong
Email: [email protected]
Phone: +852 2867 4931

13. Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any revised version will be posted on our website or otherwise made available to you, and the “Effective Date” will be updated accordingly.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your personal data. Your continued use of our services after any changes become effective constitutes your acknowledgement of the updated Privacy Policy, to the extent permitted by law.

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