Privacy Policy
Your privacy is important to us. This Privacy Policy describes how Enrolnet Global Limited (“we”, “our” or “us”) collects, stores, uses and discloses the following categories of personal data from and about you (where applicable) when you visit the EnrolNet Platform (as defined in the Terms and Conditions of the EnrolNet Platform (the “Terms and Conditions”)). Unless the context other requires, capitalized terms in this Privacy Policy shall have the same meaning ascribed to them in the Terms and Conditions.
This Privacy Policy applies to any personal data that is collected when you use the Services or visit the EnrolNet Platform.
You are responsible for reviewing our Privacy Policy.
If you do not wish to provide the personal data to us, then you are not obliged to do so. However, please be aware that this will affect your use of the EnrolNet Platform, and we may not be able to provide the Services to you.
We are committed to responsibly handling your personal data taking all reasonable steps to protect your information from misuse and to keep it secure in compliance with applicable laws and regulations which may include the Hong Kong Personal Data (Privacy) Ordinance (Chapter 486 of the laws of Hong Kong) (the “PDPO”), the United Kingdom General Data Protection Regulation and the Data Protection Act 2018 (“UK-GDPR”), as the case may be. We believe it is important to inform you about how we may use your personal data. You can find information about how, whether, and why we may collect and use your personal date on the EnrolNet Platform.
Our policy is to respect and protect the privacy, confidentiality and security of the personal data we collect, hold and process by complying with the PDPO and all other applicable requirements with respect to the management of personal data. We are equally committed to requiring that all employees and agents uphold these obligations. Our policy is to observe, to the extent reasonably practicable, the guiding principles set out in the PDPO which may be summarised as:
(a)
Collecting personal data fairly and lawfully and for a purpose which is lawful, necessary, adequate and not excessive;
(b)
Keeping personal data accurate, up-to-date and keeping it for no longer than is necessary;
(c)
Making sure that personal data is only used or transferred for the purpose for which it was collected;
(d)
Keeping personal data secure against loss or misuse;
(e)
Giving access to information about policies and practices in relation to personal data, the type of personal data being held and the purposes for which it will be used;
(f)
Granting data subjects a right of access to and correction of their personal data.
We may collect your personal data in order for us to be able to provide the Services. We may also collect your personal data for other related or ancillary purposes (such as to comply with our record retention obligations or to comply with the requirements of any applicable procedures, laws and regulations).
We may collect personal data about you directly from you or from third parties, and/or through the use of cookies and metadata collected on the EnrolNet Platform and the Services.
We will only collect personal data through lawful and fair means and not in any unreasonably intrusive way. Personal data is collected in a number of ways, including:
(a)
where you expressly provide this information to us, including your use of EnrolNet and the Services;
(b)
from your interactions with us (including our personnel), including by telephone, text message, e-mail communications, social media, and in person;
(c)
from your voluntary participation in surveys, reviews or marketing promotions; and
(d)
from the electronic devices you may use to access the EnrolNet Platform, including information collected from your browser’s cookies.
In some situations, EnrolNet will collect information that may include your personal data from a third party.
These third parties include:
(a)
Institutions, including secondary institutions, where you have studied or where EnrolNet reasonably believes you may have studied;
(b)
Authorities or other organizations that EnrolNet reasonably believes may hold results pertinent to your application;
(c)
Government bodies, departments and agents;
(d)
Our marketing affiliates and service providers (e.g., entities that assist us in validating the individual’s identity, or provide bank references, risk assessment, or fraud prevention services etc, and other credit reporting agencies and third party verification services providers);
(e)
Our affiliates, website hosts, live chat and online support service providers, and events vendors;
(f)
Other EnrolNet users and other EnrolNet clients or customers for the purpose of providing the Services to you or as part of a customer referral program; and
(g)
Admission centres.
We may combine the information received with other information that we collect about you.
By providing the details of an authorized person to EnrolNet (such as an Education Agent), you are consenting to the collection of your Personal Data from your authorized person.
We, and our third party service providers, automatically collect the following information about your use of the EnrolNet Platform and our online Services through cookies, web beacons, log files and other technologies (subject to your consent where required by applicable law): your domain name, your browser type and operating system, web pages you view, links you click, your IP address, the length of time you visit the EnrolNet Platform or use our Services, your activities on the EnrolNet Platform, and the referring URL or the webpage that led you to our Website.
For the avoidance of doubt and to the maximum extent permitted by applicable law, for personal data provided by a School or Education Agent, EnrolNet shall be regarded solely as a data processor, instead of a data controller or data user (as the case may be) with respect to such personal data, notwithstanding anything contrary stated herein or elsewhere.
The types of personal data we collect about you depends on your particular interaction with the EnrolNet Platform and the Services. In limited circumstances such as facilitating the application process to certain schools of interest, we may also need to collect sensitive personal data (e.g., personal data revealing racial or ethnic origin, religious or philosophical beliefs, or health information). In the event that it is necessary to collect any sensitive data about you, where required by applicable data protection laws we will obtain your explicit consent to do so. The personal data collected is only shared with EnrolNet, its affiliates (including any parent undertaking, subsidiary undertaking, holding company, subsidiary, associated company or other affiliate of EnrolNet, and any other entity within the EnrolNet group), the relevant School and Education Agent, the authority (where required by applicable law) and our third-party service providers acting as data processors for the purpose of providing the Services you request and other related or ancillary purposes (such as to comply with our record retention obligations or to comply with the requirements of any applicable procedures, laws and regulations), and will not be shared or used by us for any other purpose. Such data may be transferred in or outside Hong Kong.
| Categories of Personal Data Collected | Specific Personal Data |
| Personal Data |
Identity and contact data; full name (including any previous name(s)); billing and mailing address(es); date of birth; email address; telephone number(s); qualification information; gender; ethnicity; citizenship/residency status; language; country of birth; preferences current and previous employment history; profession, certifications and memberships; academic records, attendance records; and etc. |
| Financial and Transactional Data |
Bank account details; billing information; credit or debit card details; details of any transactions carried out using any of the Services; and payment history. |
| Special Categories of Personal Data, including sensitive data |
Information about your health, and genetic and biometric infomration; criminal record; national identification numbers and documents; and religious or philosophical beliefs. |
| Technical and Profile Data |
Device data; internet protocol address; browser type and version; operating system and platform; and username and passwords |
| Location Data |
Information about your actual location |
| Marketing and Communications Data |
Marketing and communications Data preferences in receiving marketing from us and other third-party communications; and feedback and survey responses. |
EnrolNet takes all reasonable and lawful steps to keep secure personal data collected and to keep this information accurate and up to date.
We use appropriate technical and organizational measures to protect the personal data that we collect and process. We have implemented information security policies, rules and technical measures to protect the personal data under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss. In addition, all our employees and data processors (i.e. those who process your personal data on our behalf) are obliged to respect the confidentiality of the personal data of all users of the EnrolNet Platform and those who use the Services. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal data.
Passwords
To keep your account secure, you will be asked to create a password and set up Two-Factor Authentication. We may also ask you to answer certain questions before we consider your application. You can choose to nominate a representative to act on your behalf.
Do not give your personal ID to anyone other than your nominated representative, if you choose to. Your password must not be given to anyone, even your nominated representative if any.
We will retain your personal data only as long as is necessary for the purposes for which it is collected, as set out in this Policy. We will also retain it as long as it is necessary to comply with our legal obligations, for legal and litigation purposes, and to maintain accurate financial and other records, deal with complaints, and enforce our agreements.
Generally, in respect of personal data that we process in connection with the supply of our Services, we may retain your personal data for up to six years from the date of supply of the relevant Services and in compliance with our data protection obligations. We may then destroy such files without further notice or liability.
Where we process any other personal data, we will generally retain relevant personal data for up to six years from the date of our last interaction with you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.
If any personal data is only useful for a short period (e.g., for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us. If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing communications.
The above examples may vary in some cases due to local laws, limitation periods and mandatory retention requirements.
Access and correction of personal data
If the PDPO is applicable to you, you have the right to, subject to the PDPO:
(a)
ascertain whether EnrolNet holds your personal data;
(b)
request access to your personal data; and
(c)
request the correction of your personal data that is inaccurate.
In accordance with the PDPO, EnrolNet may charge a reasonable fee for the processing of any data access request you make.
Requests for access to or correction of personal data and information about EnrolNet’s privacy policies and practice should be addressed in writing to the data privacy officer of EnrolNet at its registered address from time to time.
We reserve the right at all times to vary, change, alter, amend, add to or remove any of this Privacy Policy at our sole and absolute discretion. Please ensure that you review this Privacy Policy when you use the Website as you will be deemed conclusively to have accepted the latest version of the Privacy Policy if you continue to use the EnrolNet Platform after such latest version of the Privacy Policy has been posted on the EnrolNet Platform.
If you have any questions or concerns about this Privacy Policy, please contact us at 
.
Effective Date: 1st September, 2023