Privacy Policy | Phoenix Compass

1. Introduction

Phoenix Compass ("we", "us", "our") is committed to protecting the personal data of everyone who interacts with us, whether as a course participant, prospective enquirer, or website visitor. This Privacy Policy explains what data we collect, why we collect it, how it is used, and what your rights are under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

If you have questions about this policy, please contact us at [email protected].

2. Data We Collect

We collect personal data in the following ways:

Enquiry form submissions: name, email address, phone number (optional), and any message content you provide.
Course enrolment: name, email address, phone number, and payment details (processed by our payment provider; we do not store full card details).
Website analytics: anonymised usage data including pages visited, session duration, and browser type (collected via cookies where consent is given).
Communications: any correspondence you send to us by email or phone, including its content and metadata.

We do not collect sensitive personal data (as defined under the PDPO) and we do not seek or accept data relating to persons under 18 years of age.

3. How We Use Your Data

We use personal data for the following purposes:

To respond to enquiries and provide information about our courses.
To administer course enrolments, schedule sessions, and communicate course-related information.
To process course fees and maintain financial records as required by Hong Kong law.
To improve the content and delivery of our courses based on participant feedback.
To send occasional communications about new cohorts or course updates, where you have consented.
To comply with legal obligations under Hong Kong law.

We do not use your personal data for automated decision-making or profiling.

4. Legal Basis for Processing

Under the PDPO, we process personal data on the following bases:

Contract: data necessary to fulfil a course enrolment or respond to an enquiry.
Consent: marketing communications and optional analytics cookies.
Legitimate interest: course improvement, security monitoring, and internal administration.
Legal obligation: financial record-keeping as required by Hong Kong law.

5. Data Retention

We retain personal data for the following periods:

Enquiry data (non-enrolled): 12 months from the date of enquiry.
Participant enrolment data: 7 years from the end of the course, as required for financial record-keeping.
Marketing consent records: until consent is withdrawn.
Website analytics data: anonymised data retained for up to 26 months.

After the applicable retention period, data is securely deleted.

6. Data Sharing and Third Parties

We do not sell or rent your personal data to third parties. We share data only in the following circumstances:

Payment processing: your payment details are processed by our third-party payment provider under their own privacy policy and security standards.
Course delivery platform: your name and email are shared with the platform used to host online sessions, for access purposes only.
Legal requirements: we may disclose data if required by Hong Kong law, court order, or regulatory authority.

All third-party providers are assessed for appropriate data protection standards before engagement.

7. Data Protection Measures

Data transmitted via our website is encrypted using TLS.
Access to participant records is restricted to staff members who need it for their role.
Our systems are reviewed for security on a regular basis.
In the event of a data breach that affects your rights and freedoms, we will notify you and the relevant authority without undue delay.

8. Cookies

Our website uses cookies. Essential cookies are required for the site to function. Optional cookies for analytics and preferences are only placed where you have given consent through our cookie banner. You can manage your cookie preferences at any time through our Cookie Policy page.

9. Your Rights Under the PDPO

Under Hong Kong's Personal Data (Privacy) Ordinance, you have the right to:

Request access to the personal data we hold about you.
Request correction of any inaccurate data.
Withdraw consent where processing is based on consent (this does not affect lawfulness of prior processing).
Request erasure of data where it is no longer needed for the purpose for which it was collected, subject to legal retention obligations.
Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) if you believe your data protection rights have been infringed.

To exercise these rights, contact: [email protected]

10. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies independently.

11. Children's Privacy

Our courses are intended for adults. We do not knowingly collect personal data from persons under 18 years of age. If we become aware that we hold such data, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be published on this page with a revised "Last updated" date. Continued use of our website or services after any update constitutes acceptance of the revised policy.

13. Contact

Phoenix Compass
Unit 705, Tesbury Centre
28 Queen's Road East, Wan Chai, Hong Kong
Email: [email protected]
Phone: +852 3516 2974