Date of Last Revision: [17 May] 2024
AISL Academy HK Limited (“AAHK”) operates three brands, AISL Academy (https://portal.aisl-academy.com/en/) , AISL Mall (https://aislmall.com) and AISL Outdoor (https://aisloutdoor.com/). AISL Academy HK Limited collects information from you (including Personal Data) through the operations of AISL Academy, AISL Mall and AISL Outdoor to provide you with integrated diversified education services.
The AISL Mall website (“Website“), including the content, features, tools, data, software and functions made available by us through the Website and any other websites or applications we operate (unless those websites or applications have posted separate or additional terms of service) (together, the “Services”) owned by AISL Mall have been created to provide information to our visitors (“you” and “your”) about our products and services. This Privacy Policy explains what information and what Personal Data we collect, why we collect it, the corresponding processing rules when we use and disclose it, and how we protect Personal Data in compliance with the Personal Data (Privacy) Ordinance and other applicable data privacy laws and regulations. Please be sure to read this entire Privacy Policy before using our Services. When you use, access or interact with our Services, you are agreeing to our Terms and Conditions and consenting to the practices described in this Privacy Policy with respect to the collection, use and disclosure of your information.
In this Privacy Policy, the term “Personal Data” means any data relating directly or indirectly to a living individual which is capable of being used to identify that individual and in a form in which access to or processing of it is practicable, and “we“, “us” or “our” refers to AISL Academy HK Limited together with AISL Mall.
Information We Collect
We collect your information to make it easier for you in using our Services. Our goal is to provide our users with a safe and informative online experience, and our collection of your information helps us achieve this goal.
We collect your information in three main ways: when you provide it to us, with automatic tracking technologies and when third party sources provide it to us.
The following are examples (without limitation) of the circumstances in which we collect Personal Data:
- When you subscribe to receive updates from us, we will ask for your name (optional), email address (mandatory) and your role (e.g. whether you are a student or a parent) (mandatory); and
- When you reach out to us for support, give us feedback, participate in optional surveys, attend our events, participate in product research or training or otherwise interact or communicate with us, we may ask for your name, email address and/or phone number and any other personal information you choose to share.
The Personal Data we may ask you to provide include (without limitation):
- name;
- email address;
- role (e.g. whether you are a student or a parent);
- any messages if you write to us using the “contact us” form; and
- information related to any of the above.
The provision of the above data is on a voluntary basis. However, if you do not provide sufficient information to us, we and any third party product and service providers may not be able to provide the requested information, products or services to you.
Automatic Collection of Personal Data
In addition, when you use the Services, we may automatically collect certain data about how you access and interact with our Services which may, when combined with other information about you, constitute Personal Data. Automated technologies, such as our use of ‘cookies’, web beacons and similar technologies help us achieve our goal of providing you with the best possible service. When you access our Services, our servers will record, or track information sent from the browsers. This can include the following information (without limitation):
- attributes of the equipment or device you are using, such as the operating system and, hardware version, device settings, software and device identifiers;
- device locations, including specific geographic locations identified through GPS signals or other means;
- connection information such as the name of your mobile operator, ISP or other service provider, browser type and IP address;
- the website from which you have reached the Services;
- the Website pages viewed;
- details of the products and services on the Services that you look at, information, tools and content available on our Services that you use;
- time spent on the Services; and
- information related to any of the above.
Our use of cookies enable us to:
- provide you with a more personalised experience on our Services. It allows us to remember you when you revisit our Services or save information about your preferences;
- study browsing habits on the Services. The more we understand what products you are interested in, the greater our ability to offer you customised solutions and targeted advertisements and other marketing materials; and
- obtain information regarding the number of visitors to the Services and the pages viewed.
In most cases, cookies are deleted when you close your browser; these are referred to as session cookies. However, persistent cookies stay on your browsing device either until such time as you delete them, or they expire. By using the Services, you consent to us using cookies. Such use of data does not disclose any of your Personal Data, and we will not collect, process or use any of your Personal Data in this regard.
You can alter your computer browser settings to block or delete cookies. If you opt to block or delete cookies of the Services, you may not be able to access certain products or services and this could have an effect on the performance of the Services on your system (for example, banner ads may not display properly).
Our Services may also include cookies or similar technologies placed by advertisers and/or third-party partners (Third–party Cookies). These cookies and similar technologies may collect non-personally identifiable information related to you for analyzing how you use these services, sending you advertisements that may interest you, or evaluating the effectiveness of advertising services. These Third-party Cookies are not bound by this policy when collecting and using such information but are bound by their own privacy policies. We do not assume responsibility for any Third-party Cookies.
We may use features in Google Analytics and Google Display Network, including advertising and remarketing, that allow us to target ads to you and report on demographics and interests. These tools use cookies and other information to show ads based on your past actions on our Services. If you would like to opt out of these features, please visit https://www.google.com/settings/ads/.
Information Provided to us by Third-Party Sources
Finally, when you use the Services, we may also receive information about you from other third parties we have engaged such as business associates, subcontractors, analytics providers, platform providers and search information providers or, pursuant to your request, from third party providers of our partners. We protect and process information obtained from those parties as described in this Privacy Policy, consistent with any additional restrictions imposed by the source of the information. Our sources may vary over time and depend upon how you use the Services.
We remind you that some experiences and/or features of the Services we provide require you to provide information for them to function. If you do not wish to provide the required information, you may not be able to use certain features.
Accuracy and Retention of Personal Data
By providing us with your Personal Data, you warrant that such data is true and accurate, and undertake to notify us as soon as practicable of any change or alteration to the same. Any loss or damage caused to the Services or to the person responsible for the Services or to any third person through the provision of erroneous, inexact or incomplete information will be your exclusive and absolute responsibility.
Unless there is a mandatory legal requirement for us to keep your Personal Data for a specified period, all Personal Data that has been collected from you will only be retained for as long as is necessary to fulfill the purpose for which the personal data was originally collected.
You have the right to request access to and correction of your Personal Data as held by us. Please contact us at support@aislmall.com at any time if you wish to correct, amend or update your Personal Data. We aim to acknowledge and act upon your request promptly. To help us respond in the most timely and appropriate way, please be as specific as possible in your request or inquiry.
What do we use your Personal Data for?
We use your Personal Data we collect from you for our legitimate business interests to operate the Services, to enhance and customize users’ experiences with the Services and to improve and grow our business.
- to provide support, answer your queries and to communicate with you, for example, providing you with alerts, notifications and recommendations;
- to allow you to access and use our free comparison services;
- to enable you to access online application forms on third party external sites;
- to analyse customer behavior and market trends so that we can improve our services and to enable us to provide more personalised service and more relevant communications to you;
- to enable us to store data and manage our business operations efficiently;
- where you have signed up to receive email communications from us and hence given your consent to us, to send you marketing and/or promotional materials on our latest products and services or those of carefully selected third parties (including our business partners, the AISL Group (as defined below));
- with your consent, for remarketing and personalisation purposes (as further described below);
- to diagnose and prevent service, security or technical issues affecting the Services;
- to monitor, detect and prevent fraud or abuse of the Services;
- to protect the safety, integrity and/or rights of our users or any third party;
- to personalise your experience and tailor recommendations, advertising and offers presented to you, including through the development of insights about you and your needs based on profile matching and your interactions with the products, services and offerings of our Services;
- to comply with our legal and regulatory obligations;
- to enable us to provide services and products related to the above and/or otherwise related to your use of the Services; and
- any other directly related purpose(s).
To provide you with valuable personalised suggestions and experiences, we may process your personal information using automated and/or manual (human) methods. Our automated methods may include artificial intelligence (AI) and a range of technologies that help our services learn and reason to improve our ability to personalize and enhance your experience when using the Services.
In some circumstances, we will anonymize 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.
We may work with our marketing partners for the purposes of delivering personalized advertisements to you based on the usage data and/or Personal Data that we have collected from you, including your email address.
From time to time, we may participate in additional retargeting and behavioral advertising services that will be similar to the services described above. Users of the Services are, by submitting their information to us, consenting to our use of these remarketing services and the related processing of their Personal Data. To opt-out of participation, you may send an email, from the email address you are opting out of, to the email address provided in our contact information below. In addition, depending on how you access the Services (by computer or mobile device), you can control the placement of cookies and other data collection methodologies for purposes of opting out; however, as mentioned above opting out may have an impact on your ability to avail of our services.
How do we disclose your Information?
We are committed to keeping your Personal Data and other information shared with us confidential. There are, however, certain circumstances in which we may disclose or transfer your Personal Data to certain third parties without further notice to you, in order to achieve the purposes stated in the section “What do we use your Personal Data for?” of this policy, or to fulfill our obligations under this policy or other agreements reached with you, as set forth below:
- Business partners such as the AISL Group: We may share your Personal Data with our selected business partners such as Asia International School Limited, its subsidiaries and affiliates and the AISL Harrow family of schools (collectively, the “AISL Group”) that provide services to or share services with us.
- Marketing Partners: We may share your Personal Data with our marketing partners including third party service providers, advertisers, advertising networks and platforms, advertising agencies, and data aggregators to serve and offer personalized ads. We may share Personal Data with our marketing partners to correlate and match our list with our marketing partners’ lists for purposes of creating an “audience” for serving personalized ads.
- Legal Requirements: We and/or any of the third parties listed above may also be required to disclose your Personal Data to any court, law enforcement body, government department, regulator or industry body of any country where required by the laws of Hong Kong or any other jurisdiction, or in response to a lawful request in Hong Kong or elsewhere. We may also need to disclose your Personal Data (i) to identify, contact or bring legal action against any person who may be causing damage to or interfere with our and/or any third party’s rights or property (whether intentionally or otherwise) and/or (ii) to help with anti-money laundering and counter-terrorist financing requirements of our partners or other third parties.
- With our affiliates, or with our successors in the event of a merger, acquisition, or reorganization, for their use consistent with this Privacy Policy.
In connection with the purposes set out in this Privacy Policy, your Personal Data may be transferred outside Hong Kong. That means your Personal Data may not be protected to the same or similar level as it would in Hong Kong. However, we will take all reasonable measures to ensure that your data is processed and stored securely, regardless of the country in which it is processed or stored.
By using our Services, you consent to the use and disclosure of your Personal Data as set out above.
Keeping you Updated Regarding our Services & Direct Marketing
After you use our services, and provided you have subscribed to receive our communications, we may use your Personal Data (namely your name (if provided) and email address) to contact you about news, offers, events, and promotional campaigns in relation to price comparison services and/or, communications, online content and other products and services that we feature on the Services from time to time.
We may also share aggregated data, provided your identity will not be disclosed by such sharing, with third parties for various purposes (including marketing and advertising), and may use this data in order to better understand your needs and to improve and adapt our products and services, but please note that, unless permitted or required by law or as otherwise set out in this Privacy Policy, we will not disclose your Personal Data to any third parties without your prior consent.
If you have any questions or concerns about the communications you are receiving from us, you can get in touch with us at any time, free of charge (see “Your Rights” below).
Links
The Website may contain links to other sites and pages. By activating a link, such as by clicking on the banner of an advertisement, you leave the Website and we do not exercise control over any personal data or any other information you give to any other entity after you have left the Website. Access to and use of such other websites is at your own risk.
Third-Party Providers
If you opt to enter into a contract with a third party through our Services, the data you provide to the third party will be transferred to that third party and controlled by that third party in accordance with that third-party provider’s privacy policy. Therefore, you should contact them directly for additional information in relation to their privacy policies and read all policies, terms and conditions before entering a contract. We are not responsible for how third-party providers use your Personal Data.
Data Security
We are fully committed to safeguarding the privacy of our users and the success of our business depends on our ability to maintain the trust of our clients and users. We apply relevant security measures in securing Personal Data entrusted to us by our users and continuously improve those measures to address security risks.
Despite our security precautions, we cannot fully guarantee the security of your Personal Data because of the inherent risks of data transmission over the internet. At all times, you assume the risks associated with the transmission of your Personal Data over the internet and the possibility of malware present on your device used for our Services. Therefore, you should ensure that you only enter or upload your Personal Data on a secure device within a secure environment.
Consent
This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
Improving our Service
In order to ensure that the services we offer you continue to meet your requirements, we might ask for your feedback. Any feedback or other information you submit to us will, unless otherwise stated, be used in accordance with this Privacy Policy and our Terms and Conditions.
Your Rights
You have the right to check whether we hold Personal Data about you and to require access to or correction of your Personal Data. You can also unsubscribe from receiving our newsletter and other promotional communications from us at any time by clicking on the unsubscribe link in our email to you. You are also entitled to withdraw your consent to receiving direct marketing or promotional communications from us, our affiliates and any of our partners.
If you wish to exercise any of your above-mentioned rights, or you have any inquiries or complaints in respect of your Personal Data, please kindly contact us at support@aislmall.com.
We reserve the right to charge you a reasonable fee for complying with a data access request as permitted by the Personal Data (Privacy) Ordinance (Chapter 486 of the laws of Hong Kong).
Changes to this Privacy Policy
We may need to revise or update this Privacy Policy from time to time in order to reflect changes in our Services, our business or relevant requirements of applicable laws and regulations, and such modifications form a part of this policy. We reserve the right to modify this Privacy Policy periodically without prior notice. Your continued access to or use of the Services after any changes or revisions to this Privacy Policy will be deemed to constitute your agreement with the terms of such revised Privacy Policy. We will always include a ‘last revised’ date as part of our privacy policy. You may check this page periodically to stay informed of our Privacy Policy.
This Privacy Policy has been prepared in both English and Chinese. In the event of discrepancies between the English and Chinese version, the English version shall apply and prevail.