Linkwell Technology Develop Company / 

Privacy Policy and Personal Data Collection Statements 

These Statements are, except where separate and distinctive statements are provided, applicable to the Linkwell Technology Develop Company. Accordingly, references to "we", "us", or "our company" etc. mean , Linkwell Technology Develop Company. 

I. Privacy Policy Statement
Our Pledge
We are committed to safeguarding the privacy of individuals with respect to personal data. We therefore make sure that our policies and practices in relation to the collection, use, retention, transfer and access of personal data comply with the requirements of the Personal Data (Privacy) Ordinance (Chapter 486) under the laws of Hong Kong. 

Types of Personally Identifiable Information Collected
You may be required to give your personally identifiable information including, but not limited to, your name, gender, age, identity document number, telephone number, fax number, home address, email address, credit card information, bank account number, education level, occupation, household income, interests and favourite activities etc.. Refusal to provide such information may deny you of access to certain parts of our web site, or may render us unable to handle any application or request you are making, or may otherwise defeat the objectives of your visit. If you are under the age of 18, consent from your parent or guardian is required before you give us any personally identifiable information. 

Use of Personally Identifiable Information Collected
Specific purposes for which your personally identifiable information may be used are set out in our Personal Data Collection Statement set out in II below (particularly those contained in points (i) through to (vi) in the third paragraph of II below). 

Retention of the Information
If you are our paid subscriber, your personally identifiable information which you have given us via Internet, application form or other means, during the subscription period will be retained for a reasonable period after termination of your subscription. 

Disclosure of Information
Normally, we may not disclose, share your information with, or transfer it to any third party. For details, please refer to our Personal Data Collection Statement set out in II below. 

Access to and Correction of Information
If you want to access and/or correct your personally identifiable information which you have given us via Internet, application form or other means, you may write to our Data Protection Officer. We may charge you a reasonable fee for each successful access current from time to time. However, such fee will be waived if the access is necessary to make a genuine and reasonable correction. 

We use various encryption techniques to transmit via the Internet your Personal Data, which can only be accessed by our authorised personnel. Given the nature of the Internet, we do our very best to make sure the transmission is secure. 

Use of Cookies
Your visiting our web site(s), may trigger our use of cookies. For your information, Cookies are small computer files that can be stored in web surfers' computers for the purposes of obtaining configuration information and analysing web surfers' viewing habits. They can save you from registering again when re-visiting a web site and are commonly used to track your preferences in relation to the subject matter of the web site. You may refuse to accept Cookies (by modifying the relevant Internet options or browsing preferences of your computer system), but to do so you may not be able to utilize or activate certain available functions in our web sites. 

On-line Services
We may have on-line stores or service providers hosted in our web site which are operated by third party merchants. If you want to use or order any services or products from any of them, please note that any information you provide, once transferred to the relevant merchant, is beyond our control and thus outside the scope of protection afforded by us. 

Should you have any enquiries concerning our Privacy Policy Statement, please feel free to contact our Data Protection Officer.

II. Personal Data Collection Statement
As a subscriber of our company, or a visitor or user of our web site(s), it may be necessary for you to provide us with your personal information ("Personal Data") when you apply to us and/or continue to subscribe with us for a service and/or product ("Services"). If your Personal Data is incomplete or incorrect, we may not be able to provide or continue to provide the Services to you. 

We shall keep your Personal Data confidential at all times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of Personal Data will be in accordance with the Personal Data (Privacy) Ordinance ("Ordinance") and are as set out in this Statement. 

You agree that your Personal Data provided by you to us may be used and retained by us for the following purposes and for other purposes as shall be agreed between you and us or required by law from time to time: 

  • provisioning of the Services including iSAS and iSAS Linkwell App accounts, providing informations and news and releasing school notices ;
  • processing of any benefits to you arising out of or in connection with the Services;
  • analyzing, verifying and/or checking of your credit, payment and/or status in relation to the provision of the Services;
  • processing of any payment instructions, direct debit facilities and/or credit facilities requested by you;
  • enabling the daily operation of your account and/or the collection of amounts outstanding in your account in relation to the Services; and
  • enabling us to comply with our obligations to interconnect or other industry practices. 

Under and in accordance with the Ordinance, you have the right to:

  • check whether we hold any of your Personal Data;
  • access your Personal Data held by us;
  • require us to correct any Personal Data which is inaccurate;
  • ascertain our policies and practices (from time to time) in relation to Personal Data and the types of Personal Data held by us. 

In accordance with the Ordinance, we have the right to charge a reasonable fee for the processing of any Personal Data access request. All requests for access to or correction of Personal Data or information regarding policies and practices and types of Personal Data held should be in writing and addressed to our Data Protection Officer. 

Please note that this Statement may be amended from time to time without. Notices regarding amendments will be posted at our home-page to inform you of the effective dates of the amendments. Amendments will not have retrospective effect. 

Any matters not stipulated in this agreement shall be handled in accordance with Personal Data Collection Statement, privacy policy and related laws and regulations. 

Update: January 2018