Updated: July, 2023
Purpose
This privacy policy (the “Policy”) explains how United Prime Educational Publishing (HK) Limited (“UPEP”, “we”, “our” or “us”) process your personal information when you use the website of UPEP at www.upephk.com, and UPEP’s digital products (e.g. the applications) (collectively, the “Services”) or register for marketing communications.
UPEP is committed to protecting your privacy. Should we ask you to provide certain information by which you can be identified when using the Services, you can be assured that it will only be used in accordance with this Policy.
This Policy only applies to our Services. Use of other sites and services may be subject to different terms and privacy policies. This Policy may be supplemented by a separate agreement between UPEP and users of the Services.
Definitions
“Institutional customers” refer to learning providers such as schools, colleges, local education authorities, private language schools, education agencies or any other organisations that purchase access to the Services.
“Users” refer to the individuals who use the Services including an institutional customer’s learners, teachers and administrators, or individual subscribers who purchase access to the Services.
Responsibility of Institutional Customer
If your access to the Services is purchased for you by an institutional customer, then the institutional customer is the data controller for any personal information which is uploaded or accessed by the Services. The institutional customer confirms that it is legally responsible for protecting the personal information collected in connection with the use of the Services. In the circumstances, UPEP only processes the personal information as a data processor on behalf of the institutional customer.
For learners under the age of 18 who are registered by an institutional customer as users of the Services, please only upload school-issued email addresses for identification purposes.
What personal information will be collected?
Limited personal information is collected during the registration process for the Services. For learners, we request the following data from users:
- Name
- Contact details including name of institution (if appropriate), postal address, telephone number, e-mail address
- UPEP member identification details including name and membership details
- UPEP services accounts (e,g, UPEP iCentre) and access code program identification details including log-in, password, nick name, avatar, sex, user learning records/result, communication/feedback records, and verification information, and usage data. Details of school attending including school name, adoption and purchase record of UPEP materials
- Internet browser type and version
- Personal computer operating system
- User device information
For teachers, we request the following data from users:
- Name
- Contact details including telephone number and e-mail address
- Details of school at which he/she is working, including school name, school address, academic subjects of interest, academic subjects taught
- Results, records, and accumulative progress from visiting interactive content
- Occupation, employment position, number of years working experience
- Suggestions, personal opinions, enquiries
- Internet browser type and version
- Personal computer operating system.
How we use your personal information
We require your personal information to understand your needs and to improve the Services, and in particular for the following ways:
- internal record keeping;
- to improve and customise the Services according to your interests;
- to send you promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided;
- to contact you from time to time by way email, phone or mail for market research purposes;
- to contact you upon your request and/or feedback; and
- to process your order, application of UPEP digital resources account/membership or activity.
The administrators of the Services will not share your personal information with other entities, except required by laws or where such entities have been authorised to carry out specific services. We use the personal information you give us as a research tool to develop the content of the Services. If you provide us with feedback, you will be asked for your name, e-mail address and information, which will enable us to contact you. We will use that information to respond to your feedback.
Use of Cookies
A cookie is a small text file which is placed onto your computer, mobile phone or tablet (or other electronic device) when you access our website or applications.
We use cookies to:
- recognise you whenever you visit our website or use our applications;
- obtain information about your preferences, viewing and browsing behavior, online movements and use of the Internet;
- keep track of the items stored in your shopping basket and take you through the checkout process;
- carry out research and statistical analysis to help improve the Services and to help us better understand our visitor and customer requirements and interests;
- target our marketing and advertising campaigns and those of our business partners and advertisers more effectively by providing interest-based advertisements that are personalised to your interests; and
- make your online experience more efficient and enjoyable.
The information obtained from our use of cookies may not contain your personal data. While we may obtain information about your computer or other electronic device such as IP address, browser settings, browsing records, and/or other Internet log information, this may not be able to identity you personally. To the extent that non-personal data is combined with personal data, we treat the combined data as personal data for the purposes of this Policy. In certain circumstances we may collect your personal data, but only where you voluntarily provide it, or where you purchase or use the Services.
If you wish to disallow the use of cookies, you can do so on your own devices. If you disable cookies, you acknowledge that you may not be able to use some of the functionalities of our website and/or applications.
Marketing communications and opting out
Marketing communications will not be sent to any registered learners aged under 18 unless consent has been provided on behalf of the learners, in which case such consent may be withdrawn at any time.
Contact details for teachers, learners aged 18 or over, and adult subscribers to the Services may be used for following purposes:
- to contact the user with more promotional information in respect the Services, save as where the user does not consent to receiving such information; and
- to invite the user to participate in surveys, discussions and prize draws.
Participation in surveys and discussion forums is entirely voluntary. Users may unsubscribe from being contacted for these purposes at any time. Survey information will be used for market research with the aim of improving the Services.
We will not send marketing emails to a user who has opted out of receiving them. Any marketing communications we send will include an unsubscribe link at the end of the email.
Storing and Retaining your Personal Information
We have put in place appropriate technical and organisational measures against unauthorised or unlawful access, disclosure, loss, destruction, misuse or alteration of personal information we collected from users.
Provided that a user’s browser accepts HTTPS (Hyper Text Transfer Protocol Secure) encryption, we seek to protect payment information against unauthorised access through a secure server. Where third parties are engaged to process personal information, we require them to commit to the protection of personal information.
Please note that if you post any personal information on a bulletin board or discussion forum or similar interactive area of the Services, it may be collected and used by others. We will keep your personal information only for as long as is reasonably necessary to fulfil the purposes for which we collect it, and to comply with any statutory or regulatory obligations in relation to retention of records.
Transferring your Personal Information
Your personal data will be kept confidential, but UPEP may transfer your personal data to a data processor (e.g. printer, production house, providers of mailing services, cloud servers, storage providers, or a third party who powers UPEP’s products and services) engaged by UPEP to process or handle personal data on its behalf, subject to a duty of confidentiality. In particular, UPEP may use third-party providers of data storage, Google, Youtube, Instagram and Facebook (for matching of your personal data with their database in order to send you direct marketing materials through your Google, Youtube, Instagram and/or Facebook account(s)), digital marketing and website analytic agencies (for display of advertising materials on websites that you may visit, and analysis of your online behaviour and usage of the Services).
As the Internet is a global environment, you acknowledge and agree that this will include the transfer of your personal information to other countries and regions around the world.
Misuse of personal information
To protect personal information, users and institutional customers are urged to: (a) protect and never share their passwords; (b) only access the Services using secure networks; (c) maintain updated internet security and virus protection software on their devices and computer systems; (d) immediately change a password and contact UPEP if there is any suspicion of unauthorised use of password; and (e) contact UPEP if there is another security or privacy concern or issue.
Any improper collection or misuse of personal information by any user is a violation of this Policy. Please report to UPEP by emailing cs@upephk.com.
Institutional customers and users must not misuse any personal information available on the Services or gather personal information or use robots or other automated scripts, codes or functionalities to do so. We may immediately suspend or terminate users’ and institutional customers’ access to the Services without notice if we become aware of any breach of this Policy.
Your Rights
You have the right to request access to and rectification or erasure of your personal information and the right to restrict processing of your personal information.
If the access to the Services is provided by your institution, you should address any such request to your institution. If you (or your parent/guardian) purchased your access to the Services, you should address your request to UPEP using the details set out in the section headed “Contact Us” below. We will consider and act upon any request in accordance with applicable data protection laws.
Changes to this Policy
We may make changes to this Policy from time to time. We will always specify the date on which the Policy is last updated.
Contact Us
If you have any query about this Policy, please do not hesitate to contact us at:
Data Protection Officer
United Prime Educational Publishing (HK) Limited
28/F, 1063 King’s Road
Quarry Bay, Hong Kong
or email us at cs@upephk.com This Policy applies to the products and services which link to it.