Your Privacy Is Important To Us

 

This Privacy Policy will help you understand how we collect and use your personal data, who we share your personal data with and how you can control the way your personal data is collected and used by us.

 

We are committed to ensuring that the personal data we collect about you is treated with respect and kept strictly confidential.  We will at all times protect and respect your privacy rights in accordance with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong) (“PDPO”).

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To facilitate our protection of your personal data, please read this Privacy Policy carefully.

 

By attending our lessons or accessing or using our website (https://www.transformativemovement.com/) (“our website”), including without limitation by contacting us or subscribing to receive emails for updates and new events relating to us through our website, you agree that:

• this Privacy Policy is deemed to be agreed by you and will apply to you;

• we may collect your personal information;

• you consent to our use, disclosure and transfer of your personal data in accordance with this Privacy Policy and as permitted or required by law; and

• if you are under the age of 18 or do not have sufficient legal capacity, you have obtained consent from your parent or legal guardian for your access or use of our website and your parent or legal guardian agrees to your attendance of our lessons and to our collection, use, disclosure and transfer of your personal data in accordance with this Privacy Policy on your behalf.

 

If you do not agree with this Privacy Policy, please do not agree to attend our lessons and/or stop accessing or using our Site.

 

Sometimes, we may send you a new notice to explain how we may use your personal data in specific situations, and we will always give you the choice to consent to such uses.

 

1.    Who are we?

 

In this Privacy Policy, “we”, “us” or “our” means Transformative Movement Limited, “you”, “your” or “yours” means the persons to whom this policy applies.

 

We are the data user and controller in respect of your personal data under the PDPO.

 

Personal data we collect about you will be used in line with this Privacy Policy.

 

2.    How do we collect data?

 

We will only collect your information in line with relevant regulations and law. We may collect it from a range of sources: it may come directly from you or your parent/ legal guardian (e.g., when you provide your identity details us by submitting them through our website in order to contact us or subscribe to our news and updates) or we may collect information about you when you interact with us (e.g., when you browse our website, call us or ask about any of our products and services).

 

3.    What information do we collect about you?

 

It may be necessary for you (or your parent/ legal guardian on your behalf) to provide us with certain personal data in order for you to attend our lessons, use certain functions or receive the benefits of our website. We will let you know when such data is essential to provide.  All other personal data is up to you to supply or not, as you prefer.

 

3.1  Information you provide

 

(a)  Personal information

 

Prior to attending our lessons, you (or your parent/ legal guardian on your behalf) provide us with your full name, home address, email address, home number, mobile phone number and date of birth (and, in the case where you are under the age of 18 or do not have sufficient legal capacity, the names of your parents/ legal guardian(s)) so that we can verify your identity.

 

When you make reservations for appointments or lessons, you (or your parent/ legal guardian on your behalf) provide us with your full name, phone number and email address so that we can facilitate the reservations.

 

(b)  Information related to attending our lessons

 

Prior to attending our lessons, you (or your parent/ legal guardian on your behalf) will complete a questionnaire that will help us understand your goals for the lessons and for us to evaluate your profile in the context of attending our lessons, which will provide us with information about your concerns, medical history and personal goals.

 

(c)  Direct communications

 

When you communicate with us, we may receive information about your demographic information and feedback, the type of device you are using, your service provider and, if you have enabled the location permissions in your device, the latitude and longitude of your location when you contact us.  We use this information to improve our performance, to fix problems in our website and to reply to your communications.

 

3.2  Information created when you use our website or attend our lessons

 

The following are the types of information created when you use our website or attend our lessons.

 

(a)  Information related to attending our lessons

 

Over time, as you are observed by us during lessons, we collect information about your health and physical abilities. This information is collected for us to cater our lessons to you as necessary.

 

(b)  Device information

 

We collect information about the devices you use to access our website, including the type of computer or device you use, the hardware model, operating system and versions, software, file names and versions, the preferred language, time zone settings and device motion information. This information is necessary for us to diagnose bugs and improve our website. We do not collect any permanent device ID numbers.

 

(c)  Log & usage information

 

Each time you open our website, we collect information about how and when you use it (such as the time and date, pages visited, website crashes and other system activity). We use this information to improve our website in multiple ways (e.g., fixing bugs preventing future crashes and working out which features our users find most helpful).

 

(d)  Cookies

 

We may use online tracking technology such as cookies, pixel tags, web beacons and other similar technologies to automatically collect information about:

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• your visits to our website, such as your browsing history, how long you stay on our website and how often you visit;

• your location information as provided by your mobile or other device when you interact with our website, including your [IP address] and general geographic location and the device that you use to browse our website (e.g., your device ID, operating system, type of device, browser type and version, website crashes and other system activity and third party sites you were using before interacting with our website).

 

You have the right to disable any of these online tracking technologies. To learn more about how we use the above data, please see the section below on Cookies policy.

 

4.   How do we use your information?

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We will only use your personal data for the purposes set out below.

 

4.1  Profile administration

 

To help administer and maintain your profile, including:

 

• creating and updating your profile;

• verifying your identity; and

• completing transactions, including processing or facilitating payments.

 

4.2  Provision of services

 

To enable us to provide and improve services, including:

 

• recommending lesson plans based on your personal details;

• making lesson reservations; and

• assessing your health and physical abilities.

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4.3  Customer support

 

To assist you when you contact us, such as responding to and investigating any of your questions or concerns, and monitoring and improving our customer support services.

 

4.4  Marketing

 

To provide you with marketing and promotional materials, including without limitation with respect to new developments in our service and organisation and for the purpose of inviting you to events organised by us (“Marketing Communications”) if you choose to receive them. Please see the section on Direct Marketing below for more information.

 

4.5  Optimisation & improvements

 

We may use your personal data to understand and improve our website operations, through various means, such as the use of analytics tools, research, surveys and feedback forms. This will enable us to enhance services, develop new features and benefits, and amend business, marketing and strategic operations and plans.

 

4.6  Legal & administration purposes

 

We may use your personal data to investigate or handle any incidents, claims or disputes, or as otherwise required by law or requested by any law enforcement or regulatory authorities, courts or other governmental agencies. We may also use your personal data in relation to any legal proceedings concerning you.

 

5.    Who do we share your information with?

 

To protect your privacy, we will endeavour to only share with third parties data which has either been aggregated and anonymised or which otherwise does not contain your name or contact details. However, there may be limited circumstances where we will share data (which may include your personal data) with third parties who may or may not be located overseas, as detailed in this section. By using our website or attending our lessons, you agree to allow us to share your personal data with third parties and to the cross-border transfer of your personal data in accordance with this section. Regardless of where we store or process your personal data, we are committed to protecting it and will take reasonable steps to safeguard it in accordance with this Privacy Policy and all applicable laws.

 

5.1   Service providers

 

We may share your personal data with our service providers (including agents and contractors) (who may or may not be located overseas) who process personal data on our behalf for the purposes of providing administrative services, communications services, payment processing services, web-hosting (conducting data analytics) services, security services or carrying out any of the above purposes. These may include IT vendors, back-office and front-end or ancillary service providers, call centre operators, marketing agencies, payment processing companies, data management and analytics service providers and customer contact service providers. Our service providers may contact you on our behalf for any of the purposes set out above.

 

We only use trustworthy service providers, who are under an obligation to only use your personal data in accordance with this Privacy Policy.

 

5.2  Professional advisors and assignees

 

When necessary, we may share your personal data with our professional advisors, including lawyers, accountants, financial advisors and insurers. Your personal data may also be shared with third parties in connection with any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets.

 

5.3  Government & regulatory authorities

 

This Privacy Policy is governed by the laws of the Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). We strive to handle your personal data in accordance with any data privacy laws that we believe apply to us. Your personal data may be shared with regulatory authorities, courts and other governmental agencies to comply with any legal or regulatory requirements, orders or requests. Any dispute concerning the terms and conditions of this Privacy Policy shall be subject to the exclusive jurisdiction of the courts of Hong Kong.

 

6.   Children’s privacy

 

We consider the privacy interests of children to be of utmost importance and we encourage parents and guardians to take an active role in their children’s online activities and interests. We do not knowingly collect, store, use or process personal information from children without proper consent from their parents or legal guardians.

 

7.    Aggregated & anonymised data

 

Aggregated or anonymised data that do not include any personally identifiable information, may be used by us or other third parties for various purposes, including enabling them to better understand customer needs or to improve and adapt their operations, products and services or for the purposes of industry benchmarking, machine learning, research or analytics.

 

8.    Direct Marketing

 

If you have opted to receive news and promotions from us, we may use your personal data to:

 

• send you direct marketing communications in connection with the latest news, events, updates, offers and promotions relating to us and lessons provided by us; and

• in conjunction with any events or other promotional activities.

 

We may send you direct marketing communications by email, when you access our website, or through post, telephone or SMS.

 

Before providing you with direct marketing communications, we will always ask for your consent. You can choose at any time, without charge, not to receive any direct marketing communications from us. Please see the section on Your rights below.

 

9.  How we secure your information

 

We take the confidentiality and security of your information seriously. We take all reasonable steps, including the implementation of technical and physical security measures, to ensure that all your personal data held by us is kept secure and safe from any loss or unauthorised disclosure, use and modification. All personal data we collected about you is stored on our secure servers. We comply with our security policies and standards when accessing or using your personal data and restrict access to those persons who need to use it for the purpose(s) specified above.

 

10.  How long do we keep your data for?

 

We will keep your personal data only for so long as is necessary to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it on our servers.

 

11.   Your rights

 

11.1  Access and correction

 

You have the right to access and correct your personal data held by us, at any time, by Contacting Us.

 

11.2  Opt-out of direct marketing

 

At any time, you can ask us to stop using your personal data to send you direct Marketing Communications. You can exercise your rights to do this by following the unsubscribe instructions in the Marketing Communications we send to you.

 

We will stop using your personal data to send you Marketing Communications in accordance with your request. However, we may still send you non-promotional communications such as information concerning the administration of your profile and may use non-personally identifiable information collected via cookies and other tracking technology to display marketing information via online advertising banners on websites and apps visited by you.

 

12.   Cookies policy

 

Cookies are small text files that are stored on your browser or device by websites, applications, online media and advertisements when you visit a website.

 

We use cookies and other similar identification technologies such as web beacons and pixel tags on our website, emails and online advertisements for various purposes, including verifying users; remembering user preferences and settings to enhance your experience when you return to our website; delivering relevant content and advertisements based on your preferences, location and usage patterns; monitoring, evaluating and optimising the operation of our website; tracking and measuring the effectiveness of our advertising campaigns; and analysing traffic on our website.

 

You can exercise your right to choose whether or not to accept cookies by adjusting your browser settings to modify your cookie preferences. Most browsers are set to accept cookies by default, but you are free to remove or block all browser cookies. However, if you turn off your cookies, some of our services may not function properly and you will not be able to receive the most efficient and personalised experience.

 

13.   Links

 

Our website may contain links to other third party websites and applications, including practices, organisations and departments where you may find out more about the services offered through these different avenues (“Third Party Sites”).  We do not own or control, and are not responsible for the privacy practices of, those Third Party Sites.  We encourage you to remain alert if you follow any links to leave our website, and to review the privacy policies of those Third Party Sites so that you are aware of how your personal data may be collected and used by such third parties.

 

14.  Update of this Policy

 

From time to time, we may update this Privacy Policy to reflect new technologies, regulatory requirements or any other changes that may be necessary.  We will notify you of any updates in accordance with your subscription preference settings and, where required by law, obtain your consent.  We will inform you by emailing you at the email address you provided us and/or by posting a notice of these changes on our website.

 

15.  How to contact us

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If you have any questions or comments concerning this Privacy Policy, you can Contact Us.