Privacy Policy

Effective Date: [Date]
Last Updated: [Date]

Emcompass 360 ("we", "us", or "our") is committed to protecting the privacy and security of personal data. This Privacy Policy explains how we collect, use, disclose, retain, and safeguard your personal data when you visit our website and use our career exploration consultancy services. This Policy also constitutes a Personal Information Collection Statement ("PICS") under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and reflects our commitment to complying with the PDPO and its Data Protection Principles.

Personal Data We Collect

We collect only personal data that is adequate, relevant, and not excessive for the purposes of providing our services and operating our business, and the categories of data collected depend on how you interact with us. For students and parents, we may collect your name, age, contact telephone number, email address, correspondence address, current school and year level, academic background, areas of career or subject interest, and the name and contact details of a parent or guardian where the student is under 18; for shadowing programs, we may also collect health-related information, such as any special medical conditions or reasonable accommodation needs, to ensure participant safety and the suitability of the activity. For website visitors and enquirers, we may collect your name, email address, telephone number, enquiry content, and any other information you voluntarily provide through our website forms. For partner contacts, we may collect your name, job title, organisation name, work email address, and telephone number. In addition, when you browse our website, we may automatically collect certain analytical data, including your Internet Protocol (IP) address, browser type, device type, time of visit, pages viewed, and duration of visit, as well as identifiers generated through cookies or similar technologies. You are not obliged to provide the data requested, but if you choose not to provide data that we specify as necessary, we may be unable to process your enquiry, registration, or provide the relevant services.

Purposes of Collection

We collect and use personal data for purposes directly related to our functions and activities, including processing and responding to your enquiries, service requests, or partnership proposals; arranging, administering, and delivering career workshops, industrial tours, and shadowing programs; communicating with students, parents, and partners regarding activity arrangements, safety matters, and follow-up; conducting internal statistics, service evaluation, and quality improvement; sending you information about our latest activities, services, or promotional messages subject to your consent; complying with applicable legal and regulatory requirements; and protecting the safety and interests of our company, participants, and partners. We will not use your personal data for any new purpose other than those stated above unless we have obtained your voluntary and explicit consent, or the new purpose is directly related to the original purpose of collection.

Disclosure and Transfer of Personal Data

We do not sell, rent, or trade your personal data, and we disclose or transfer personal data to third parties only where necessary and in the following circumstances. We may engage third-party service providers to assist with website operation, email communications, customer relationship management, or IT support, and such providers are permitted to access personal data only to the extent necessary to perform their duties and are bound by contractual obligations of confidentiality and security. To arrange industrial tours or shadowing programs, we may disclose the name, year level, and contact details of participating students to host corporations where the corporation has a reasonable need to know, and we will inform you of such arrangements before the activity. We may disclose personal data where required by law, court order, or a lawful request from a regulatory authority. Our services are primarily based in Hong Kong, but some third-party service providers may operate servers or facilities outside Hong Kong; where personal data is transferred across borders, we will take reasonable steps to ensure that the data receives a comparable standard of protection to that under the PDPO, including, where appropriate, adopting the standard contractual clauses recommended by the PCPD or other safeguard mechanisms.

Direct Marketing

We will use your personal data, such as your name, email address, and telephone number, to send you information about our latest activities, services, or promotional messages only after obtaining your consent. Before obtaining consent, we will provide you with a clear opt-in mechanism, for example a consent checkbox on our forms, to choose whether to receive such communications. You may withdraw your consent at any time, free of charge, by emailing us at [Email Address] or by clicking the "unsubscribe" link in our promotional emails, and upon receiving your notification, we will cease using your personal data for direct marketing within a reasonable time.

Cookies and Similar Technologies

Our website uses cookies and similar technologies to enhance your browsing experience, analyse website traffic, and improve website functionality. Cookies are small text files stored on your device that may record your language preferences, browsing behaviour, and device information. You may refuse or delete cookies through your browser settings; however, if you refuse cookies, some features of our website, such as form submission or page navigation, may not function properly. We do not use cookies to collect sensitive personal data that directly identifies you.

Data Security

We take practicable technical and organisational measures to safeguard personal data against unauthorised or accidental access, processing, erasure, loss, or use. These measures include restricting access to personal data to authorised personnel only, using secure channels for handling sensitive data, and regularly reviewing our data security practices. While we strive to protect your personal data, no internet transmission is completely secure, and we cannot guarantee that data transmitted through our website will be free from interference during transmission; you should assess the risks of providing personal data over the internet accordingly.

Data Retention

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or a directly related purpose, unless a longer retention period is required or permitted by law. Generally, enquiry records are retained for a reasonable period after resolution for follow-up purposes, and participant data is retained after an activity until administrative, insurance, or legal compliance requirements are satisfied. When personal data is no longer needed, we will securely delete or anonymise it.

Your Rights: Access and Correction

Under the PDPO, you have the right to request access to the personal data we hold about you and to request correction of any inaccurate or incomplete personal data. To exercise these rights, please submit a written request to us using the contact details in the Contact Us section below. To protect your privacy, we may require reasonable proof of identity before processing your request. We will respond within the timeframe stipulated by the PDPO and may charge a fee for processing an access request not exceeding the statutory maximum.

Children's and Minors' Privacy

Our services are available to secondary school students. Where a participant is under 18, we will seek consent from, or communicate and confirm arrangements through, their parent or guardian before collecting their personal data. We do not knowingly collect personal data from minors for marketing purposes without parental or guardian consent.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights of access or correction, or request that we stop sending you direct marketing communications, please contact our Data Protection Officer at Emcompass 360, Email: [Privacy Contact Email Address], Address: [Hong Kong Office Address].

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any revisions will be posted on this page with an updated "Last Updated" date. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.