Privacy Policy

1. Introduction

Pearl Sextant ("we", "us", "our") is committed to protecting the personal data of everyone who interacts with our website and enrols in our courses. This policy explains what data we collect, why we collect it, and how it is handled. It is written in plain language and intended to be read by the people it concerns.

This policy applies to our website at pearl-sextant.site, to enquiries made by email or telephone, and to participants enrolled in our courses. If you have questions, contact us at [email protected].

2. Data we collect and why

We collect only what is necessary to administer our courses and respond to enquiries.

• Name and email address — collected through our contact form or by email to identify you and respond to your enquiry or process your enrolment.
• Phone number — collected if you provide it, used only to follow up on enrolment or course questions.
• Payment information — processed through a secure payment provider. Pearl Sextant does not retain card details.
• Course participation data — notes relevant to your written work and feedback, held for the duration of your course and for one year afterwards.
• Website usage data — collected via cookies if you consent. Covers page views and session behaviour. See our Cookie Policy for detail.

We do not collect data that has no clear administrative purpose. We do not purchase third-party marketing lists or use data for targeted advertising.

3. Legal basis for processing

Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, personal data must be collected for a lawful purpose directly related to the functions of the data user. Our basis for processing is:

• Contract performance — processing needed to deliver the course you have enrolled in.
• Legitimate interests — responding to pre-enrolment enquiries and maintaining basic administrative records.
• Consent — for optional cookies and analytics. Consent may be withdrawn at any time.

4. How long we retain data

• Enquiry records: 12 months from the date of last contact if no enrolment follows.
• Participant records: for the duration of the course plus 12 months.
• Payment records: 7 years, as required by Hong Kong tax and accounting law.
• Cookie and analytics data: per the terms of the analytics provider — typically 26 months.

5. Who we share data with

We do not sell personal data. We share data only with:

• Our payment processor, for the purpose of processing course fees.
• Our email service provider, used to send enrolment confirmations and course materials.
• Analytics providers, if you have consented to analytics cookies.

All third-party processors are bound by data processing agreements. We do not share participant data with other participants or with any marketing parties.

6. Data protection measures

• Website data transmitted over HTTPS encryption.
• Access to participant records is restricted to Pearl Sextant staff involved in course administration.
• Written feedback documents held in access-controlled storage.
• Periodic review of data handling practices.
• Breach notification to affected individuals and the Office of the Privacy Commissioner for Personal Data (PCPD) where required.

7. Cookies

Our website uses cookies for essential site functionality and, with your consent, for analytics. Full details are set out in our Cookie Policy. You can manage your preferences at any time using the controls on that page.

8. Your rights under Hong Kong law

The Personal Data (Privacy) Ordinance gives you the following rights regarding your personal data held by Pearl Sextant:

• Right of access — to request a copy of the personal data we hold about you.
• Right of correction — to request that inaccurate data be corrected.
• Right to object — to object to the use of your data for direct marketing purposes.
• Right to withdraw consent — where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days, as required by the Ordinance.

If you are not satisfied with how we have handled a complaint, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) at pcpd.org.hk or by telephone at +852 2827 2827.

9. Third-party links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies separately before submitting any personal data.

10. Children's privacy

Pearl Sextant courses are designed for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you believe we have received data from a minor, please contact us immediately.

11. Changes to this policy

We may update this policy periodically. Any material changes will be communicated to enrolled participants by email and will be reflected in the "Last updated" date above. Continued use of our website after notification of changes constitutes acceptance of the revised policy.

12. Contact

Pearl Sextant
15/F, Harbour East
280 Gloucester Road
Wan Chai, Hong Kong

Privacy enquiries: [email protected]

General: [email protected]