Privacy Policy

Effective Date: 6 December, 2025 Last Updated: 6 December, 2025

Privacy Policy (Hong Kong Special Administrative Region)

Growth Education Limited ("Company") is committed to complying with the Personal Data (Privacy) Ordinance (PDPO) and the Data Protection Principles (DPPs). This Policy explains how we handle personal data in Hong Kong.

  1. Types of Data Collected
  • Account Data: name, email address, and contact details.
  • Usage Data: login records, actions taken, feature usage, and error logs.
  • Transaction Data: subscription status and payment records (we only retain necessary identifiers).
  1. Purpose of Collection and Use (DPP1/DPP2)
  • To provide and improve services; support and customer care; account management; subscriptions and payments; security and risk control; and compliance with legal requirements.
  1. Retention (DPP2)
  • We retain personal data only for as long as necessary to fulfill the purposes stated in this Policy and regularly review whether continued retention is required.
  1. Security (DPP4)
  • We adopt reasonable technical and organizational measures to protect data against unauthorized access, alteration, or disclosure.
  1. Direct Marketing (DPP3)
  • We conduct direct marketing only with your consent and provide an opt-out mechanism at any time.
  1. Cross-Border Transfer
  • If data must be transferred outside Hong Kong (e.g., to cloud servers), we ensure that the recipient implements safeguards comparable to the PDPO and will notify you when necessary.
  1. Access and Correction (DPP6)
  • You may request access to or correction of your personal data; we will respond within a reasonable time.
  1. Complaints and Enquiries
  • For questions or complaints about this Policy or data processing, email: info@geledtech.com.
  • You may also lodge complaints with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.
  1. Policy Updates
  • We may update this Policy from time to time and publish the latest version on the website or in the app.

© 2025 Growth Education Limited. All rights reserved under PDPO