Privacy Policy

1. Introduction

Dragon Ledger ("we", "us", "our") is committed to protecting the personal data of everyone who interacts with our courses and website. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and what rights you have in relation to it.

This policy applies to the Dragon Ledger website at https://dragon-ledger.live and to all programmes offered by Dragon Ledger. It is written to comply with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

If you have any questions about this policy, please contact us at [email protected].

2. Data We Collect

We may collect the following categories of personal data:

• Contact information: Name, email address, telephone number — collected when you submit an enquiry form or enrol in a course.
• Course participation data: Records of your enrolment, module access, and any written outputs produced during a course (such as the tax map in our Retirement Planning course).
• Communication records: Emails or messages you send us and our responses.
• Website usage data: Information about how you use our website, collected via cookies and similar technologies. See our Cookie Policy for details.

We do not collect sensitive personal data (such as financial account details, identity document numbers, or health information) unless specifically required for a course activity and consented to by you.

3. How We Collect Data

• Directly from you when you complete an enquiry or enrolment form on our website.
• When you send us an email or call our office.
• Automatically through cookies when you visit our website.
• Through third-party services we use for analytics (where you have consented to analytics cookies).

4. Legal Basis for Processing

Under the PDPO, we process your personal data on the following bases:

• Contract performance: To deliver the course you have enrolled in and respond to your enquiries.
• Consent: For optional analytics cookies and any marketing communications (which you may withdraw at any time).
• Legitimate interests: For basic website operations and service improvement, where these do not override your privacy rights.
• Legal obligation: To comply with applicable Hong Kong law.

5. How We Use Your Data

• To process your course enrolment and manage your access to course materials.
• To respond to your enquiries and provide course support.
• To communicate about your enrolment, including module releases and course updates.
• To improve our courses based on aggregate, anonymised feedback.
• To comply with applicable legal and regulatory requirements.

We do not use your personal data for automated decision-making or profiling.

6. Data Sharing

We do not sell or share your personal data with third parties for marketing purposes. We may share your data in the following limited circumstances:

• Service providers: We use third-party services for website hosting, email delivery, and course platform operation. These parties are contractually bound to process your data only as we direct and to maintain appropriate security.
• Analytics: If you consent to analytics cookies, anonymised website usage data may be processed by our analytics provider.
• Legal requirement: We may disclose your data if required by law, court order, or regulatory authority in Hong Kong.

7. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Enquiry data (non-enrolments): up to 12 months from last contact.
• Course participant records: for the duration of your course access plus 3 years, to allow for any queries or objections relating to your enrolment.
• Financial transaction records: 7 years in accordance with applicable accounting requirements.
• Website analytics data: as configured by our analytics provider (typically 14 months for session data).

After these periods, personal data is securely deleted or anonymised.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure, including:

• Encrypted transmission of data over HTTPS.
• Access controls limiting data access to staff with a need to know.
• Regular review of our security practices.

In the event of a data breach that is likely to affect your rights and interests, we will notify you and the Office of the Privacy Commissioner for Personal Data (PCPD) in accordance with the requirements of the PDPO.

9. Cookies

Our website uses cookies. Essential cookies are necessary for the website to function. Analytics and preference cookies are only placed if you consent. Please see our Cookie Policy for detailed information and to manage your preferences.

10. Your Rights

Under the PDPO, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that we correct inaccurate personal data.
• Erasure: Request deletion of your personal data, subject to any legal retention requirements.
• Objection: Object to our processing of your personal data where we rely on legitimate interests.
• Withdrawal of consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing.

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

11. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend that you review their own privacy policies.

12. Children's Privacy

Our courses are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If we become aware that we have done so, we will delete it promptly.

13. Supervisory Authority

If you have concerns about our data practices that we have not resolved to your satisfaction, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data Hong Kong (PCPD) at www.pcpd.org.hk.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the revised version on this page with an updated date. If changes are material, we will notify current participants by email.

15. Contact

For any privacy-related queries:

• [email protected]
• Dragon Ledger, 17/F, Cityplaza One, 1111 King's Road, Quarry Bay, Hong Kong
• +852 3428 7091