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Pearson Education North Asia Limited
Policy and Practices relating to the Personal Data (Privacy) Ordinance
of Hong Kong SAR |
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| I. |
Objectives of this Privacy Policy Statement
This statement sets out the obligations
and policies of Pearson Education North Asia Limited ("PENA") formulated
in accordance with the Personal Data (Privacy) Ordinance of the
Hong Kong Special Administrative Region (the Ordinance).
Any part of this
statement with an asterisk (*) applies to the on-line media only.
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| II. |
Personal Data
PENA holds personal data collected from
various types of sources (including on-line media) for the purposes
laid out in Part IV below, and ensures that the aforementioned personal
data will be handled in accordance with the provisions of the Ordinance
A.
Types of personal data that may
be held by PENA:
- Name
- Contact
details including contact name, address, telephone number,
fax number, e-mail address, pager number
- Longman
Teachers' Club identification details including name and
membership number
- Education
level
- Details
of school attending/attended including school name, school
address, subjects interested in
- Details
of school employed at including school name, school address,
academic subjects of interest, academic subjects taught
- Occupation,
employment position, number of years working experience
- Suggestions,
personal opinions, enquiries
- Interests
and hobbies
- Internet
browser type and version*
- Personal
computer operating system*
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B.
How personal data is collected by
PENA?
(i)
PENA may collect personal data from visitors to the web
site when they:
- visit
the PENA web site (www.longman.com.hk) (including
the Teaching Resource Centre, Longman Teachers' Club,
Longman Teachers' Club (Pre-school), Home Study Programme,
Game, Current Issues & Forum, Dictionary World and
other web pages in the site)*
- download
application forms, make on-line subscription of particular
subject(s)' information from PENA web site,*
- complete
questionnaires, respond to surveys, or
- participate
in competition, enroll seminars, promotional events
or training courses
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| (ii) |
PENA may conduct
desk research to collect personal data. This source includes
information posted in world wide web, government publication,
newspaper, magazine, registered associations' release,
and any other information which is released to public. |
| (iii) |
PENA also obtains
personal data from all kinds of primary research such
as sales visit, personal and telephone interview, focus
group discussion and so on. |
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| III. |
Cookies & Domain Name Server (DNS) Address*
| A. |
PENA web server may also
collect data relating to visitors' online session, the use of
which is to provide aggregated, anonymous, statistical information
on the server's usage so that PENA may better meet the demands
and expectations of visitors to our sites. This type of data
includes: |
- the browser type and version
- operating system, or
- the DNS address and/or domain name
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| B. |
Certain PENA web pages
may place a "cookie" on visitors' browser in order to provide
personalised services and/or maintain their identity across
multiple pages within a single session. |
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| IV. |
Purpose of Collecting Personal Data
Purposes for which personal data may
be used include:
- marketing of
books, CD-ROMs, cassettes and other related teaching resources
- conducting customers,
products and services surveys, activities and joint-promotions
with third parties (please refer to Section V.C)
- evaluation and
further enhancement of the company's products and services
- processing games,
lucky draws and promotional events
- provision of on-line teaching
resources and useful web linkage*
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| V. |
Transfer of Personal Data
| A. |
Personal data will be
kept confidential but PENA may provide such information to:
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- its subsidiaries and associated companies in order to
provide information on products, training courses as well
as promotional and sales events
- any person who owes a duty of confidentiality to PENA
who has undertaken to keep such information confidential
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| B. |
PENA does not sell or share personal data to any party unrelated
to Pearson Education unless disclosure is required under applicable
law.
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| C. |
Although PENA may conduct joint-promotional activities of
products and services with a third party that is unrelated
to Pearson Education, no transfer, sharing or disclosure of
personal data, in hard or soft copy, to such third party will
be made. The third party may only access the personal data
of those customers who participate in services or purchases
(e.g. competition, lucky draw, coupon or gift voucher) from
a specific joint-promotional campaign that requires a direct
response from each customer.
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| VI. |
Data Access and Correction Requests
A.
As a data subject, any individual has the right under the Ordinance:
- to check whether PENA holds any
personal data, to obtain a copy of that data and to correct
any data that is inaccurate. Requests for access to data
or correction of data should be in writing and made to:
The Data Protection Officer
Pearson Education North Asia Limited
18th Floor Cornwall House,
Taikoo Place,
979 King's Road,
Quarry Bay, Hong Kong.
Fax: 2565 7440
- to ascertain PENA's policy
and practice in relation to such data and to be informed
of the type of personal data held by PENA
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| B. |
PENA will respond to such requests of access or correction
within 40 days in compliance with the Ordinance.
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| C. |
A reasonable
fee may be charged to cover administrative expenses for the
access request. |
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| VII. |
Security Precautions
| A. |
PENA will use encryption for transmission of sensitive data.
While PENA strives to protect all personal information, PENA
cannot ensure or warrant the security of any information transmitted
to PENA in any form*.
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| B. |
Access to personal data is restricted to those PENA employees
who need to use the data and who have been trained to handle
such data properly and to observe confidentiality.
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| C. |
Any person who has access
to personal data held by PENA is duty bound under an act of
confidentiality to PENA, which has in turn undertaken to keep
such information confidential. |
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| VIII. |
Protection of Children*
| A. |
Visitors to the web site
who are under the age of 18 must obtain permission from parents
or legal guardians before undertaking any of the following activities:
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- sending any individual personal information or any information
about others
- entering any contest, game or lucky draw
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| B. |
It should be noted that
once permission is obtained, the user should only submit a first
name or initials to be publicly posted on the web site. A full
name should never be used. |
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| IX. |
Exemption
Nothing stated in this Policy shall limit
the rights of any data subject under the Ordinance. However, there
are certain exemptions. They include exemptions from subject access
and use limitation requirements of the Ordinance where their application
is likely to prejudice certain competing public or social interests,
such as: security, defence and international relations; prevention
or detection of crime; assessment or collection of any tax or duty;
news activities; and health.
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PENA reserves the right to change this
policy at any time by notifying the parties concerned, through a notice
posted on the Homepage, or by e-mail, fax, or mail, of any updates.
Copyright © 2001 Pearson Education North Asia Limited
All rights reserved.
If you do not wish to receive any promotional material other than
that relating to PENA's products and services, please write to our
Data Protection Officer:
Pearson
Education Asia Limited
18th Floor Cornwall House,
Taikoo Place,
979 King's Road,
Quarry Bay, Hong Kong.
Fax: 2565 7440 |
If there is any inconsistency or conflict
between the English version and Chinese version of this statement,
the English version shall prevail. |
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