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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: |
- 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: |
- 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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