Privacy Policy

Bamboo Gate · Last updated: 15 March 2025 · Effective: 15 March 2025

Bamboo Gate ("we", "us", "our") is committed to protecting the personal data of individuals who interact with us. This Privacy Policy explains what personal data we collect, how we use it, and the rights you have in relation to it. We comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong SAR ("PDPO").

1. Introduction and Scope

This policy applies to all personal data collected through our website at bamboo-gate.sbs, our programme application and enrolment processes, and any direct communications with us. By using our website or enquiring about our programmes, you acknowledge this policy.

Questions about this policy should be directed to: [email protected]

2. What Personal Data We Collect

We collect personal data that you provide directly to us, including:

• Full name and contact details (email address, telephone number)
• Business name, industry sector, and role
• Enquiry content and programme interests
• Payment information (processed via secure third-party payment providers — we do not store card data)
• Programme participation records and written outputs where relevant to administration

We also collect limited technical data automatically when you visit our website, including IP address, browser type, pages visited, and time of access. This is collected through cookies and analytics tools as described in our Cookie Policy.

3. Legal Basis for Processing

We process personal data on the following bases:

• To fulfil a contract — where you have enrolled in a programme or requested a service from us
• Legitimate interest — for website analytics, improving our services, and responding to enquiries
• Consent — for any optional marketing communications, which you may withdraw at any time
• Legal obligation — where required by applicable Hong Kong law

4. How We Use Your Personal Data

• To respond to your enquiries and provide information about programmes
• To administer programme enrolment, delivery, and completion records
• To process payments for programme fees
• To improve website functionality and user experience
• To send programme-related communications, where you are enrolled
• To comply with our legal and regulatory obligations in Hong Kong

We do not sell, rent, or otherwise share your personal data with third parties for their own marketing purposes.

5. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected:

• Enquiry data not resulting in enrolment: 12 months from the date of enquiry
• Programme participant records: 7 years from programme completion (for administrative and legal purposes)
• Payment records: 7 years (as required for financial record-keeping under Hong Kong law)
• Website analytics data: aggregated and anonymised after 26 months

6. Data Protection Measures

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include:

• HTTPS encryption for all website communications
• Access controls limiting data access to authorised staff only
• Secure third-party payment processing (we do not store payment card data)
• Regular review of data handling practices

In the event of a data breach that is likely to cause harm to affected individuals, we will notify the Office of the Privacy Commissioner for Personal Data (PCPD) and affected individuals as required by applicable law.

7. Cookies

Our website uses cookies to improve functionality and understand usage patterns. For full information on the cookies we use and how to manage your preferences, please see our Cookie Policy.

8. Third-Party Services

We use a limited number of third-party services in operating our website and programmes. These may include analytics providers (such as Google Analytics) and payment processors. These parties process personal data on our behalf and are bound by data processing agreements. We do not disclose your personal data to third parties for purposes other than those described in this policy.

9. Your Rights Under the PDPO

Under the Personal Data (Privacy) Ordinance, you have the right to:

• Request access to personal data we hold about you (Data Access Request)
• Request correction of inaccurate personal data
• In certain circumstances, request erasure or restriction of processing
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk

To exercise your rights, contact us at [email protected]. We will respond within 40 days as required by the PDPO. A fee may be charged for Data Access Requests in accordance with the Ordinance.

10. Third-Party Links

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

11. Children's Privacy

Our programmes are designed for adults aged 18 and above. We do not knowingly collect personal data from persons under 18. If we become aware that personal data has been collected from a minor, we will take steps to delete it promptly.

12. International Transfers

Our primary operations are based in Hong Kong. Where personal data is transferred outside Hong Kong (for example, through cloud-based services), we take steps to ensure equivalent levels of protection apply, in accordance with the PDPO.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by posting the updated policy on our website with a revised effective date. Continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact

For any questions, Data Access Requests, or concerns regarding this policy, please contact:

Bamboo Gate
Room 609, Winning Centre, 46-48 Wyndham Street, Central, Hong Kong
Email: [email protected]
Tel: +852 3052 8417