In accordance with the provisions of the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong SAR of the People’s Republic of China) (“Ordinance”) setting this Privacy Policy Statement (“PPS”).
This PPS applies to following companies/brand names: -
Educational Publishing House, Limited
Educational Publishing House Limited (Macau)
EduSmart Company Limited
Kam Pui Enterprises Limited
Pan Lloyds Publishers Limited
Popular e-Learning (HK) Limited
Popular Educational Services (H.K.) Company Limited
Popular Holdings (Greater China) Limited
Popular Modern Books Company Limited
Smart Education Travel Limited
Jumpstart Publishers (A branch of Pan Lloyds Publishers Limited)
WonderKids Publisher (A branch of Educational Publishing House, Limited)
Yuk Choi Bookstore (A branch of Educational Publishing House, Limited)
1.1 This PPS sets out the obligations and policies of Popular Holdings Limited (hereinafter collectively called as our “Group”) in accordance with the Ordinance. It is to ensure that staff members who have access to personal data will take all reasonable steps to ascertain that such personal data is properly and confidentially kept and dealt with.
2.1 Our Group holds and keeps personal data collected from various types of sources (including online media) for the purposes listed in this PPS, and ensure that the following personal data will be handled and dealt with in accordance with the Ordinance and this PPS.
2.2 In this PPS, unless otherwise stated: -
(a) a data subject means a personal data provider, who is a person being a customer, a user, a member, a subscriber, a visitor and etc. of those website(s), App(s), services and/or products provided by our Group, provides his/her personal data to our Group (“data subject”);
(b) “personal data” includes any personally identifying information or sensitive data from which it is practicable for the identity of an individual to be ascertained, such as: name, age, gender, photo image, address, contact details, HKID card or passport/entry permit numbers, job, working experience, education background, academic assessment and performance records, co-curricular data, bank information and etc.;
(c) words in the singular shall include plural, and vice versa;
(d) the masculine gender shall include the feminine and neutral and vice versa;
(e) a person shall include a reference to a natural person, a firm, an unincorporated association/organization, a body corporate, legal entity and etc.; and
(f) the headings in this PPS are for convenience only and shall not affect the interpretation of any provision of this PPS.
2.3 Our Group will collect personal data in accordance with the relevant legislations.
2.4 In case that a data subject is a minor, our Group will request and collect such data subject to provide us with his/her parents’/guardian’s name and contact phone number for necessary or urgent purpose.
2.5 Ways of our Group collecting personal data include:
(a) processing the data subject's orders;
(b) handling and following up on service requests and inquiries;
(c) visit our Group website and other supporting/related websites;
(d) visit any Apps of our Group;
(e) participate in competitions, activities and entertainment matters;
(f) enrol for seminars, promotional events, training courses, tuition courses or interest classes;
(g) sign up for any individual user account(s) or school-based (including tuition courses, interest classes and etc.) account(s);
(h) services and entertainment provided at our Group website;
(i) subscribe to the newsletter or publications of our Group; and
(j) participate those activities operated and/or organized by our Group.
2.6 Our Group may also conduct desk and/or online research to collect personal data. Sources may come from general information on the Internet, government publications, newspapers, magazines, information released by registered organizations and any other information which is open for public inspection.
2.7 Our Group may conduct marketing activities (including marketing activities through internet) to collect personal data. Our Group may also obtain personal data from all kinds of primary research such as sales visits, personal and telephone interviews, focus group discussions, questionnaires and so on.
3.1 Purposes for which personal data may be used for the following purposes including:
(a) sending written notifications/messages in relation to our Group’s activities, competitions, mock examinations, trainings, promotions and events;
(b) sending written notifications/messages in relation to the services provided under the website and other related products and services;
(c) sales promotions of books, multimedia and other teaching/learning resources, products as well as services (you may opt out from receiving promotional messages) (please see Parts 4 and 5 below for details):
(d) evaluation and further enhancement of the products and services quality/performance of our Group
(e) processing games, lucky draws and promotional events;
(f) processing the data subject's orders;
(g) handling and following up on service requests, inquiries, and complaints.
(h) provision of on-line teaching/learning resources, teaching, activities and useful weblinks; and
(i) those purposes listed in our Group’s Personal Information Collection Statement.
4.1 Our Group will use personal data for the use of our Group’s business including but not limited to: -
(a) process membership application, subscription of services and products, activities/course enrolment and handle account matters;
(b) compile overall statistics of data subjects;
(c) verify identity and records, and maintain a contact list to facilitate communication between data subjects and our Group;
(d) handle and follow up orders, goods and/or service requirements, inquiries and complaints;
(e) conduct survey researches;
(f) provide data subjects with the latest information that our Group believes data subjects are interested in, such as promotional activities, new services and products, and other promotional and marketing materials;
(g) events/activities invitation;
(h) notify data subjects about privileges exclusive to our Group members; and
(i) from time to time, our Group will cooperate with relevant organizations to organize events, provide joint sponsorship, brand promotion or products and services, and share data subjects’ information with relevant organizations.
4.2 If the use of personal data involves direct marketing use, our Group will deal with it in accordance with Part 5 below.
5.1 Our Group may use the personal data including name, telephone number, address, email address, education background, etc. to promote and market our Group's products, services and etc. to data subjects through direct marketing. Our Group will always comply with the Ordinance and other applicable law and, if required obtain the prior consent of data subject(s) before our Group uses any personal data for direct marketing.
5.2 If any data subject and any person concerned prefers his/her personal data not to be used for the purpose of direct marketing activities, please send an email, along with his/her name and account number, to PDP Coordinator at
enquiry_pdp@popularworld.com notifying our Group that he/she does not wish his/her personal data to be used for such purposes.
6.1 Some of the web pages on our website(s) contain ‘cookies’ to enhance users’ experience. Cookies are text files placed in users’ (including data subjects’) computer’s Internet browser to store users’ preferences. Cookies, by themselves, do not provide users’ email addresses or other personal data to us. Our Group only obtains this information when the users choose to provide it to our Group’s website(s). However, once the users choose to furnish the website with their personal data, such data may be linked to data stored in the ‘cookies’. Most browsers are initially set to accept cookies. If users would prefer, they can set their browser to disable cookies or inform them when they are set. But if they do so, certain functionalities of our website(s) may not be available to them.
7.1 Our Group’s PPS is to retain personal data for a period no longer than is required to fulfil the purpose (or any directly related purpose) for which the personal data was to be used, subject to legal, statutory and regulatory requirements mandating the retention of personal data.
8.1 Our Group has certain procedures in place to maintain personal data at a reasonable level of accuracy, completeness and relevancy for the purpose for which the personal data is to be used. Our Group aims to keep personal data of any data subject accurate and up-to-date. However, our Group relies on any data subject to disclose all material information to us and to inform us of any errors or changes in such information.
8.2 Any person concerned may amend his/her personal data in accordance with “Data access and correction requests” part below.
9.1 Under the Ordinance, a data subject has the right to:
(a) Check whether our Group holds any of his/her personal data and get access to such data;
(b) Retrieve a copy of their data and correct their data. For access or correction to the data, please make requests by a letter or through an email to: -
Data Protection Officer
Popular Holdings Limited
14/F, Tsuen Wan Industrial Centre, 220-248 Texaco Road, Tsuen Wan, NT, Hong Kong
9.2 Our Group will reply to the data access or correction requests within 40 days from the date of receipt of such written request.
9.3 Our Group may charge an administrative fee, when handling the requests.
9.4 Our Group will properly keep and store those data subjects’ personal data until (i) his/her membership ceases; (ii) our Group has received the written request of the data subject or any person concerned; or (iii) the completion of the relevant purpose of the collection of the personal data, our Group shall delete such person’s personal data accordingly.
10.1 Generally speaking, the personal information/data provided by data subjects is restricted to employees authorized by our Group. Our Group will not sell, trade or rent personal identification information to others. The personal data held by our Group will be kept confidential, except in the following cases: -
(a) If our Group needs to use third-party suppliers and service providers to assist or improve our Group's information delivery and services, and the data subject uses the above-mentioned services, our Group will provide the data subject's personal information to the supplier providing such services or service provider.
(b) Our Group will disclose and provide personal data when required to do so by law or pursuant to the Court’s orders (including the need of the litigations) or under the request/order of the relevant governmental authorities (including law enforcement agencies, authorities and regulatory authorities).
(c) Our Group will also disclose or access account information for administrative management and other purposes that our Group considers necessary to maintain, overhaul and improve our Group’s products and services.
(d) If our Group and its working partners on joint promotions and the participants/data subjects’ personal information is needed to fulfill the committed service. If any data subject does not want to permit the use of his/her personal data for this purpose, please email to
enquiry_pdp@popularworld.com to notify our Group.
11.1 Our Group will try to encrypt all personal data and use encryption for transmission of sensitive data. While striving to protect all personal data, our Group cannot ensure or warrant the security of any information transmitted to our company in any form.
11.2 Access to personal data is restricted to those of our Group’s employees who need to use the data and have been trained to handle such data properly and to observe confidentiality.
11.3 Any person who has access to personal data held by our Group is duty bound under an act of confidentiality to our Group, which has in turn undertaken to keep such information confidential.
12.1 Visitors/Users to any website(s) and/or App(s) of our Group who are under the age of 18 must obtain permission from parents or his/her guardian before undertaking any of the following activities:
(a) sending out any of his /her personal data or information of others
(b) entering any competitions, games, entertainment activities or lucky draws; or
(c) purchasing any service and/or products.
12.2 Visitors/Users to any website(s) and/or App(s) of our Group who are under the age of 18 undertake any of the above activities and/or provide us with personal data, he/she will be deemed to have obtained permission of his/her parents or guardian therefor. Thus, our Group advises that parents and guardian should closely monitor those persons under 18 who visit our Group’s website(s) and/or App(s) and give proper guidance.
12.3 As the above data may be made public online, it should be noted that the user who is under the age of 18 is advised to submit a first name or initials instead of a full name, even with the permission from parents or legal guardians.
13.1 Nothing stated in this PPS shall limit the rights of any data subject under the Ordinance. However, certain exemptions may arise in the circumstances where prejudice or affect public or social interests such as national safety and security, anti-terrorism, anti-money laundering, prevention or detection of crime and so on.
13.2 The articles, essays, photos and content uploaded on this website and/or Apps of our Group are provided by authors or information providers. The authors or information providers will be held liable for all consequences of legal disputes or the loss of our Group.
14.1 When any person and/or any data subject visits and uses our Group’s website and/or Apps clicking on any advertisement or hyperlink linking to another website and/or Apps, he/she will then leave our Group’s website and/or Apps for another location. Our Group shall not be responsible for the privacy and security practices or the content of such websites and/or Apps and he/she should always check the privacy policy of all websites and/or Apps he/she clicked in.
15.1 Our Group reserves its right to amend, revise and change this PPS at any time but will as soon as practicable notify the concerned parties on the website and/or App’s homepage, or by email, fax, or mail for any updates.
15.2 If there is Chinese version of this PPS and the content therein (if any) has any difference with English version thereof, the English version shall prevail.
15.3 Nothing in this PPS shall affect the rights and obligations of our Group with any data subject under any contract.
15.4 If you or any data subject do(es) not wish to receive any promotional and direct marketing materials, information and messages from our Group, please write a letter or an email to: -
Popular Holdings Limited
14/F, Tsuen Wan Industrial Centre, 220-248 Texaco Road, Tsuen Wan, NT, Hong Kong