Privacy Policy

1. Introduction

Meridian Crane ("we", "us", "our") is committed to protecting the personal data of participants, enquirers, and visitors to our website. This Privacy Policy explains what data we collect, how we use it, who we may share it with, and what rights you have in relation to your personal information.

This policy applies to all data collected through our website at meridian-crane.info, through programme enrolment processes, and through any correspondence with us. If you have questions about this policy, please contact us at [email protected].

2. Data We Collect

We collect personal data in the following ways:

• Enquiry and contact forms: name, email address, phone number (optional), and any details you include in your message.
• Programme enrolment: name, email, billing information, and correspondence related to your participation.
• Written exercises: content submitted as part of programme work. This may include information about your personal financial situation if you choose to use your own data in exercises.
• Website usage: technical data such as IP address, browser type, pages visited, and session duration — collected via analytics cookies where consent has been given.

3. How We Use Your Data

We use personal data for the following purposes:

• Responding to enquiries and providing programme information
• Processing enrolment and administering your participation in a programme
• Delivering written feedback on exercises and scheduling sessions
• Sending programme-related communications (schedules, reading materials, reminders)
• Analysing website performance and improving our content (analytics data only, where consent given)
• Complying with legal obligations applicable in Hong Kong

We do not use participant data for marketing purposes unless you have expressly opted in. We do not sell personal data to any third party.

4. Legal Basis for Processing

We process your personal data on the following bases:

• Contract: processing necessary for programme enrolment and delivery
• Legitimate interest: responding to general enquiries and improving programme content
• Consent: analytics and optional marketing communications (you may withdraw consent at any time)
• Legal obligation: where required by Hong Kong law or regulatory requirements

5. Data Retention

We retain personal data for the following periods:

• Enquiry data (no enrolment): 12 months from the date of enquiry
• Participant data (enrolled): duration of enrolment plus 3 years for legal and compliance purposes
• Written exercise content: 12 months following programme completion, then permanently deleted
• Financial transaction data: 7 years as required under Hong Kong regulations

6. Data Sharing

We do not share personal data with third parties for commercial purposes. We may share data with:

• Technology providers who host our website and programme platform (under data processing agreements)
• Payment processors handling enrolment fees (PCI-DSS compliant providers)
• Legal or regulatory authorities where required by Hong Kong law

All third-party providers are selected on the basis of adequate data protection standards and are prohibited from using participant data for their own purposes.

7. Data Protection Measures

We take the protection of personal data seriously. Our measures include:

• Encrypted storage of all personal data
• Access controls limiting who within our team can view participant data
• Secure HTTPS transmission for all website interactions
• Regular review of data holdings and deletion schedules
• Staff awareness of data handling obligations

In the event of a data breach that is likely to affect your rights, we will notify you and the relevant authority without undue delay.

8. Cookies

We use cookies on our website. For detailed information about the types of cookies we use and how to manage your preferences, please see our Cookie Policy.

9. Your Rights

Under the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong, and depending on your jurisdiction, you have the following rights regarding your personal data:

• Access: the right to request a copy of personal data we hold about you
• Correction: the right to request correction of inaccurate or incomplete data
• Erasure: the right to request deletion of your data (subject to legal retention requirements)
• Restriction: the right to request that we limit how we use your data in certain circumstances
• Objection: the right to object to processing based on legitimate interest
• Withdrawal of consent: the right to withdraw any previously given consent at any time

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

10. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices or content of those sites and encourage you to review their privacy policies independently.

11. Children's Privacy

Our programmes are designed for adults and are not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If we become aware that we have received data from a minor, we will delete it promptly.

12. Supervisory Authority

If you have concerns about how we handle your data that we are unable to resolve, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong at www.pcpd.org.hk.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The current version will always be available on our website with the date of last update noted above. Where changes are material, we will notify enrolled participants by email.

14. Contact

For any questions about this Privacy Policy or your personal data:

• Email: [email protected]
• Address: Unit 1806, Manulife Place, 348 Kwun Tong Road, Kwun Tong, Hong Kong