OnGrad Consulting Company Limited and/or its subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the “Company”; if the context requires or permits, “Company” may refer to any one of OnGrad Consulting Company Limited and/or its subsidiary(ies) and/or affiliate(s)) pledges to meet fully with the requirements of the Personal Data (Privacy) Ordinance, Chapter 486 of the Laws of Hong Kong. In doing so, the Company will ensure compliance by its staff to the strictest standards of security and confidentiality in respect of all personal information and data submitted by users via OnGrad.com, its sub-domains, any other websites, media platforms or applications including mobile applications operated/developed by the Company (hereinafter collectively referred to as the "Channels" ) and the Company will not release such information to anyone without the prior consent of the relevant user(s) of the Channels (whether registered or not) (“User(s)”) except to the authorized persons listed under paragraph 3 below.
any deems necessary.
In the course of using the Channels, Users may disclose or be asked to provide personal information and/or data. In order to have the benefit of and enjoy various services offered by the Channels, it may be necessary for Users to provide the Company with their personal information and/or data. Although Users are not obliged to provide the information and/or data as requested on the Channels, the Company will not be able to render certain services on the Channels in the event that Users fail to do so. The Company’s purposes for collection of information and data on the Channels include but not limited to the following:
The Company strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove.
If the Company requires the use of Users’ personal data for a purpose other than those set out hereinabove, the Company may request the Users’ prescribed consent to the same.
The Company may collect personal information and/or data about a User such as his/her name, log-in ID and password, address, email address, phone number, sex, education history, work history, and other personal information that is/are not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from a User in connection with contests, surveys, or special offers.
Only duly authorized staff of the Company will be permitted to access the Users’ personal information and data, and the Company shall not release such personal information and data to any third parties save and except for the circumstances listed out under the Paragraph 3 entitled “Disclosure or Transfer of Data”.
The Company agrees to take all practicable steps to keep all personal information and data of Users confidential and/or undisclosed, subject to the following.
Generally speaking, the Company will only disclose and/or transfer Users’ personal information and/or data to the Company’s personnel and staff for the purpose of providing services to Users. However, the Company may disclose and/or transfer such information and/or data to third parties under the following circumstances:
Personal data collected via the Channels may be transferred, stored and processed in any country in which the Company operate. By using the Channels, Users are deemed to have agreed to, consented to and authorized the Company to disclose and/or transfer their personal information and data under the circumstances stated above, as well as to any transfer of information (including the Information) outside of the Users’ country.'
The Company may from time to time send to members and Users of the Channels, by way of emails and/or short message service (SMS) notifications, newsletters, marketing and promotional materials and information regarding the Company or its third-party advertisers’ products, services and the like based on the personal information and data that the Users have provided to the Company. The Company may use Users’ data in direct marketing and the Company requires the Users’ consent (which includes an indication of no objection) for that purpose. In this connection, please note that:
the name, log-in ID and password, contact details, age, sex, date of birth, country of residence, nationality, education level and work experience of Users held by the Company from time to time may be used by the Company and/or its authorised personnel or staff in direct marketing;
the following classes of services, products and subjects may be marketed:
The above products, services and subjects may be provided or (in the case of donations and contributions) solicited by the Company and/or:
third party service providers providing the products, services and subjects listed in paragraph (b) above; and
charitable or non-profit marking organizations;
in addition to marketing the above services, products and subject itself, the Company also intends to provide the data described in paragraph (a) above to all or any of the persons described in paragraph (c) above for use by them in marketing those services, products and subjects, and the Company requires the Users’ written consent (which includes an indication of no objection) for that purpose;
the Company may receive money or other property in return for providing the data to the other persons in paragraph (d) above and, when requesting the Users’ written consent as described in paragraph (d) above, the Company will inform the Users if the Company receives any money or other property in return for providing the data to the other persons.
Suitable measures are implemented to make available to such members the options to “opt-out” of receiving such materials. In this regard, Users may choose to sign up or unsubscribe for such materials by logging into the membership registration or user account maintenance webpage, or clicking on the automatic link appearing in each newsletter/message, or contact the Customer Human Resource Department of the Company, whose contact details are set out under Paragraph 13 entitled “Enquiries” below.
Any User is entitled to request access to or make amendments to his/her own personal information and data kept with the Company by contacting the Human Resources Department of the Company, whose contact details are set out under Paragraph 13 entitled “Enquiries” below.
In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to a User’s requests within 40 days of his/her request and will endeavor to do so wherever possible.
The Company does not collect any personally identifiable information from any Users whilst they visit and browse the Channels, save and except where such information of the Users is expressly requested. When Users access the Channels, the Company records their visits only and do not collect their personal information or data. The Channels’ server software will also record the domain name server address and track the pages the Users visit and store such information in “cookies”, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring.
The Company and third-party vendors engaged by the Company use the Company’s cookies and third-party cookies, such as the Google Analytics cookies, together to inform, optimize, and serve marketing materials based on the Users’ past visits to the Channels. Please visit http://networkadvertising.org/managing/opt_out.asp for details. The Company does not link the information and data automatically collected in the above manner to any personally identifiable information. The Company generally uses such automatically collected information and data to estimate the audience size of the Channels, gauge the popularity of various parts of the Channels, track Users’ movements and number of entries in the Company’s promotional activities and special events, measure Users’ traffic patterns and administer the Channels. Such automatically collected information and data will not be disclosed save and except in accordance with the Paragraph 3 entitled “Disclosure or Transfer of Data”.
Google Analytics Advertising Features (“Features”) are implemented on the Channels. The Features which the Company has implemented are based on Google Analytics Demographics and Interest Reporting.
Google Analytics is a web analysis service provided by Google which utilizes the data collected to track and examine the use of the Channels, to prepare reports on the Users’ activities and share them with other Google services. Google may use the data collected to contextualize and personalize the marketing materials of its own advertising network.
The Channels may provide links to other websites / media platforms / applications which are not owned or controlled by the Company. Personal information and data from Users may be collected on these other websites / media platforms / applications when Users visit such websites / media platforms / applications and make use of the services provided therein. Where and when Users decide to click on any advertisement or hyperlink on the Channels which grants Users access to another website / media platforms / applications, the protection of Users’ personal information and data which are deemed to be private and confidential may be exposed in these other websites / media platforms / applications.
The security of Users’ personal information and data is important to the Company. The Company will always strive to ensure that Users’ personal information and data will be protected against unauthorized access. The Company has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data.
Registered Users should safeguard his/her unique Username and Password by keeping it secret and confidential and never share these details with anyone.
The Company uses third party payment gateway service providers to facilitate electronic transactions on the Channels. Regarding sensitive information provided by Users, such as credit card number for completing any electronic transactions, the web browser and third party payment gateway communicate such information using secure socket layer technology (SSL).
The Company follows generally accepted industry standards to protect the personal information and data submitted by Users to the Channels, both during transmission and once the Company receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while the Company strives to protect Users’ personal information and data against unauthorized access, the Company cannot guarantee its absolute security.
The Company would like to help Users keep his/her personal information accurate and up-to-date. To view or edit personal information that has been stored at the Channels, please email to email@example.com
Any User may make a data access request or a data correction request at any time by contacting the Customer Relationship Executive of the Company, whose contact details are set out under Paragraph 13. entitled “Enquiries ” below.
In the event that a User wishes to access or amend his/her personal information and data, the Company may request him/her to provide personal details in order to verify and confirm his/her identity. HKID card number or passport number or business registration certificate number cannot be amended unless such data is proved to be inaccurate. The Company is required to respond to Users’ request within 40 days of his/her request and will endeavour to do so wherever possible.
Please note that if Users do make a data access request and if the Company deems the same as appropriate, only a copy of your personal data would be provided.
Once the Company has obtained a User’s personal information and/or data, it will be maintained securely in the Company’s system. Subject to legal requirements, the personal information and/or data of Users will be retained by the Company until the User requests the Company in writing to erase his/her own personal information and/or data from the Company's database or to terminate his/her membership of the Channels.
For any query, please contact our Human Resource Department with contact details as follows:
Tel: +852 51751000
Last updated: June 5, 2019
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.
We collect information directly from individuals, from third parties, and automatically through the OnMyGrad Platform.
Account and Profile Information: When you create an account and profile on the OnMyGrad Platform, we collect your name, contact information, and other information you provide, such as topics that you know about or find interesting. Your name, photo, and any other information that you choose to add to your public-facing profile will be available for viewing to users of the OnMyGrad Platform. Once you create a profile, other users will be able to see in your profile certain information about your activity on the OnMyGrad Platform, such as the questions and answers you post, your followers and who you follow, topics of interest to you, the information you list as credentials, and your edits to Your Content. For more information about your choices for publicly displayed information, see the section below about Your Choices.
Your Content: We collect and store the information and content that you post to the OnMyGrad Platform, including your questions, answers, photos, comments, learning materials and activities. Unless you have posted certain content anonymously, Your Content, date and time stamps, and all associated comments are publicly viewable on the OnMyGrad Platform, along with your name. This also may be indexed by search engines and be republished elsewhere on the Internet in accordance with our Terms of Service. For more information about what you can change, see the below section on Your Choices.
Communications. When you communicate with us (via email, phone, through the OnMyGrad Platform, or otherwise), we may maintain a record of your communication.
Engagement. We collect browsing information – such as IP address and location, date and time stamp, user agent, OnMyGrad cookie ID (if applicable), URL, unique advertising or content identifiers (if applicable) and time zone, and other information about user activities on the OnMyGrad Platform, as well as on third party sites and services that have embedded our widgets, plug-ins, buttons, or related services. We may also receive information about you from third parties, such as other users, partners (including ad partners), or our affiliated companies.
We do not sell your personal data – such as your name and contact information – to third parties to use for their own marketing purposes. OnMyGrad uses the information we collect for the following purposes:
We share information as set forth below, and where individuals have otherwise consented:
Service Providers. We may share your information with third party service providers who use this information to perform services for us, such as payment processors, hosting providers, auditors, advisors, consultants, customer service and support providers, as well as those who assist us in providing the Ad Services.
Business Transfers. We may disclose or transfer information, including personal information, as part of any merger, sale, and transfer of our assets, acquisition or restructuring of all or part of our business, bankruptcy, or similar event.
Legally Required. We may disclose your information if we are required to do so by law.
Protection of Rights. We may disclose information where we believe it necessary to respond to claims asserted against us or, comply with legal process (e.g., subpoenas or warrants), enforce or administer our agreements and terms, for fraud prevention, risk assessment, investigation, and protect the rights, property or safety of OnMyGrad, its users, or others.
Your Content and Activity. Your Content, including your name, profile picture, profile information, and certain associated activity information is available to other users of the OnMyGrad Platform and may be viewed publicly. Public viewing includes availability to non-registered visitors and can occur when users share Your Content across other sites or services. In addition, Your Content may be indexed by search engines. See the section below about Your Choices for information about how you may change how certain information is shared or viewed by others.
Metrics. We may share with users of our advertisers or publishers aggregate statistics, metrics and other reports about the performance of their ads or content in the OnMyGrad Platform such as the number of unique user views, demographics about the users who saw their ads or content, conversion rates, and date and time information. We do not share IP addresses or personal information. We may also allow our advertisers or publishers to collect information about the performance of their ads or content.
Anonymized and Aggregated Data. We may share aggregated or de-identified information with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual.
We may display personalized content (including from third party publishers) and personalized ads (including sponsored content), based on information that we have collected via the OnMyGrad Platform, and through our widgets, and buttons embedded on third party sites. We also may report aggregated or de-identified information about the number of users that saw a particular ad or content and related audience engagement information to users of our advertisement services and to publishers of content on the OnMyGrad Platform.
Users of our advertisement services may also provide us with information as part of their ad campaigns, including customer list information (e.g., email addresses and demographic or interest data) with us in order to create customized audiences for their ad campaigns; we only use this information to facilitate the particular user’s campaign (including ad metrics and reporting to that user) or for fraud detection and security purposes; and we do not disclose this information to third parties (other than our service providers) unless required by law. We also do not disclose to the users of our advertisement services the names or identities of their customers that were successfully reached as part of such campaigns.
The security of your information is important to us. OnMyGrad has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using the OnMyGrad Platform on a shared or unsecured device.
You may update or correct your account information at any time by logging in to your account. You may also make a number of other adjustments to settings or the display of information about you as described in more detail in the following section about Your Choices.
You may, of course, decline to submit information through the OnMyGrad Platform, in which case we may not be able to provide certain services to you. You may also control the types of notifications and communications we send, limit the information shared within the OnMyGrad Platform about you, and otherwise amend certain privacy settings. Here is some further information about some of your choices:
Anonymous Posts.You may post certain content anonymously, including questions and answers. In such event, your name is not displayed along with the content, and OnMyGrad does not associate such content with your user ID and other profile data.
Your Content.You may edit or delete the answers that you post at any time. Any questions you have posted may remain on the OnMyGrad Platform and be edited by other users. Any deleted content will be removed from third party sites from which it has been shared via OnMyGrad’s standard sharing features; however we have no control over deletions or changes to Your Content if it has been shared manually by others. When you make edits to Your Content, other users will be able to see the history of those edits in your profile activity and on content edit logs.
Emails and Communications. When you join the OnMyGrad Platform by signing up for an account or creating a profile, as part of the service, you will receive the newsletters containing content that we believe may match your interests. You can manage your email and notice preferences in your account profile settings, under your Emails and Notifications settings. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you transactional e-mails about your account or any services you have requested or received from us.
Third parties may comment on your postings within the OnMyGrad Platform. In your profile, under your Privacy Settings, you can adjust whether to allow people to comment on your answers and posts. You can also adjust permissions about who you allow to send you messages on the OnMyGrad Platform.
Followers. You can block the ability of other OnMyGrad users to follow you by selecting the setting for this in the other user’s profile. You can change whether or not you follow other users.
Topics. You can change topics that you follow or that your profile lists as areas that you know about.
Deleted Account. If you choose Delete Your Account in your privacy settings, then all of Your Content will be removed from public visibility on the OnMyGrad Platform, and it may not be restored by us, even if you change your mind.
Transferring Your Data OnMyGrad is headquartered in the HKSAR, PRC, and has operations, entities and service providers throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.
Children’s Privacy We do not knowingly collect or solicit personal information from anyone under the age of 15 or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.
By email: firstname.lastname@example.org