Legal
Privacy Policy
Last Updated: 15 March 2025
Qilin Counsel ("we", "us", "our") is committed to handling personal data with care and transparency. This Privacy Policy explains how we collect, use, store, and protect personal information provided to us through our website and programmes, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
If you have questions about this policy, please contact us at [email protected].
1. Data Controller
The data controller is Qilin Counsel, located at 24/F, One Island East, 18 Westlands Road, Quarry Bay, Hong Kong. We are the organisation responsible for decisions about how and why your personal data is processed.
2. What Personal Data We Collect
We may collect the following categories of personal information:
- Identity data: Name, initials, or preferred form of address
- Contact data: Email address, phone number
- Programme data: Responses to reflection exercises and materials you share in the context of a programme (treated with strict confidentiality)
- Communication data: Correspondence you send us by email or via our contact form
- Technical data: IP address, browser type, pages visited, collected via cookies (see our Cookie Policy)
We do not collect sensitive personal data (such as financial account details, health information, or identity document numbers) unless you specifically share such information in programme materials, in which case it is handled with heightened confidentiality and is never stored in digital systems.
3. How We Collect Data
- Contact forms: When you submit an enquiry via our website
- Programme enrolment: When you register for and attend a programme
- Email correspondence: When you write to us directly
- Cookies and analytics: Automatically when you visit our website (subject to your consent)
4. Legal Basis for Processing
We process personal data on the following grounds:
- Consent: For marketing communications and analytics cookies
- Contractual necessity: To administer programme enrolment and deliver programme materials
- Legitimate interests: To respond to enquiries and improve our programmes
5. How We Use Your Data
- To respond to enquiries about our programmes
- To process programme enrolment and send relevant materials
- To communicate with you during and after a programme
- To understand how our website is used, with the aim of improving it
- To fulfil legal or regulatory obligations where applicable
We do not use personal data for automated decision-making. We do not sell personal data to third parties under any circumstances.
6. Data Sharing
We do not share your personal data with third parties for commercial purposes. Limited sharing may occur in the following circumstances:
- Service providers: Organisations that support our operations (e.g., email hosting, website hosting), bound by confidentiality obligations
- Legal requirements: Where required by Hong Kong law or a competent authority
We do not share your data with financial institutions, legal firms, or charitable organisations — including those discussed in our programmes.
7. Data Retention
We retain personal data only for as long as necessary for the purposes described in this policy:
- Enquiry data: Up to 12 months from the date of enquiry if enrolment does not follow
- Programme participant data: Up to 3 years from programme completion
- Financial records: 7 years, as required by Hong Kong law
- Cookie and analytics data: As specified in our Cookie Policy
8. Data Protection Measures
We take reasonable and appropriate security measures to protect personal data against unauthorised access, disclosure, or loss. These include:
- Encrypted transmission of data via our website (HTTPS)
- Access controls limiting who within our team can access personal data
- Secure email practices for all programme-related correspondence
- Physical security at our Quarry Bay office
9. Cookies
We use cookies on our website. For detailed information about the types of cookies we use and how to manage them, please see our Cookie Policy.
10. Your Rights Under the PDPO
As a data subject under Hong Kong's Personal Data (Privacy) Ordinance, you have the right to:
- Request access to personal data we hold about you
- Request correction of inaccurate personal data
- Request deletion of personal data where retention is no longer necessary
- Object to processing for direct marketing purposes (we will cease immediately on request)
- Withdraw consent where processing is based on consent
To exercise any of these rights, please write to us at [email protected]. We will respond within 40 days, as required by the PDPO.
If you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.
11. Third-Party Links
Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.
12. Children's Privacy
Our programmes and website are intended for adults aged 40 and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.
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 "Last Updated" date. Continued use of our website or programmes after such changes constitutes acceptance of the revised policy.
14. Contact
For any questions relating to this Privacy Policy or how we handle your personal data, please contact:
Qilin Counsel
24/F, One Island East, 18 Westlands Road, Quarry Bay, Hong Kong
Email: [email protected]
Phone: +852 3561 2847