Privacy Policy Statement

Last Updated: 2019-05-02

General

At MagiCube Limited (“MagiCube”), we care about your personal data, so we have prepared this Privacy Policy statement to explain how we collect, use and share it. This online platform (“Una”), is owned and operated by MagiCube Limited. We respect personal data and are committed to full implementation and compliance with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486 (“the Ordinance”) of Hong Kong. This Statement is important and should be read thoroughly in order to understand the privacy policies of Una in respect of any personal data it collects from you, as a data subject (as defined below).

This statement is applicable to all users of the platform, including but not limited to all Students, Parents, and Teachers/Tutors, as well as any other persons that their personal data is collected, by whatever means, used and held by us. We may update our Privacy Policy to reflect changes of our information practices. By accessing and using Una and any of its pages, you are agreeing to the terms and conditions set out herein.

Types of Personal Data

The term “personal data”, wherever mentioned in this Statement, includes the following kind of information:

  1. All the data which may be collected or held by MagiCube from time to time in connection with the registration and establishment of user’s account or the use or continuation of provision of educational services, products and facilities, the following data relating to a data subject (including any updated data of any of the following data):
    1. Full name;
    2. Date of birth;
    3. Correspondence address and/or residential address;
    4. E-mail address;
    5. Telephone number;
    6. Fax number;
    7. Hong Kong Identity Card Number or travel document number;
    8. School name;
    9. Class code; and
    10. Information as referred to in the paragraphs below under ‘Cookies, Domain Names and IP Addresses’.
  2. Information collected through computer technologies by third parties whom MagiCube works with to find out more about users of MagiCube’s website, including number of the visitors, behaviour and usage patterns, for more accurate reporting and to improve the effectiveness of marketing of MagiCube.
  3. Other data collected from data subjects in the ordinary course of the continuation of the relationship between MagiCube and data subjects such as the followings:
    1. When a data subject uses Una;
    2. When a data subject registers to conduct on-line shopping activities through any of Una;
    3. When a data subject submits any work or statement through Una;
    4. When a data subject takes part in any activities published by Una on its website or other website linked to Una;
    5. When a data subject makes a purchase or obtains a product or service introduced or referred to by Una on its website (except for any online payment);
    6. When a data subject enters into, uses and/or makes a comment on a discussion board, blog or similar forum established on Una; and
    7. When a data subject participates in online activities as published on Una including learning software, online learning games, competitions, assessments, exercises and other online activities as published from time to time.

The term “data subject(s)”, wherever mentioned in this Statement, includes the following categories of individuals:

  1. Students;
  2. Parents;
  3. Guardians;
  4. Teachers;
  5. Users of Una; and
  6. Users of education related services and products so forth provided by MagiCube or its partners.

For the avoidance of doubt, “data subjects” shall not include any incorporated bodies. The contents of this Statement shall apply to all data subjects and form part of any contracts for services that the data subjects have or may enter into with Una from time to time. If there is any inconsistency or discrepancy between this Statement and the relevant contract, this Statement shall prevail insofar as it relates to the protection of the data subjects’ personal data. Nothing in this Statement shall limit the rights of the data subjects under the Ordinance.

Cookies, Domain Names and IP Addresses

When you browse Una, your visit to Una may be recorded for analysis on visitor flow and general usage patterns analysis. Some of this information will be collected through the use of cookies (as defined below).

“Cookies” are small bits of information that are automatically stored in your computer hard drive which can be retrieved by this website.

Cookies can make the site more useful by storing information about your preferences on particular websites and thus enabling MagiCube as website owners to provide more useful features for its users. The information collected by cookies is anonymous aggregated research data, and contain no name or address information or any information that will enable anyone to contact you through telephone, e-mail or any other means. Most web browsers are initially set to accept cookies and if you would prefer, you can disable the functionality of cookies. However, by disabling cookies, you may not be able to take full advantage of Una.

Every time you log on to this website, MagiCube will, through its network servers, automatically collect your domain name and IP address for the purpose of verification and MagiCube will use such data for visitor flow statistical and data analysis.

Collection of Personal Data

From time to time, it is necessary for the data subjects to supply MagiCube with personal data in connection with the registration and establishment of user’s account or the use or continuation of provision of educational services, products and facilities.

MagiCube may work with third parties that use applications or computer technologies to find out more about users of Una.

Failure to supply such personal data may result in MagiCube being unable to register and establish a user account or use or continue the provision of educational services and products and facilities.

Protection of Children under the age of 18

Data subjects who are under the age of 18 must obtain permission from their parents or legal guardians before providing any personal data to MagiCube.

Purposes of Use of Personal Data Collected

The purposes for which the personal data relating to the data subjects may be used will vary depending on the nature of the data subjects’ relationship with MagiCube, they may include the following:

  1. Assessing the merits and suitability of the data subjects as actual or potential applicants for educational services, products and facilities;
  2. Conducting statistical and data analysis;
  3. Allowing a purchase or an obtaining of a product or service introduced or referred to by MagiCube;
  4. Communicating with data subjects or its authorised;
  5. Enabling MagiCube to ensure smooth operation of the products, services and facilities provided to the data subjects, and to improve, optimize and configure the services for the data subjects;
  6. Researching and/or designing and/or implementing education related services, products and facilities;
  7. Marketing services, products and other subjects (please see further details related to ‘Direct Marketing’ below);
  8. Conducting, or allowing to be conducted, research on usage and activities on parts of Una including number of visitors, behaviour and usage patterns, for more accurate reporting and to improve the effectiveness of marketing of Una;
  9. Performing investigation or inquiry of any illegal conduct;
  10. Complying with obligations, requirements, arrangements or procedures that apply to MagiCube or that it is expected to comply according to:
    1. Any law binding or applying to it within the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future;
    2. Any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies within Hong Kong existing currently and in the future; and
    3. Any contractual obligations or other commitment applying to it under any contractual arrangement MagiCube has with its agent, representative, contractor, business partner or other third party which MagiCube has entered into a contractual relationship with
  11. Maintaining an usage or purchase history or pattern of data subjects for MagiCube to evaluate into future opportunity in education products, services and facilities; and
  12. Purposes incidental, associated or relating to any of the above items (i) to (x).

Transfer of Personal Data Collected

Personal data held by MagiCube relating to data subjects will be kept confidential but MagiCube may provide and disclose (as defined in the Ordinance) such personal data to the following parties for the purposes set out in the previous paragraph:

  1. Any agent, contractor, business partner or other third party which MagiCube works together with in its provision of such service, product or facility, wherever situated;
  2. Any party that a data subject has initiated a business transaction with or will make a payment to or through;
  3. Any party to whom MagiCube is under an obligation or otherwise required to make disclosure under the requirements of any law binding or applying to it within or outside Hong Kong, or any disclosure under and for the purposes of any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies with which MagiCube is expected to comply, or any disclosure pursuant to any contractual or other commitment of MagiCube, all of which are within Hong Kong and may be existing currently and in the future;
  4. Such party as authorized to receive a response from MagiCube in accordance with Part V of the Ordinance.

Storage of Personal Data and Security

All personal data collected from data subjects will be stored in secure servers of MagiCube in order to prevent any unauthorized or accidental access, processing or erasure.

MagiCube maintains this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure personal data.

MagiCube will take all practical steps to ensure that personal data will not be kept longer than necessary and MagiCube will comply with all statutory and regulatory requirements of Hong Kong concerning the retention of personal data.

While MagiCube does everything it can to protect personal data from unauthorized use, processing and disclosure, data subjects should take precaution not to share, provide or facilitate unauthorized use of an unique username and/or password assigned by MagiCube or allow access or use of it by others. If, in the unlikely event, unauthorized transactions have been discovered through no fraud, fault or negligence on the part of data subjects, the data subjects should inform MagiCube immediately.

Direct Marketing

MagiCube intends to use the data subject’s data in direct marketing and MagiCube requires the data subject’s consent (which includes an indication of no objection) for that purpose.

The specific requirement regarding data subject’s consent (which includes an indication of no objection) under Part VIA of the Ordinance shall take effect on 1st April 2013. In this connection, please note that:

  1. The name, contact details, product and services portfolio information, usage pattern and demographic data of the data subject held by MagiCube from time to time may be used by MagiCube in direct marketing and the following classes of services, products and subjects may be marketed:
    1. Education related services, products and facilities;
    2. Co-branding partners of MagiCube for a particular service, product or facility which can be found on MagiCube’s website as the case may be
  2. Other than marketing the above services, products and subjects itself, MagiCube does not intend to provide any personal data to all or any of the persons described in paragraph 18 for use by them in direct marketing, and MagiCube requires the data subject’s written consent (which includes an indication of no objection) for that purpose.

If a data subject does not wish to receive any marketing and other promotional materials from MagiCube, a data subject can always have an opportunity to opt-out by email to admin@magicubedu.com or by phone to (+852) 6711 2315 or by mail sent to MagiCube’s office. MagiCube will then, at no cost to the data subject, act on the request to opt-out within 14 days and ensure that the data subject will not included in future direct marketing promotions.

Rights of Access or Correction of Personal Data

In accordance with the terms of the Ordinance, MagiCube has the right to charge a reasonable fee for the processing of any data access request. Any data access request must be made in writing and with completed form as prescribed under the Ordinance.