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                                 Our Commitment to Your Privacy

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Mandarin Time (“MT”) is committed to protecting the privacy of our potential and existing customers. The MT privacy policy (the “Privacy Policy”) applies to all Personal Data (as defined below) processed by us, including Personal Data collected or submitted through our websites, mobile applications or through our official social media pages or through other channels online and offline as further described below (collectively the “MT Products”).

 

If you cannot, or will not, provide us with the personal information we reasonably require, we may be unable to provide you with the information, goods or services you have requested.

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Your data will be controlled by Mandarin Time International Ltd, Owner: Yang Jing, Room A&B,14th Floor, World Trust Tower, 50 Stanley Street, Central, Hong Kong. Tel: +852 61110523. Email: contact@mandarintime.com. Mandarin Time controls www.mandarintime.com, www.mandarintimeschool.com, www.mandarintime.online.

Being the controller means that this company is responsible for ensuring that your personal data is processed in compliance with applicable privacy and data protection legislation.

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 Personal Data

 “Personal Data” is information or pieces of information that could allow you to be identified, such as for example:

  • Name and contact details (e.g. postal and email address, telephone number)

  • Account information (e.g. user name, profile picture or social media account ID)

  • Country of residence

  • Birth date

  • Technical information, e.g. screen/user name, IP address, browser and device data, information collected through cookies, pixel tags and other technologies, server log file data, app usage data and location data

  • Preferences (e.g. shopping habits, preferred educational courses)

  • Company or school name and address

  • Credit and debit card number

  • Medical condition (e.g. allergies or illness)

 

 How do we collect Personal Data?

 We collect Personal Data in a variety of ways:

  • Directly from you: Information is collected directly from you, either by you providing the information directly to us or you acting in a manner that provides us with the information, for example:​

    • Online: We collect your Personal Data through the MT Products, for example when you sign up for a newsletter or a brochure, enrol in a product or service. We also collect Personal Data:

    • Through cookies. Cookies allow a web server to transfer data to a computer or device for recordkeeping and other purposes. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. For detailed information about the cookies we use and the purposes for which we use them, please see our cookie policy.

    • Through your use of a mobile application. When you download and use our mobile application, and to the extent allowed by your privacy settings in the application, we track and collect mobile application usage data, such as the date and time the mobile application on your device accessing our servers and what information and files have been downloaded to the mobile application based on your device number.

    • Through your device. Provided that you have enabled that function on your device, we collect the physical location of it to provide you with personalized location-based services and content. Read more about such services under “How do we use Personal Data?”

    • Offline: We collect Personal Data from you offline, for example when you contact customer service, enrol in a class or service or provide information to us in writing.

    • Business partners, such as local sales agents that promote the sales of our services in your country of residence.

    • Claims handlers who receive information about your insurance claims in case of an insurance situation.

    • From other sources. We may receive your Personal Data from other sources, such as public databases; joint marketing partners such as marketing agencies or providers of software and services for digital marketing automation and analytics; social media platforms, including but not limited to; Facebook, Instagram, Snapchat, Musically, LinkedIn, Twitter, YouTube and messenger services such as WhatsApp or Facebook Messenger; from people with whom you are friends or otherwise connected with on social media platforms, as well as from other third parties. For example, if you elect to connect your social media account to your MT Products account, such Personal Data that you have registered in your profile, such as your email address, phone number, postal address, date of birth, name and user name will be shared with us. Furthermore, we use cookies to track members of social media networks as further explained in our cookie policy.

    • If you browse our sites We may also collect information about your use of our services through your browser to trace activity on our sites, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version, service provider, and the name and version of the MT Product you are using. In addition, an IP Address is identified and logged automatically in our server log files whenever you visit the MT Products, along with the time of the visit and the page(s) that were visited. These data are only stored and used together with other Personal Data that you have submitted if you have given your consent to do so. You can read more about collection of your IP address and other browsing data in our cookie policy.

       

How do we use Personal Data?

Your Personal Data will be processed by MT for the purposes of completing your booking, providing you with the  products and services that you have ordered, for customer service,  administrative services or as otherwise necessary to perform the contract between you and us or as further described in this policy

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  •  We may also use Personal Data:

    • For statistical purposes, calculating usage levels, and helping diagnose server problems with the MT Products as well as to ensure that the MT Products function properly.

    • To allow you to contact and be contacted by other users through the MT Products, as permitted by the applicable product.

    • To allow you to participate on message boards, chat, profile pages and blogs and use other services enabling you to post information and materials.

    • If you have given your consent:​

    1. To provide you with personalised location-based services and content through the use of your device’s physical location. 

    2. To market our products and services, including special promotions based on your interests, for example through email marketing solutions such as Salesforce Marketing Cloud’s management software which maintains mailing lists and schedules and modifies email messages based on what recipients read, click-on or forward. All such email communication will include a clear unsubscribe link.

    3. To analyse and improve our offers by identifying usage trends, determining the effectiveness of our promotional campaigns and tailoring the MT Products experience and content based on your past activities on the MT Products. 

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     How do we share Personal Data?

  • We share your Personal Data with our corporate affiliates, business partners and service providers both within and outside Hong Kong/EU:

    • Our corporate affiliates are for example a local MT school that promotes the sales of our services and offers customer service in your country of residence, or the school in your destination country that provides some of the services that you have ordered.

    • Business partners are for example local sales agents that promote the sales of our services in your country of residence; 

    • Service providers, such as providers of IT systems, for example for managing customer relations or payments, scheduling classes or storing learning results; or providers of software and services for digital marketing automation and analytics.

  • We also share Personal Data as we believe to be necessary: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions or a contract; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

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   On what do we base our right to collect and use Personal Data?

    We base our right to collect and use your Personal Data on the need to do so in order to provide you with the services or               products that you have ordered from us, or when there is a legitimate interest for us (i.e. the service provider) to use your             Personal Data, such as for the marketing of products or services similar to the one(s) you have already purchased from that         same legal entity.

 

    To the extent we use sensitive Personal Data, we base this on your explicit consent. Sensitive data can for example be                   information about health, ethnicity or religious beliefs, read more under “Sensitive data”.

 

    To the extent that we use your Personal Data to send you offers beyond what is considered to be within our legitimate interest,     such as marketing of products and services provided by an MT affiliate, we base this on your specific consent.

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   Security

   We use appropriate organizational, technical and administrative measures to keep the Personal Data under our control                accurate and up-to-date, as well as to protect the Personal Data against unauthorised or unlawful processing and the                  accidental loss, destruction or damage of the Personal Data.

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   Unsubscribe

   If at any time you wish to stop receiving marketing communications from us you can use the unsubscribe feature in the                marketing communication you received or let us know by using the contact information listed in the “Contact Us” section. In        your request, please indicate that you wish to stop receiving marketing communications from us.

   

   Please note that changes may not be effective immediately. We will endeavour to comply with your request(s) as soon as              reasonably practicable. 

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  Third Party Sites

  This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third         parties, including any third party operating any site to which the MT Product contain a link. The inclusion of a link on MT           Products does not imply endorsement of the linked site by us or by our affiliates.

  Additionally, we may provide you with access to third-party functionality that permits you to share your activities on EF

  Products to your social media account(s), for example Facebook or LinkedIn. Please note that any information that you provide   through the use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We   have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this     functionality.

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  How long do we store personal data?

  We will only keep your Personal Data for as long as it is necessary for the purposes for which it has been collected or in               accordance with time limits stipulated by law and market practice, unless further retention is necessary for compliance with a     legal obligation or for the establishment, exercise or defence of legal claims or unless a specific time period has been                   communicated.

  We will keep limited parts of your Personal Data which are necessary for marketing purposes until you withdraw your consent,   but in no event for longer than 10 years after your last completed service or delivery of product.

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  If you are under the age of 16

  If you are under the age of 16, you should review this text together with your parent or guardian to make sure you both               understand them. We are not responsible for checking your age but sometimes we still do verification checks. If we learn that       you are under the age of 16 and that we have collected information about you without consent from your parent or guardian,       we will delete the information as soon as possible and you will not be able to use MT Products.

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  Sensitive Data

  We do not generally seek to collect any sensitive Personal Data. Sensitive Personal Data is data related to racial or ethnic             origin, political opinions, religious or philosophical beliefs, health or medical condition, criminal background or trade union         membership. In certain situations, this might however be necessary (for example we would ask if your child have any food           allergy if your child booked Summer Camp at Mandarin Time). We will make sure that we receive your explicit consent to such   processing and treat this information securely.

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  Updates To This Privacy Policy

  Our Privacy Policy may change from time to time. We will not significantly reduce your rights under this Privacy Policy without   informing you. We will post any Privacy Policy changes on this page and, prior to implementing such changes, we will provide a   more prominent notice. Where required by law, we will seek your prior consent to any change.

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  Your Rights

   You have a right to, once per calendar year, contact us and without cost find out which information about you that is being          used. You have a right to receive your Personal Data in a machine readable format and you have a right to transfer your              personal to another data controller.

   You have the right to, at any time, withdraw your consent or object to us using your Personal Data for direct marketing                purposes and you may at any time request that the use of your Personal Data is restricted or that we shall delete your Personal    Data. Note however that a restriction or deletion could mean that we are not able to provide you with information, services or      products as you have requested. Upon your request, we are also obliged to correct Personal Data about you that is incorrect,        incomplete or misleading.

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   Contact Us

    If you would like to have a copy of the information MT holds about you; a copy of the standard data protection clauses or             would like to exercise any of your rights, please email us at contact@mandarintime.com.

    If you have complaints about our handling of your Personal Data, you have a right to contact the supervisory authority in the       country where you live.

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