Privacy Policy

1. Introduction

This Privacy Policy applies to Ink Well ("we", "us", "our"), a private education provider operating from 7/F, Eton Tower, 8 Hysan Avenue, Causeway Bay, Hong Kong. It covers the personal data we collect through our website, enquiry forms, course enrolment processes, and course sessions.

We collect and use personal data only for legitimate educational and administrative purposes. We do not sell personal data, and we do not share it with financial product providers, advertisers, or any third party for commercial purposes.

For data protection questions, please contact us at: [email protected]

2. Data We Collect

2.1 Enquiry and contact data

When you submit an enquiry through our website, we collect the information you provide, which may include your name, email address, and telephone number. This data is used solely to respond to your enquiry and, if appropriate, to discuss course options with you.

2.2 Enrolment data

When you enrol in a course, we collect the personal data necessary to administer your participation, including your name, contact details, and payment information. Payment processing is handled by a third-party provider and we do not store card data.

2.3 Course session data

Financial details and personal circumstances that participants choose to share during course sessions are treated as strictly confidential. This information is not recorded, stored, or shared. It exists within the session for educational discussion purposes only.

2.4 Website usage data

Our website may collect standard technical data including IP addresses, browser type, and pages visited through analytics cookies. See our Cookie Policy for details. This data is used to understand how visitors use the site and to improve the user experience.

3. How We Use Your Data

• To respond to enquiries about our courses
• To administer enrolment and course participation
• To send course materials, schedules, and administrative communications
• To process payments for course fees
• To maintain records as required by applicable law
• To analyse website usage and improve our online presence
• To contact you about future cohorts or related courses, if you have consented to this

We do not use personal data for automated decision-making or profiling.

4. Legal Basis for Processing

Under the Personal Data (Privacy) Ordinance (Cap. 486), we collect and use personal data only where we have a lawful basis to do so. Applicable bases include:

• Consent — for marketing communications and non-essential cookies, where you have actively opted in
• Contractual necessity — for data required to enrol you in a course and administer your participation
• Legitimate interest — for responding to enquiries and understanding how our website is used
• Legal obligation — where required to maintain records under applicable Hong Kong law

5. Data Retention

We retain personal data only for as long as is necessary for the purpose for which it was collected:

• Enquiry data from non-enrolling contacts: 12 months from the date of enquiry
• Enrolment and participation records: 7 years from the date of course completion, as required for financial record-keeping
• Website analytics data: 26 months (standard Google Analytics retention)
• Marketing consent records: until consent is withdrawn, plus 3 years

After the relevant retention period, data is securely deleted or anonymised.

6. Data Protection Measures

We take data security seriously and apply the following measures to protect the personal data we hold:

• Website data is transmitted over encrypted HTTPS connections
• Enrolment and payment data is held in secured, access-controlled systems
• Access to personal data is restricted to staff with a need to access it for their role
• Third-party service providers are subject to data processing agreements
• Our data handling practices are reviewed periodically

In the event of a data breach that poses a risk to individuals, we will notify affected parties and the Office of the Privacy Commissioner for Personal Data (PCPD) in accordance with applicable guidance.

7. Cookies

Our website uses cookies to support site functionality and to understand how visitors use the site. You can manage your cookie preferences at any time through our Cookie Policy page.

8. Third-Party Services

We use the following third-party services which may process personal data on our behalf:

• Payment processor — for secure handling of course fee transactions
• Email service provider — for sending administrative communications
• Website analytics — Google Analytics, for understanding site usage (anonymised where possible)

We do not share personal data with financial institutions, insurers, investment product providers, or marketing companies.

9. Your Rights

Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:

• Request access to the personal data we hold about you
• Request correction of inaccurate personal data
• Request deletion of personal data we hold about you (subject to applicable legal retention requirements)
• Withdraw consent for marketing communications at any time
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk

To exercise any of these rights, please contact us at [email protected]. We will respond within 40 days in accordance with the Ordinance.

10. Children's Privacy

Our courses are designed for adults aged 18 and above. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently received data from a minor, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last Updated" date at the top of the page. Continued use of our website or services following notification of changes constitutes acceptance of the revised policy.

12. Contact

For privacy-related questions, data access requests, or complaints, please contact us: