Privacy Policy

1. Introduction

Heirloom Desk ("we," "us," or "our") is committed to handling your personal data responsibly. This Privacy Policy explains what personal information we collect, why we collect it, how we use it, and what rights you have in relation to it. It applies to personal data collected through our website at heirloom-desk.pro, through our enquiry and enrolment process, and through participation in our programmes.

If you have questions about this policy or how we handle your data, please contact us at: [email protected]

2. Data We Collect

We collect the following categories of personal information:

• Contact information: your name, email address, and telephone number, provided when you submit an enquiry via our website contact form.
• Enrolment information: information provided during the programme enrolment process, including your address and payment details.
• Programme participation data: attendance records and feedback you provide during or after a programme.
• Website usage data: technical information collected via cookies and analytics tools, including pages visited, session duration, and device type. See our Cookie Policy for details.

We do not collect sensitive personal data (such as financial account details or health information) through our website. Payment processing is handled by a third-party payment provider subject to its own privacy policy.

3. How We Use Your Data

We use the personal data we collect for the following purposes:

• Responding to your enquiries and providing information about our programmes
• Processing programme enrolments and administering your participation
• Sending confirmation and administrative communications related to the programme you have enrolled in
• Improving our website and understanding how visitors engage with our content
• Complying with our legal obligations

We do not use your personal data for direct marketing without your explicit consent. We do not sell your data to third parties.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

• Contractual necessity: where processing is necessary to fulfil your programme enrolment and deliver our services.
• Legitimate interests: where we have a legitimate interest in responding to enquiries and improving our services, provided this does not override your rights.
• Consent: where you have given explicit consent, for example for optional marketing communications.
• Legal obligation: where we are required by Hong Kong law to retain certain records.

5. Data Retention

We retain personal data for no longer than is necessary for the purpose for which it was collected. Specifically:

• Enquiry data is retained for up to 12 months if you do not proceed with a programme.
• Enrolment and participation records are retained for 7 years for accounting and legal compliance purposes.
• Website analytics data is retained in anonymised or aggregated form.

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

6. Data Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or misuse. These include:

• Secure, encrypted data storage
• Access controls limiting who within our organisation can access personal data
• Regular review of our data handling practices

In the event of a data breach that may affect your rights, we will notify you as required under applicable Hong Kong law.

7. Sharing Your Data

We do not sell or rent your personal data. We may share your data with:

• Service providers: third parties who assist us in delivering our services, including payment processors, email platforms, and website hosting providers. These parties are contractually required to protect your data and use it only for specified purposes.
• Analytics providers: such as Google Analytics, which processes website usage data in accordance with its own privacy policy.
• Legal authorities: where required by law or in response to valid legal process.

8. Cookies

Our website uses cookies to improve functionality and understand usage patterns. Please refer to our Cookie Policy for a full explanation of the cookies we use and how to manage your preferences.

9. Your Rights

Under applicable Hong Kong privacy law (the Personal Data (Privacy) Ordinance, Cap. 486), you have the following rights:

• Access: you may request a copy of the personal data we hold about you.
• Correction: you may request that inaccurate or incomplete data be corrected.
• Erasure: in certain circumstances, you may request that your data be deleted.
• Objection: you may object to processing carried out on the basis of legitimate interests.
• Withdrawal of consent: where processing is based on your consent, you may withdraw it at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact us at [email protected]. We will respond within 40 days as required under Hong Kong law. If you are dissatisfied with our response, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.

11. Children's Privacy

Our programmes are designed for adults aged 18 and over. We do not knowingly collect personal data from individuals under 18. If you believe a minor has submitted data to us, please contact us and we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will post the updated version on our website and indicate the date it was last revised. If changes are material, we will notify programme participants directly. Continued use of our website or services after any update constitutes acceptance of the revised policy.

13. Contact

For privacy-related enquiries, please contact:

Heirloom Desk
10/F, Wanchai Central Building
89 Lockhart Road, Wan Chai, Hong Kong
Email: [email protected]
Phone: +852 3247 5981