Privacy Policy — Oxherd Ledger

1. Introduction

Oxherd Ledger is committed to handling personal information with care and transparency. This Privacy Policy explains what personal data we collect, why we collect it, how we use and protect it, and what rights you have in relation to your data. It applies to all individuals who use our website or enrol in our programmes.

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

2. Data We Collect and How We Collect It

Information you provide directly

Name and email address (submitted via our contact form or enrolment enquiry)
Phone number (if provided voluntarily)
Messages or enquiries submitted through the contact form
Payment information processed via our payment processor (we do not store card details)

Information collected automatically

Browser type, device type, and operating system
IP address and approximate geographic location
Pages visited, time spent on the site, and referring URLs
Cookie and tracking data (see our Cookie Policy for details)

Legal basis for processing (under Hong Kong PDPO and applicable frameworks)

Your consent (for marketing communications and optional cookies)
Contract performance (to administer your enrolment and deliver programmes)
Legitimate interests (to improve our services and respond to enquiries)
Legal obligation (where required by law)

3. How We Use Your Data

To respond to enquiries submitted via the contact form
To administer course enrolment and deliver programme materials
To send administrative communications related to your enrolment
To analyse how the website is used and improve its content and structure
To send marketing communications where you have given consent (you may withdraw consent at any time)
To comply with legal obligations

We do not sell personal data. We do not share personal data with financial product providers or any commercial partners for marketing purposes.

4. Data Retention

Enquiry data is retained for up to 24 months. Enrolment records are retained for seven years for administrative and legal compliance purposes. Marketing consent records are retained until you withdraw consent. Cookie data retention periods are described in the Cookie Policy.

5. Data Protection Measures

We take reasonable technical and organisational steps to protect personal data against unauthorised access, loss, or disclosure. These include encrypted data transmission (HTTPS), access controls limiting who within Oxherd Ledger can access personal data, and regular review of our data handling practices. In the event of a data breach affecting your rights, we will notify you as required by applicable law.

6. Third-Party Services

We use a small number of third-party services in connection with operating our website and programmes. These may include analytics tools, email delivery services, and payment processors. Each is selected on the basis of data protection standards. We do not permit third parties to use your data for their own marketing purposes. A full list of current third-party service providers is available on request.

7. Cookies

Our website uses cookies for essential site function and, with your consent, for analytics purposes. We do not use advertising cookies. For a full explanation of the cookies we use and how to manage your preferences, see our Cookie Policy.

8. Your Rights

Under the Personal Data (Privacy) Ordinance (Hong Kong) and applicable data protection law, you have the following rights in relation to your personal data:

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: You may request deletion of your data in certain circumstances.
Withdrawal of consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
Objection: You may object to processing based on legitimate interests.
Complaint: You have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (Hong Kong) if you believe your rights have been infringed.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

9. External Links

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

10. Children's Privacy

Our programmes are designed for adults aged 18 and over. We do not knowingly collect personal data from anyone under the age of 18. If you believe we have inadvertently collected such data, please contact us and we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. Material changes will be communicated by posting an updated version on this page with a revised "Last Updated" date. Continued use of our website after the effective date of any update constitutes acceptance of the revised policy.

12. Contact

Oxherd Ledger
16/F, Prosperity Tower, 39 Queen's Road Central, Central, Hong Kong
Email: [email protected]
Phone: +852 2519 6384