1. 21 Silk Rd Limited (hereafter “21 Silk Rd”) is a company incorporated in HKSAR under the Companies Ordinance (Cap. 622 of the Laws of Hong Kong). The website BRI Updates (www.BRIupdates.com) is being managed by 21 Silk Rd, which pledges to meet and comply with the requirements of the Personal Data (Privacy) Ordinance (Cap.486 of the Laws of Hong Kong) (hereafter “Privacy Ordinance”). In doing so, 21 Silk Rd has committed itself to protect and keep in strict confidence any personal data (as defined below) collected.
2. This Statement is important and should be read thoroughly in order to understand the privacy policies of 21 Silk Rd in respect of any personal data it collects from you, as a data subject (as defined below).
3. 21 Silk Rd may amend, update, vary or add to this Statement from time to time without any prior notice as necessary and any revised Statement will be published on this website (“www.BRIupdates.com”).
4. By accessing and using www.BRIupdates.com and any related platforms owned and managed by 21 Silk Rd, including but not limited to Belt & Road Express Facebook Page (https://www.facebook.com/BeltRoadExpress/)/Instagram, you are agreeing to the terms and conditions set out herein.
Type of Personal Data
5. The term “personal data”, wherever mentioned in this Statement, includes the following kind of information:
a. All the data which may be collected or held by 21 Silk Rd from time to time in connection with the registration and establishment of user’s account or the use or continuation of provision of services and products, the following data relating to a data subject (including any updated data of any of the following data):
i. email address;
ii. full name;
iii. date of birth;
vi. current location;
viii. company name;
ix. educational level;
x. institution; and
xi. information as referred to in the paragraphs below under ‘Cookies, Domain Names and IP Addresses’.
b. Information collected through computer technologies by third parties whom 21 Silk Rd works with to find out more about users of 21 Silk Rd’s platforms and products, including number of the visitors, behavior and usage patterns, for more accurate reporting and to improve the effectiveness of marketing of 21 Silk Rd.
c. Other data collected from data subjects in the ordinary course of the continuation of the relationship between 21 Silk Rd and data subjects such as the followings:
i. when a data subject uses 21 Silk Rd’s website and/or social media platforms;
ii. when a data subject submits any work or statement through 21 Silk Rd’s website and/or social media platforms;
iii. when a data subject takes part in any activities published by 21 Silk Rd on its website or other social media platform managed by 21 Silk Rd;
iv. when a data subject enters into, uses and/or makes a comment on a discussion board, blog, similar forum established on BRI Updates, or other social media platform managed by 21 Silk Rd; and
v. when a data subject participates in online activities as published on 21 Silk Rd’s website or social media platforms including multi-media competitions, assessments, survey and other online activities as published from time to time.
6. The term "data subject(s)", wherever mentioned in this Statement, includes the following categories of individuals:-
a. Users of 21 Silk Rd’s website;
b. Users of social media platforms managed or owned by 21 Silk Rd; and
c. Users of related services and products so forth provided by 21 Silk Rd or its partners.
7. 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 21 Silk Rd 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 Privacy Ordinance.
Cookies, Domain Names and IP Addresses
9. “Cookies” are small bits of information that are automatically stored in your computer hard drive which can be retrieved by this website.
10. Cookies can make the site more useful by storing information about your preferences on particular websites and thus enabling 21 Silk Rd 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 21 Silk Rd’s website.
11. Every time you log on to this website, 21 Silk Rd will, through its network servers, automatically collect your domain name and IP address for the purpose of verification and 21 Silk Rd will use such data for visitor flow statistical and data analysis.
Collection of Personal Data
12. It is necessary for the data subjects to supply 21 Silk Rd with personal data in connection with the registration and establishment of user’s account for accessing the full function/content (including the personalization of content) of BRI Updates website or for the use extra online/offline services 21 Silk Rd or its partner(s) provide.
13. 21 Silk Rd may work with third parties that use applications or computer technologies to find out more about users of 21 Silk Rd’s website and/or social media platforms.
Protection of Children under the age of 18
14. Data subjects who are under the age of 18 must obtain permission from their parents or legal guardians before providing any personal data to 21 Silk Rd.
Purposes of Use of Personal Data Collected
15. 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 21 Silk Rd, they may include the following:
a. assessing the merits and suitability of the data subjects as actual or potential applicants for both online and offline services and products;
b. conducting statistical and data analysis;
c. communicating with data subjects or its authorized;
d. enabling 21 Silk Rd 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;
e. researching and/or designing and/or implementing media related services and products;
f. marketing services, products and other subjects (please see further details related to ‘Direct Marketing’ below);
g. conducting, or allowing to be conducted, research on usage and activities on parts of 21 Silk Rd’s website including number of visitors, behavior and usage patterns, for more accurate reporting and to improve the effectiveness of marketing of 21 Silk Rd;
performing investigation or inquiry of any illegal conduct;
h. complying with obligations, requirements, arrangements or procedures that apply to 21 Silk Rd or that it is expected to comply according to:
i. any law binding or applying to it within the Hong Kong Special Administrative Region (“Hong Kong”) existing currently and in the future;
ii. 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
iii. any contractual obligations or other commitment applying to it under any contractual arrangement 21 Silk Rd has with its agent, representative, contractor, business partner or other third party which 21 Silk Rd has entered into a contractual relationship with;
i. maintaining an usage or purchase history or pattern of data subjects for 21 Silk Rd to evaluate into future opportunity in education products, services and facilities; and
j. purposes incidental, associated or relating to any of the above items 15(a) to 15(i).
Transfer of Personal Data Collected
16. Personal data held by 21 Silk Rd relating to data subjects will be kept confidential but 21 Silk Rd may provide and disclose (as defined in the Privacy Ordinance) such personal data to the following parties for the purposes set out in the previous paragraph:-
a. any agent, contractor, business partner or other third party which 21 Silk Rd works together with in its provision of such service or product, wherever situated;
b. any party that a data subject has initiated a business transaction with or will make a payment to or through;
c. any party to whom 21 Silk Rd 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 21 Silk Rd is expected to comply, or any disclosure pursuant to any contractual or other commitment of 21 Silk Rd, all of which are within Hong Kong and may be existing currently and in the future;
d. such party as authorized to receive a response from 21 Silk Rd in accordance with Part V of the Privacy Ordinance; and
Storage of Personal Data and Security
17. All personal data collected from data subjects will be stored in secure servers of 21 Silk Rd in order to prevent any unauthorized or accidental access, processing or erasure.
18. 21 Silk Rd maintains this commitment to data security by implementing appropriate physical, electronic and managerial measures to safeguard and secure personal data.
19. 21 Silk Rd will take all practical steps to ensure that personal data will not be kept longer than necessary and 21 Silk Rd will comply with all statutory and regulatory requirements of Hong Kong concerning the retention of personal data.
20. While 21 Silk Rd 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 21 Silk Rd or allow access or use of it by others.
21. 21 Silk Rd may use the data subject's data in direct marketing and 21 Silk Rd requires the data subject's consent (which includes an indication of no objection) for that purpose.
22. The specific requirement regarding data subject's consent (which includes an indication of no objection) under Part VIA of the Privacy Ordinance shall take effect on 1st April 2013. In this connection, please note that:-
a. the name, contact details, product and services portfolio information, usage pattern and demographic data of the data subject held by 21 Silk Rd from time to time may be used by 21 Silk Rd in direct marketing and the following classes of services, products and subjects may be marketed:
i. education related services, products and facilities;
ii. co-branding partners of 21 Silk Rd for a particular service, product or facility which can be found on 21 Silk Rd’s website as the case may be; and
b. other than marketing the above services, products and subjects itself, 21 Silk Rd does not intend to provide any personal data to all or any of the persons described in paragraph 17 for use by them in direct marketing, and 21 Silk Rd requires the data subject’s written consent (which includes an indication of no objection) for that purpose.
23. If a data subject does not wish to receive any marketing and other promotional materials from 21 Silk Rd, a data subject can always have an opportunity to opt-out by clicking the unsubscribe link in the promotional emails. 21 Silk Rd 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 include in future direct marketing promotions or subscription.
Rights of Access or Correction of Personal Data
24. In accordance with the terms of the Privacy Ordinance, 21 Silk Rd 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 Privacy Ordinance.
25. The persons to whom requests for access to data or correction of data or for information regarding policies and practices and kinds of personal data held are to be addressed is as follows:-
Data Protection Officer,
21 Silk Rd Limited
Email : firstname.lastname@example.org
Last updated: April 23, 2019