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Privacy Policy

Last Updated: 14 March 2025  ยท  Effective: 14 March 2025

1. Introduction

Lion Rock Study ("we", "us", "our") is committed to protecting the personal data of everyone who contacts us or enrols in our courses. This policy explains what data we collect, how we use it, how long we retain it, and what rights you have under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

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

2. Who We Are

Lion Rock Study is an educational services company registered in Hong Kong, operating from Suite 808, Lippo Centre, 89 Queensway, Admiralty, Hong Kong. We are the data controller responsible for personal data collected through our website and in the course of delivering our programmes.

3. What Data We Collect

Contact and Enquiry Data

When you submit an enquiry through our website, we collect your name, email address, and optionally your phone number and a message. This information is used solely to respond to your enquiry and, if you proceed, to administer your enrolment.

Enrolment Data

If you enrol in a course, we collect the contact details you provide at enquiry stage, together with any additional information relevant to course administration (for example, which cohort you are joining and your payment reference).

Course Participation Data

Written exercises submitted as part of the Considered Portfolio programme or the Midlife Investor Full Track are held securely and used only for the purpose of providing written feedback. They are not shared with other participants or third parties.

Website Usage Data

We may collect anonymised information about how visitors use our website, including pages viewed and time spent on each page. This data is collected in aggregate and is not linked to identifiable individuals unless you have given consent via our cookie preference controls.

4. Legal Basis for Processing

Under the PDPO, we process personal data on the following bases:

  • Your consent, given when you submit an enquiry or accept our cookie policy
  • The performance of a contract (course enrolment and delivery)
  • Our legitimate interest in responding to enquiries and administering course cohorts
  • Compliance with applicable Hong Kong law

5. How We Use Your Data

  • To respond to your enquiry within two working days
  • To confirm enrolment and provide course access
  • To deliver written feedback on submitted exercises
  • To send course-related communications (scheduling, material availability, cohort reminders)
  • To improve the quality of our programmes through aggregate analysis of cohort feedback

We do not use your personal data for marketing purposes without your explicit consent. We do not sell, rent, or share your personal data with financial product providers, advertisers, or any unaffiliated third parties for commercial purposes.

6. Data Retention

Enquiry data is retained for six months if no enrolment follows, after which it is securely deleted. Enrolment and course participation data is retained for three years from the end of the course, to support any follow-up queries from participants. Payment records are retained for seven years in accordance with Hong Kong accounting requirements.

7. Data Security

We store personal data on servers located in Hong Kong or with providers operating under equivalent data protection standards. Access to personal data is restricted to members of the Lion Rock Study team who require it to perform their role. We review our security practices annually. In the event of a data breach that poses a material risk to individuals, we will notify affected parties as promptly as is practicable.

8. Cookies

Our website uses cookies to understand how it is being used and to store your preferences. Please read our Cookie Policy for a full explanation of the cookies we use and how to manage your preferences.

9. Third-Party Services

We may use the following third-party services in the course of operating our website and programmes:

  • Email delivery services, for sending course communications
  • Analytics services, if you have consented to analytics cookies
  • Video conferencing platforms, for hosting reflection calls

Each third-party service processes data in accordance with its own privacy policy. We select providers that meet an appropriate standard of data protection for Hong Kong-based operations.

10. Your Rights Under the PDPO

Under the PDPO, you have the right to:

  • Access the personal data we hold about you
  • Correct any inaccurate personal data
  • Withdraw consent at any time where processing is based on consent
  • Request deletion of your personal data, subject to our legal retention obligations
  • Object to processing for purposes not related to your course or enquiry

To exercise any of these rights, please write to [email protected]. We will respond within 40 days, as required by the PDPO.

11. External Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to read their privacy policies before sharing personal data with them.

12. Children

Our courses are designed for adults aged 40 and over. We do not knowingly collect personal data from anyone under the age of 18. If we become aware that we have done so, we will delete that data promptly.

13. 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 after a change constitutes acceptance of the revised policy. For material changes, we will notify enrolled participants by email.

14. Contact

All data-related enquiries should be directed to:

Lion Rock Study
Suite 808, Lippo Centre, 89 Queensway, Admiralty, Hong Kong
Email: [email protected]
Phone: +852 2531 9462

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong at www.pcpd.org.hk.