Legal
Privacy Policy
Last Updated: 14 April 2025 · Golden Abacus
Golden Abacus is committed to handling personal information responsibly and transparently. This policy explains what information we collect, how we use it, and what rights you have in relation to it. It applies to all interactions with Golden Abacus, including course enquiries, enrolments, and use of this website.
If you have questions about this policy, please contact us at [email protected].
1. Who We Are
Golden Abacus is an education provider registered in Hong Kong, operating from 18/F, Skyline Tower, 39 Wang Kwong Road, Kowloon Bay, Hong Kong. We provide structured educational programmes on gold, precious metals and alternative assets for pre-retirees.
2. Information We Collect
We collect the following categories of personal information:
- Contact information: name, email address, phone number, provided when you submit an enquiry or register for a programme.
- Programme participation information: course attended, attendance records, written materials completed during the programme.
- Communication records: records of correspondence between you and Golden Abacus by email or phone.
- Website usage data: anonymised analytics data about how visitors use this website, collected via cookies (see our Cookie Policy).
- Payment information: bank transfer references or cheque details used for course fee payment. We do not store card details.
We do not collect sensitive personal data (such as financial account details, identity card numbers or health information) unless you choose to share it voluntarily during a programme session — in which case it remains within that session and is not recorded by us.
3. Legal Basis for Processing
We process personal information on the following legal grounds:
- Contract performance: to deliver the course or programme you have enrolled in and to respond to your enquiry.
- Legitimate interest: to maintain records of past participants, to improve our programmes, and to send relevant follow-up communications where participants have engaged with us.
- Consent: for marketing communications, which you may withdraw at any time.
- Legal obligation: where required by Hong Kong law, including the Personal Data (Privacy) Ordinance (Cap. 486).
4. How We Use Your Information
- To respond to enquiries and process enrolments
- To deliver course materials and facilitate programme participation
- To communicate about scheduling, cohort updates and programme-related matters
- To provide the six-month post-completion educator access included in each programme
- To send occasional updates about new programmes or cohort dates, where you have not objected
- To maintain administrative and financial records as required
- To improve the quality and accuracy of our course content over time
5. Data Sharing
We do not sell, rent or share your personal information with third parties for commercial purposes. Personal information is not provided to product providers, financial institutions or advertisers under any circumstances.
Limited sharing may occur in the following circumstances:
- Service providers: we use a small number of trusted service providers (email and document storage) who process data only on our instructions and under contractual obligations of confidentiality.
- Legal requirements: where required to do so by applicable Hong Kong law or by a lawful authority.
What is discussed during programme sessions is treated as confidential. Participant contributions are not attributed or reported outside the session context.
6. Data Retention
- Enquiry records: retained for 12 months from last contact if no enrolment follows.
- Participant records: retained for 7 years following programme completion, in accordance with standard administrative and financial record-keeping requirements.
- Marketing consent records: retained until consent is withdrawn and for 2 years thereafter.
- Website analytics data: retained in anonymised form for up to 26 months.
7. Data Security
We use appropriate technical and organisational measures to protect personal information from unauthorised access, disclosure, alteration or destruction. These include encrypted email communications, password-protected file storage, and restricted staff access to personal data. In the event of a data breach that affects your rights, we will notify you and the Office of the Privacy Commissioner for Personal Data (PCPD) as required by applicable law.
8. Cookies
This website uses cookies to support basic functionality and to understand how the site is used. For full details, see our Cookie Policy.
9. Your Rights Under Hong Kong Law
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
- Object to direct marketing uses of your personal data at any time
- Withdraw consent for processing based on consent
- Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD)
To exercise any of these rights, please contact us at [email protected]. We will respond within 40 days, as required under the Ordinance.
10. Third-Party Links
This website may include links to external websites. We are not responsible for the privacy practices of those sites, and we encourage you to review their policies before sharing personal information with them.
11. Children's Privacy
Our programmes are designed for adults aged 18 and above. We do not knowingly collect personal information from individuals under 18. If you believe we have inadvertently collected such information, please contact us and we will delete it promptly.
12. Changes to This Policy
We may update this policy from time to time to reflect changes in our practices or in applicable law. Material changes will be communicated to current participants by email. The date of last update is shown at the top of this page. Continued engagement with Golden Abacus after changes take effect constitutes acceptance of the updated policy.
13. Contact
For privacy-related enquiries, requests or complaints:
- Email: [email protected]
- Address: 18/F, Skyline Tower, 39 Wang Kwong Road, Kowloon Bay, Hong Kong
- Phone: +852 3926 4178
If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.