Privacy Policy

Who We Are

Dawn Terrace is a financial education provider based in Hong Kong. Our registered address is 12/F, Peninsula Office Tower, 18 Middle Road, Tsim Sha Tsui, Hong Kong. We offer structured financial courses for adults 40 and older who are reorganising their finances following a significant life change.

For the purposes of this policy, Dawn Terrace is the data controller responsible for any personal data we hold about you. If you have questions about how we handle your data, you are welcome to contact us at [email protected] or by calling +852 2835 4617.

What Information We Collect

We collect only the information that is necessary for us to deliver our courses and respond to your enquiries. This includes:

• Your name, as provided when you make an enquiry or enrol in a course
• An email address and telephone number where you wish to be contacted
• Details about the course or topic you are enquiring about
• Any additional information you choose to share with us in your message
• Technical data collected automatically when you visit our website, such as browser type, operating system, and pages visited

We do not ask for sensitive personal data such as financial account numbers, identity card numbers, or medical records unless there is a specific reason tied to course delivery, in which case we will explain this to you separately and obtain your clear agreement first.

How We Use Your Information

We use the information you provide to:

• Respond to your enquiries in a timely and relevant way
• Process your enrolment in a course and send you course materials
• Send administrative communications related to your enrolment, such as schedule changes or logistical information
• Improve our courses and understand which topics are most relevant to participants
• Meet our legal obligations, including record-keeping requirements

We will not use your contact details to send you marketing communications unless you have specifically agreed to receive them. If you do agree and later change your mind, you can withdraw that agreement at any time by writing to us.

Legal Basis for Processing

Our handling of your personal data is grounded in the following bases under the Personal Data (Privacy) Ordinance:

• Your consent, where you have actively provided information through our contact form or enrolment process
• The performance of a contract, where processing is necessary to deliver a course you have enrolled in
• Our legitimate interests in operating a lawful, well-run educational business, provided those interests do not override your rights
• Compliance with applicable legal obligations

How We Share Your Information

We do not sell, rent, or trade your personal information. We may share it in limited circumstances:

• With service providers who assist us in delivering courses or managing our systems — for example, an email delivery platform or a payment processor — under contractual obligations that require them to protect your data
• With professional advisers such as legal or accounting firms, on a confidential basis, where needed
• With regulatory bodies or law enforcement agencies, where we are legally required to do so

Any third parties we work with are selected carefully and are required to handle your data only for the purposes we specify.

How Long We Keep Your Data

We hold your personal data only for as long as is necessary. Enquiries that do not lead to enrolment are generally retained for twelve months and then deleted. Records relating to course enrolments are held for seven years to meet standard accounting and record-keeping obligations, after which they are securely removed from our systems.

You may ask us to delete your data earlier where there is no legal obligation on us to retain it. We will respond to such requests within a reasonable time.

Cookies and Website Analytics

Our website uses cookies — small files stored on your device — to help the site function and, where you have agreed, to understand how visitors use our pages. You can read more about the specific cookies we use in our Cookie Policy.

Analytics data is collected in aggregate form. We do not use it to identify individual visitors beyond what is necessary for the operation of the site.

Your Rights

Under the Personal Data (Privacy) Ordinance, you have the right to:

• Ask whether we hold personal data about you, and to receive a copy of it
• Request correction of any inaccurate or incomplete data we hold
• Ask us to delete your data, subject to any legal obligations that require us to keep it
• Withdraw consent where processing is based on your agreement
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (Hong Kong) if you are not satisfied with how we have handled your information

To exercise any of these rights, please write to us at [email protected]. We will respond within the timeframe set out under applicable law.

Data Security

We take reasonable steps to protect your personal data from unauthorised access, disclosure, or loss. Our systems are maintained with appropriate technical and organisational safeguards. However, no transmission over the internet can be guaranteed to be entirely secure, and we ask that you exercise care when sharing information online.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in how we work or in applicable law. When we do, we will revise the date shown at the top of this page. We encourage you to review this policy periodically. Continued use of our website or services after any update indicates your acceptance of the revised terms.

Contact Us

If you have any questions about this Privacy Policy or the way we handle your personal information, please reach out to us:

• Email: [email protected]
• Telephone: +852 2835 4617
• Post: Dawn Terrace, 12/F, Peninsula Office Tower, 18 Middle Road, Tsim Sha Tsui, Hong Kong

We are available Monday to Friday, 9:00 – 18:00 HKT, and will do our best to respond promptly.