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Privacy Policy

Privacy Policy

This Privacy Policy explains how Fluent Pathways handles personal data in connection with its website and small-group language courses in Hong Kong.

Terms of Service Contact
Data collected only as described in this policy
Your rights and options are detailed below
Questions handled via our contact channel
Privacy Office

Contact Details

Email contact
[email protected]
Telephone
+852 5104 5514
Postal address
70, Tai Ho Road, Tsuen Wan, Tsuen Wan, Hong Kong
Privacy contact
[email protected]

Use the contact details below for privacy questions, access requests, or other data-related enquiries.

Contact Page
Data category

Data We Collect

We may collect identification and contact details, course enquiry information, level screening responses, timetable preferences, enrolment records, attendance and progress information, payment-related records, and communications sent to us. Where needed for course administration, we may also process learning-plan details, materials lists, and other information provided during scheduled lessons or progress reviews.

The data we collect depends on the enquiry, enrolment, and course support steps used.
Collection source

How We Collect Data

We receive data when you submit a contact form, communicate by phone or email, visit the centre, complete screening or enrolment steps, make a payment, or take part in lessons and course reviews. We may also generate internal records from booking, attendance, and administrative activity connected with your course.

Most information comes directly from the learner or from routine service interactions.
Cookie type

Cookie Types

Our website may use essential cookies to support core functions, preference cookies to remember basic settings, and analytics cookies to understand site use in aggregate. Cookies may be session-based or persistent, depending on their purpose. We do not use cookies to collect more information than is reasonably needed for the operation of the site.

We use only the cookie categories needed for site operation and basic measurement.
User control

Cookie Controls

You may manage cookies through your browser or device settings, including blocking or deleting them. Some site functions may not work properly if certain cookies are disabled. Where required, we may also present a cookie choice tool or similar notice for non-essential cookies.

Browser settings can usually limit or remove non-essential cookies.
Why we process data

Purposes of Use

We process personal data to respond to enquiries, assess course suitability, arrange level screening, match learners to groups and timetables, confirm course terms, manage enrolment, deliver scheduled lessons, support guided practice, review progress, handle payments and records, maintain website security, and meet legal or accounting obligations. We may also use limited data to improve administrative processes and keep our communications accurate and relevant to the service.

Note
We use personal data only for purposes connected with the website, enrolment, and course administration.
Third-party sharing

Service Providers and Operational Sharing

We may share personal data with service providers that assist with website hosting, communications, booking administration, payment processing, record storage, or similar operational support. We may also disclose limited information to instructors or staff involved in course delivery, timetable matching, and progress review. These parties may use the data only for the services they provide to us.

Note
Operational recipients are used only to support the service and are expected to handle data appropriately.
Sharing legal basis

Legal Disclosure

We may share personal data where required to comply with law, court orders, regulatory requests, or other binding legal processes. We may also disclose information where necessary to establish, exercise, or defend legal claims, or to protect the rights, safety, or property of Fluent Pathways, our learners, or others.

Note
Disclosure to public authorities is limited to lawful requests or mandatory obligations.

Subject to legal limits, you may request access to your personal data, ask for correction of inaccurate information, or object to certain processing where permitted. You may also ask about the basis on which we hold or use your data and request deletion where retention is no longer justified.

Available rights may vary depending on the nature of the data and applicable law.

Please describe your request clearly and provide enough information for us to locate the relevant record. We will review the request, confirm whether any legal exception applies, and respond within a reasonable period under applicable law.

We may need to verify identity before acting on a request.

Retention periods depend on the type of record and the reason it was collected. Course and enquiry records are kept for the period needed to manage the service, resolve questions, maintain business records, and meet legal or accounting obligations. When data is no longer required, we delete it or anonymise it where practicable.

We keep data only for as long as needed for the stated purpose or for legal recordkeeping.

The revised version will apply from the date it is posted on our website unless a different effective date is stated. If a change is material, we may also provide a separate notice through a reasonable communication channel.

We review this notice from time to time and update it when our practices or legal obligations change.