Whizpa Limited (“Whizpa”, “we”, “our”, “us”) is the owner and operator of the online service platform whizpa.com (the “Website”) that assists adult users over the age of eighteen (18) (“User”, “you”) and education service providers, schools, charities, activities providers and any and all other service providers in the childcare service industry (“Service Provider(s)”) in respect of gathering information of Service Providers, posting opinions of related issues, and engaging in interactive forums of the Service Providers (collectively, the “Services”). The Website also provides a forum to the Service Providers to post promotional material and advertisements pertaining to their respective institutes and organizations to promote and sell classes, courses, educational packages to Users (“Class Packages”) and for Users to post comments and/or reviews regarding the Service Providers.
Any and all collection of Users’ personal information by Whizpa under this Policy is strictly in compliance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486). If you do not agree to the terms of this Policy, you must immediately cease using the Website or our Services.
This Policy was last updated on 6 Jun 2017. We may amend this Policy from time to time so please review this Policy regularly to keep informed of any updates.
2. Purpose of Collection of Information
To have the benefit of and access to the features offered by the Website or our Services, it may be necessary for Users and Service Providers to provide Whizpa with their personal and/or business related information. It is the Users’ and Service Providers’ voluntary decision as to whether or not to provide the information as requested on the Website. However, if Users or Services Providers do not provide such information and/or data, Whizpa may not be able to provide certain Services, and such Users’ and Service Providers’ use of the Website would be limited as a result. Whizpa uses the information we collect from Users for the following purposes, including, but without limitation to:-
a. for the daily operation of the Services provided to Users;
b. to identify Users and/or Service Providers who have posted advertisements, materials, messages, photos, reviews, comments and/or any other relevant information (collectively “Submission”) on the Website;
c. to identify Users who have viewed such Submission;
d. to handle and follow up service calls, enquiries, requests and complaints;
e. to provide Users with event information, marketing and promotional materials;
f. to allow Users and/or Service Providers to register as members of the Website;
g. to contact Users and/or Service Providers regarding administrative notices and communications relevant to the membership accounts maintained with Whizpa (if any) and/or the Services offered by Whizpa;
h. to design and provide customized Services to Users and/or Service Providers; and
i. to compile and analyze aggregate statistics in respect of the use of the Website and for Whizpa’s internal use.
j. to manage Users’ account, including to allow the access to and use of Whizpa;
k. to communicate with Users in general, including to provide information about Whizpa and invitations from the Whizpa community;
l. to enable us to publish Users’ reviews, forum posts, and other content to the Whizpa community;
m. to respond to Users’ questions and comments;
n. to measure interest in and improve our products, services, and Website;
o. to notify Users about special offers and products or services available from us or our partners that may be of interest to Users;
p. to otherwise customize Users’ experience with Whizpa, including customizing the ads shown;
q. to resolve disputes or troubleshoot problems;
r. to prevent potentially prohibited or illegal activities;
t. as otherwise described to you at the point of collection.
Whizpa strives to only collect personal data which is necessary and adequate but not excessive in relation to the purposes set out hereinabove.
If Whizpa requires the use of your personal data for a purpose other than those set out above, Whizpa shall request the Users’ consent to the same. Minors are not eligible to use our Website unless they are at least eighteen (18) years of age and otherwise have the legal capacity to enter into a binding contract. Any action conducted by a minor on a User’s account would deem such User liable.
Whizpa may retain certain information associated with Users’ account in our archives for analytical purposes and for recordkeeping integrity. The periods for which we retain Users’ information shall depend on the purpose for which Whizpa collects and uses the same.
Whizpa will not retain Users’ personal information for longer than is necessary for our business purposes or for legal requirements. Whizpa may, however, retain certain information for a period of time after Users have terminated their accounts with us, for reasons such as when the retainment of such information is necessary for Whizpa to meet legal obligations or to exercise, defend or establish legal rights.
Whizpa wants Users to feel confident about using Whizpa, and we are committed to protecting the information we collect. While no website can guarantee security, we have implemented and maintain appropriate physical, administrative, technical, and organisational measures to protect the personal information Users provide us against unauthorized or unlawful access, use of disclosure, and against accidental loss, damage, alteration or destruction. For example, only authorized employees are permitted to access personal information, and they only may do so for permitted business functions. In addition, we use encryption when transmitting Users’ personal information between Users’ system and ours, and between our system and those of the parties with whom we share sensitive information, and we employ firewalls and intrusion detection systems to help prevent unauthorized persons from gaining access to Users’ information. We endeavor to ensure that Users’ personal information is relevant to its intended use, accurate, and complete.
3. Collection of Personal Data
3.1 Personal Information
When User uses our Services or Website, we receive and store any information Users enter on our Website or give us in any other way. This includes information that can be used to identify Users as an individual or to contact Users directly or any other affiliated information pertaining to any minor ("personal information").
Personal information includes information Users provide us such as first and last name, telephone number, postal and email addresses, user name and password, and billing information (such as credit card number, cardholder name, and card expiration date).
Users can choose not to provide this personal information to us, but in general some information is required in order to receive relevant offerings from Whizpa and its partners and enjoy other benefits of having a Whizpa account such as posting reviews, participating in discussion forums, emailing Whizpa content to themselves and others, accessing members-only newsletters.
Other information we may choose to collect may also include details such as Users’ IP address, information identifying Users’ device, and website browsing history to the extent that information is about Users. User will further be required to sign up for a membership account of our Website in event that the User wishes to purchase Class Packages offered by Service Providers on our Website. In order to complete the sign up process and to facilitate payment, we will request Users to provide additional information including without limitation to first and last name, age, gender, date of birth, nationality, education level, work experience, payment details, and any other information.
Users may also be asked to provide contact information in order to fully access our Service. We may send services and administrative emails to Users, or contact Users by SMS, MSS, text message or other electronic means to inform Users about changes to our Services. We may also from time to time send to our Users newsletters, marketing and promotional materials and information regarding Whizpa or its third-party advertiser’s products and services.
Whizpa may also collect information through Users’ use of our Service such as transaction details, of which shall include the date and time of the transaction, amount charged, and/or other relevant transaction details.
We may automatically collect some information from Users’ computer or Device when Users visit Whizpa. For example, we will collect session data, including your IP address, Web browser software, and referring website. We also may collect information about your online activity, such as content viewed, pages visited, and searches and/or reservations facilitated or made. One of our goals in collecting this automatic information is to help us understand the interests and preferences of our Users and customize Users’ experience.
3.2 Business Information
Service Providers are required to sign up on our Website for an account in order to claim a listing, set up a profile for the organization or institute, reply to requests and reviews of Users, and promote and sell Class Packages to Users.
By signing up with our Website, Service Providers will be required to provide information in respect of their organizations or institutes including but not limited to name, address of business, year of incorporation, copy of business registration certificate, the corporate structure of the organization or institute, and any awards and/or qualifications Service Providers may be requested to provide.
3.3 Information Collected by Business Partners and Ad Networks
Many of the advertisements Users see on Whizpa are served by Whizpa or its service providers. But we also allow third parties to collect information about Users’ online activities through cookies and other technologies. These third parties include (1) business partners, who collect information when Users view or interact with one of their advertisements on our sites, and (2) advertising networks, who collect information about Users’ interests when Users view or interact with one of the advertisements they place on many different websites. The information gathered by these third parties is used to make predictions about Users’ characteristics, interests or preferences and to display advertisements on our sites and across the Internet tailored to Users’ interests.
3.4 Other Information
Users and Service Providers are entitled to provide and/or post education or related information through our Website. Users and Service Providers shall obtain the consent from the owner of such information prior to posting the same. Whizpa is not responsible for any third party claims arising from any infringement of any patent, trademark, trade secret, copyright or other intellectual or proprietary right of any party in respect of information posted by the Users and/or Service Providers.
4. Disclosure or Transfer of Data
At all times, the sharing of any information by Whizpa collected shall be done in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) and may be transferred as set out herein:-
the information and/or data is disclosed and/or transferred to any Service Providers who have been duly authorized by Whizpa to use such information and/or data and who will facilitate the Services on the Website, including without limitation the organizations or institutes which have subscribed to Whizpa’s website, who are under a duty of confidentiality;
we may engage third party service providers to work with us in order to administer and provide our Services. These third party service providers will have access to your information only for the purpose of performing services on our behalf and are expressly obligated to secure and not to disclose or use your information for any other purpose;
information that we collect from our Users and/or Service Providers is considered to be a business asset. In the event we are acquired by a third party as a result of a merger, acquisition, or asset sale or if our assets are acquired by a third party in the event we go out of business or enter bankruptcy, your information may be disclosed or transferred to a third party acquirer in connection with the transaction. In the event of such a transaction, we will give you notice of the transaction and the opportunity for a period of 30 days to refuse disclosure or transfer of your information to the third party acquirer in connection with the transaction;
we may share aggregated information and non-identifying information with third parties for research and analysis, and demographic profiling purposes; and
we cooperate with government and law enforcement officials or private parties to enforce and comply with the law. In the event that we, in our sole discretion, believe that it is necessary or appropriate to disclose your information in respond to claims, legal process and/or to protect the property, rights, and safety of Whizpa, a third party, or the public in general. We may also disclose your information in order to identify and stop any activity that we consider illegal, unethical, or legally actionable activity.
Personal information collected via the Website may be transferred, stored and processed in any country in which Whizpa operates. By using the Website, Users and Service Providers are deemed to have agreed to, consented to and authorized Whizpa to disclose and/or transfer their information under the circumstances stated above, as well as to any transfer of information (including any Submissions) outside of the User’ country.
Whizpa may cooperate with social sharing services which will allow Users to share actions Users take on our Services with other applications, sites, or media. Such features enable the sharing of Users’ information with Users’ friends or the public, depending on the settings Users establish with the social sharing services. Please refer to the privacy policies of those social sharing services for more information in respect of how they handle the information provided to or shared through them.
5. Access to or Request for Amendment of Data
Whizpa may also share Users’ information if we believe, in our sole discretion, that such disclosure is necessary
to comply with legitimate and enforceable subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;
in connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Should you wish to delete or modify your information or discontinue the provision of your information to third parties, please contact us at Contact Us with your request. We shall take steps to modify or delete your information in a reasonable time frame (unless otherwise permitted by applicable law). Please note, however, that some information may remain in archived/backup copies for our records or as otherwise required by law. Whizpa will comply with the User’s and/or Service Provider’s requests regarding access, correction, and/or deletion of the information stored on the Services in accordance with Hong Kong law.
Whizpa will take practical steps to safeguard the Users’ and the Service Providers’ information from unauthorized or accidental access, processing, erasure, loss or use. Users and Service Providers are also advised to keep their Whizpa account details secure at all times.
6. Cookies and Log Files
Whizpa does not collect any personally identifiable information from any Users whilst they visit and browse the Website, save and except where such information of the Users is expressly requested. The Website only records the Users’ visits, domain names, server address and tracks the pages the Users visit. Such information shall be stored as “cookies”. A cookie is small text file that our Website transfers to your computer or device’s hard disk. Whizpa uses these cookies to better serve, accommodate you and/or maintain your information across multiple pages, across one or more sessions. Cookies are used to gather and store information like IP addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. The processes will occur without affecting the Users’ utilization of the Website.
Whizpa and any third-party vendors engaged by Whizpa use Whizpa’s cookies and third-party cookies, such as the Google Analytics cookies, together to inform, optimize, and serve marketing materials based on the Users’ past visits to the Website. Whizpa does not link the information and data automatically collected in the above manner to any personally identifiable information. Whizpa generally uses such automatically collected information and data to estimate the audience size of the Website, estimate the popularity of various parts of the Website, track Users’ movements and the number of entries on the Website, measure Users’ traffic patterns and administer the Website.
7. Links to Other Websites / Media Platforms / Application
Our Website may provide links to other websites/media platforms/applications (collectively, the “Third Party Sites”) which are not owned or controlled by Whizpa. Personal information and data from Users may be collected on these Third Party Sites when Users visit and make use of the services provided therein.
Non-registered Users who gain access to our Website via other Third Party Sites or their online social networking accounts (including but not limited to Facebook) are deemed to have consented to the terms of this Policy, and such Users’ personal data which they have provided to those networking accounts may be obtained by Whizpa and be used by Whizpa and its authorized persons in and outside of the User’s country. The purpose of this is to provide services and marketing materials to the Users. These Users are deemed to have consented to Whizpa and its authorized personnel’s access and use of their personal data so obtained, subject to the other provisions of the Policy.
8. Promotional Communications
You may opt out of receiving promotional messages from us by contacting us at Contact Us. Notwithstanding, we may still send you non-promotional messages, such as those about your appointments, or our ongoing business relations.
The security of Users’ personal information is important to Whizpa. Whizpa will strive to ensure that any and all personal information will be protected against unauthorized access. Whizpa has implemented the appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information.
All personal information and data provided by our Users are only accessible by the authorized personnel of Whizpa or its authorized third parties, and such personnel shall be instructed to observe the terms of this Policy when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfill the purpose for which it is collected, unless Users request Whizpa to cease to hold the same or terminate his/her membership account with Whizpa. Such requests may render Whizpa unable to further provide its services, information and/or promotional materials for your benefit in the future.
Whizpa follows generally accepted industry standards to protect the personal information and data submitted by Users to the Website, both during transmission and once Whizpa receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while Whizpa strives to protect Users’ personal information and data against unauthorized access, Whizpa cannot guarantee its absolute security.
10. Contact Us
Please contact us at Contact Us if you have any questions about our Policy, or if you wish to make a complaint about our collection, use, or disclosure of your information under this Policy. We will use our reasonable endeavors to address any complaint you may have as soon as possible.