Privacy Policy Statement & Personal Information Collection Statement

1. Privacy Policy

1.1 This Platform www.masterin.co and any other websites or mobile applications as operated and managed by MasterIn from time to time (“ this Platform”) are owned and operated by Snapask (Holdings) Inc. (“ the Company”, “ we” or “ us”). We respect personal data and are committed to full implementation and compliance with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance, Cap. 486 (“ the Ordinance”) of Hong Kong as well as the relevant and applicable laws in your country.

1.2 This Privacy Policy is applicable to all Users of this Platform, including but not limited to all Learners and all Coaches, as well as any other persons that their personal data is collected, by whatever means, used and held by us.

1.3 By accessing and/or browsing and/or using and/or logging in and/or signing up and/or requesting any services and/or receiving and experiencing any services and/or dealing in any manners in this Platform, you acknowledge that you have read, understood and accepted this Privacy Policy. Should you be under the age of 18, please obtain prior acceptance from your parents or guardians in respect of this Privacy Policy.

2. Kinds of Personal Data Collected, Used and Held

2.1 Only the following personal information and data will be mandatorily collected, used and held by us when signing up in this Platform and using the services provided by MasterIn, and no data or information other than the following will be collected by us:

  1. Your name, gender, date of birth, correspondence address, postal code (if applicable), country;
  2. Email address;
  3. Phone number;
  4. Name of Companies you engage(d) in, work title and working experience (if applicable);
  5. Facebook account and data provided by Facebook, including but not limited to first name, last name, gender, birthday and company name (if the User signs up through his Facebook Account); and
  6. Google account and data provided by Google, including but not limited to first name, last name, gender, birthday and company name (if the User signs up through his Google account)

2.2 The User hereby acknowledges and agrees that his name, user name, work title, work experience, company and/or profile picture may be published to the Platform and be viewable by the other Users .

2.3 You may provide us with your personal data at your own will. The above personal data and information are regarding as mandatory. We may refuse your account registration and you will then be unable to have access to the services provided by MasterIn.

2.4 Other than the above, provision of any other or further data and information is optional, and does not affect your registration or access the services.

3. Purpose of Personal Data to be Collected

3.1 The personal data and information collected from you will be used by the Company for the following purpose: -

  1. Signing Up, Registration and Identification:

    1. To sign in and register a user account on this Platform of MasterIn;
    2. To verify and ascertain your identity; and
    3. To conduct introduction of Coaches.
  2. Payment: To facilitate and process payment from you in respect of your subscription of membership plan(sand other service(s) (if applicable);
  3. Providing Services: To provide services to you on this Platform of MasterIn, and to permit you to participate in other activities on this Platform of MasterIn, including but not limited to contest, promotions, campaigns, polls and surveys;

  4. For administration, management and technical support

    1. For our internal administration and management, including auditing and internal analysis;
    2. To communicate with you, provide applicable technical support, receive your comments and handle your complaints; and
    3. To detect, investigate and prevent any fraudulent, prohibited and illegal activities, any misuse of this Platform or use of this Platform with improper or dishonest motive, and if necessary, to provide or respond to the requests or directions of the courts, enforcement agencies or similar authorities and statutory bodies of your country or elsewhere.
  5. Statistics: to carry out statistics and data analysis to improve and enhance our services and develop our marketing strategies; and
  6. Profiling: To build up your user profile.

4. Transfer of Personal Data within the Group

4.1 For the sake of facilitating us to provide services to you as well as the above purposes, only after obtaining your consent when signing up , may your information and data collected and obtained by Snapask (Holdings) Inc. be used by, shared to and retained by all its subsidiaries, related and/or associated companies(“Group”), which may be situate outside your country. We undertake that all the above subsidiaries, related and/or associated companies will be in strict compliance of this policy and the applicable laws in their countries.

5. Transfer of Personal Data to Third-Parties

5.1 We will not transfer your personal information or data to other Users or any third parties without obtaining your prior consent.

5.2 We may also transfer non-personally identifiable, aggregated, statistical and/or anonymous basis to third-party academic institutions, inside and outside your country, for strictly academic, teaching and educational purposes , with or without consideration. Use of the data and information for any otherwise purposes is strictly prohibited.

5.3 You have the right to opt out and elect to cease sharing your information and data at any time by informing us of your request by way of email to contact@masterin.co. We shall effect the cessation of the provision or sharing within 3 days upon receiving your email.

6. Direct Marketing and Promotion

6.1 Only after obtaining your consent, may we send you by way of email and contact you from time to time to share promotional or marketing information. Promotional and marketing subjects include but not limited to information regarding promotions and discounts on subscriptions/packages or any new feature introductions.

6.2 Once you have elected to receive marketing and promotional emails, you have the right at any time to elect not to accept by clicking on the “Unsubscribe” link embedded in our marketing and promotional emails received. This does not prejudice you from receiving our other non-marketing and promotional emails to you.

7. Third-Party Marketing and Promotion

7.1 We will not provide or share your information and data to any third parties for marketing or and/or promotional of their own goods and services and/or any other purposes without your prior consent in writing.

8. Retention of Data and Information

8.1 We will retain all your personal data and information so long as is necessary for the fulfilment of (i) the purposes for which they were collected and (ii) of the legal requirements. All your personal data and the transaction records will be destroyed thereafter.

8.2 You hereby acknowledge that your information and data are stored and maintained in our electronic database, facilities, servers and back-up servers which may be located outside your country, where the legal protection and standard of security requirements may not be equivalent to the same provided by and legally required by the applicable laws and regulations of your country.

8.3 At any time, if you desire to erase any of your information or data from our electronic databases, facilities, servers and/or back-up servers, please contact us.

9. Accuracy and Change of Personal Data

9.1 In order to ensure the correctness and accuracy of your personal information and data, particularly your contact details retained by us, you may receive from time to time our request of confirmation, verification and/or update of your information and data.

9.2 You can also from time to time request us to correct and/or change your personal information and data held by us.

10. Handling and Security Measures

10.1 The personal data and information we collect about you will not be disclosed to any other party without your prior approval.

10.2 We have established in place security measures and monitoring procedures to prevent unauthorized or accidental access, processing, erasure, loss or use of the data. All personnel that may access the data will be ensured complying with the requirements of data protection.

10.3 Our security measures are listed below:

  1. Controls on password complexity, re-tries or resets are implemented to prevent passwords from being compromised;
  2. Advanced encryption technology is used to protect the safety of personal data (including names, email addresses, telephone numbers, credit card information and purchase records) during transmission. Our SecureSocketLayer (SSL) system will prevent your data being transmitted from unauthorized interception or access by third parties;
  3. Only the personnel that have been trained with the strict privacy guidelines and procedures are authorized to access or handle your personal data. Such personnel are accountable for non-compliance with the related obligations; and
  4. The security system and procedures are reviewed regularly.

11. Third-Party Websites

11.1 After clicking on any advertisements or any hyperlinks on this Platform, you may have left this Platform and be diverted to websites of our advertising clients, content providers, suppliers, business partners or otherwise. You acknowledge that your visit to these third-party websites is not protected by this Privacy Policy.

11.2 We have not authorized these third-party websites to collect any information or data from you. You acknowledge we are not responsible for any exposure of your data at these websites or losses arising from a third-party website’s practice or policy.

11.3 For avoidance of doubt, we do not endorse the contents, the privacy policies or their security measures in respect of personal information and data collected by any third-party websites.

12. Cookies

12.1 We may use “Cookies” to improve this Platform and enhance your online experience. Cookie refers to an alphanumeric identifier stored on your hard drive of your device to facilitate us to track your activities in this Platform. Cookies may be used to remember you and your preferences when you visit the Website and enable us to tailor this Platform to your needs. The information collected by Cookies is anonymous visitor’s personalized settings information and contains no name or address information or any information that will enable anyone to contact you via telephone, email or any other means.

12.2 For avoidance of doubt, we will not collect any personal data from you when the cookies are being used. You can disable cookies by changing the settings of your web browser. Cookies cannot be used to run programs or deliver viruses to your computer.

12.3 You acknowledge that we collect, hold, store the following information and data through the cookies when you browse and access to this Platform:

  1. Kind and nature of services and activities you engage in;
  2. Your type of subscription of membership plan (as a Platform);
  3. Frequency and time of engagement of the services of MasterIn;
  4. Your browsing history of this Platform;
  5. Logs of interaction between you and other users on this Platform;
  6. Logs of interaction with any of our staff, agents or representative on this Platform;
  7. Logs of interaction with any visual, third-party applications, advertising products and services which are offered, linked to, or made available on this Platform;
  8. Contents, details and particulars of your queries and/or requests and/or answers made on this Platform;
  9. Images, documents, photos and voice records submitted by you to this Platform;
  10. The model number, registration number and/or other information and particulars in respect of your device you use when having access to this Platform; and
  11. Telecommunication and digital network information and data including IP address of your device, URL information, the particulars and details of your device, the browsers, third-party applications and network you use in assessing this Platform.

13. Limitation of Liability

13.1 We undertake to implement all reasonably practicable procedures, measures and steps to safeguard the security of all your information and data.

13.2 We do not accept responsibility for any unauthorized or unlawful access, alternation, use, destruction, loss, erasure, transmission, disclosure or leakage of any of your information and data, irrespective of whether the same occur in our electronic database, facilities, servers or back-up servers located in your country or elsewhere.

14. Changes in this Privacy Policy

14.1 We may update or amend this Privacy Policy in the future, if necessary. The revised Policy will be posted on this Platform with an effective date and by our email to you.

15. Access to Personal Data

15.1 You have the right to request for access to and copy of, and correction and updating of your information and data held by us. Your request should be made by way of email to contact@masterin.co. Your request will be proceeded within 14 days. Administrative fees will be charged.

16. Contact Us

16.1 Should you have any requests (including opt-out), enquiries or comments to this Privacy Policy, please email us at contact@masterin.co, telephone us at +852 3706 5070 or write to our office at 13/F, Fontaine Building, 18 Mody Road, TST, HK. In general circumstances, your requests or enquiries will be handled within 14 working days after our receipt of the same and our verification of your identity.

17. English Version to Prevail

17.1 In the event of any inconsistencies or discrepancies between the English version and any other translated versions of this Privacy Policy, the English version shall prevail.

18. Governing Law

18.1 This Statement is governed by and shall be construed in all respects in accordance with the laws of the Hong Kong and all the parties hereto hereby submit to the exclusive jurisdiction of the Hong Kong courts in connection with any matters arising hereunder.

19. Effective Date

19.1 This Privacy Policy becomes effective from: 2021/FEB/26

Consent (for Direct Marketing)

Your name, address, email address and mobile number collected by us will be used for providing you with information in relation to the promotion and direct marketing of our products and/or services. We cannot use your personal data unless we have received your consent or indication of no objection.

If you do not wish to receive information on the above, please tick the box below:-= I object to the proposed use of my personal data as stated above.