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Personal Information Collection Statement ("PICS") – Student
Last Updated: 11 March 2025
This Personal Information Collection Statement (this “Statement”) is made in accordance with the requirements of the Personal Data (Privacy) Ordinance (the “PDPO”) and the Privacy Policy Statement of ARCH Education Group (“ARCH”, “we”, “us” and “our”), which is available on our website https://www.arch-education.com/privacy-policy/. If you are a parent or guardian, this Personal Information Collection Statement “PICS” shall apply to both your own personal data and the personal data of your child provided to us, and in such case the term “your personal data” shall be construed accordingly. This Statement sets out:
1) The purposes for which your personal data (for example, name, address, contact details, photos and other information from which you and/or your child might be identified) may be collected and used by ARCH;
2) To whom the personal data collected may be transferred or disclosed; and
3) How you could access and correct your personal data.
1) Purpose and Collection of Personal Data
Please note that personal data marked with asterisks (*) in this personal information collection form are mandatory. If you do not provide such personal data, we may not be able to process your application or offer our programmes and/or services to you. If a data subject is below 18 years old, we will request their parents or guardian to indicate their consent to the collection, holding, use, processing, and disclosure of their personal data. We may collect, hold, use and process your and/or your child's personal data, for the following purposes:
• providing our services, programmes and products to you;
• processing your application/enrolment;
• responding to your application/enrolment;
• conducting surveys, research and analysis for improvement of our services, programmes and products and our websites;
• performing our administrative, education, academic and research functions;
• assessment of suitability for scholarships, bursaries and other financial awards or grants (if applicable);
• billing purposes;
• (subject to your consent) offering you our services, programmes and products, including sending you marketing and promotional materials relating to our services, programmes and products;
• (subject to your consent) conducting joint promotion events, including sending you marketing and promotional materials in relation to the education programmes, courses, learning materials and children’s related products and services (including but not limited to newsletters, photos, videos, publications, media), information, products, services, events and/or business of CTF Education Group Limited, and their holding companies, subsidiaries and affiliated organisations and entities operating in education, art, culture, hospitality, sports, insurance and social innovation services (“Affiliates”);
• making such disclosures as required by law; and
• any other incidental or associated purposes relating to the above, or any other purpose which you may agree with from time to time.
2) Disclosure and Transfer of Personal Data
ARCH will take all practicable steps to keep the personal data you have provided confidential. However, ARCH may need to disclose, transfer or assign personal data collected to third parties to facilitate the purpose for which the personal data was collected. In general, the parties to which may disclose, transfer or assign personal data include:
a) Third parties (within or outside Hong Kong) engaged by us, including but not limited to any agent, contractor, or third-party service provider who provides administrative, legal, telecommunications, computer, payment, data processing or other services to our school; and
b) Any court, governmental, supervisory or regulatory authority or administrative organisation or entity, whether in or outside Hong Kong.
The personal data may be disclosed, transferred or assigned within or outside Hong Kong. In case it is to a place outside Hong Kong, while ARCH will take appropriate steps to protect the privacy of the personal data, it should be noted that such place may not have in place data protection laws which are substantially similar to, or serve the same purposes as, the PDPO so personal data located outside Hong Kong may not be protected to the same or similar level as in Hong Kong.
Subject to your consent, ARCH may use and include names, school works, school awards, video/audio recordings, transcripts and photographs of you and/or your child taken by the school or provided by you and/or your child for the purposes of publications and promotional activities (including but not limited to ARCH’s brochures, newsletters, website, social media platform, and promotional and marketing materials).
3) Retention of Personal Data
We will retain any personal data collected for the duration required to fulfil the original purpose of collection. Generally speaking, the personal data will be retained for so long as it is necessary for the fulfilment of the purpose for which the data is collected or for a maximum of 7 years, unless we are under any legal obligation to retain the same for a longer period.
4) Yours Rights
Under the Personal Data (Privacy) Ordinance, ARCH may not use or provide to another person for use any personal data in direct marketing unless with your consent. You have a right to request access to, make a copy of, and request us to make correction of any personal data you provided. If you wish to exercise any of these rights, please complete the “Personal Data Access Form” (https://www.pcpd.org.hk/english/publications/files/Dforme.pdf) and/or make the correction request and send it directly us, please find our contact details below. ARCH may charge a reasonable fee for processing your data access request.
5) Contact Us
If you have any questions about this Statement, the data we hold on you, or you would like to exercise your rights as a data subject, please do not hesitate to contact us through the following means:
a. By post, to: ARCH Education Group Limited
3/F, Phase I & II, China Taiping Tower, 8 Sunning Road, Causeway Bay, Hong Kong.
b. Using our website contact form at www.arch-education.com/contact-us;
c. By telephone, on +852 3568 0406 from 10am to 7pm (Except Sundays); or
d. By email, to info@arch-education.com.
If you wish to know more about our privacy policy, please refer to the most updated version posted on our website (https://www.arch-education.com/privacy-policy/). If there is any inconsistency or conflict between the ARCH Privacy Policy Statement and this statement, this statement shall prevail.
UK Addendum
Last Updated: 11 March 2025
This United Kingdom Addendum (this “Addendum”) is made in accordance with the requirements of UK General Data Protection Regulation (the “GDPR”) and the Privacy Policy Statement of ARCH Education, which is available on our website https://www.arch-education.com/privacy-policy/ .
“ARCH”, “we”, “our” and “us” mean any or all of ARCH Education Group Limited and its subsidiaries. “You” and “your” mean any of you and your parents or guardians (if you are a minor), as the case may be. If you are a parent or guardian, this Addendum shall apply to both your own personal data and the personal data of your child provided to us, and in such case the term “your personal data” shall be construed accordingly. This Addendum sets out:
1) The purposes for which your personal data (for example, name, contact details, and other information from which you might be identified) may be collected and used by ARCH;
2) To whom the personal data collected may be transferred or disclosed; and
3) How you could exercise your rights regarding your personal data.
In this Addendum, please note that “UK” refers to the United Kingdom. This version of Addendum shall apply to the following situations:
• Individuals located within the territory in the UK, or;
• Individuals holding an UK passport and/or resident identity card at the time of registering programmes or services with us; or
• Processing of your personal data within the UK.
1) Purpose and Collection of Personal Data
Please note that personal data marked with asterisks (*) in this personal information collection form are mandatory. If you do not provide such personal data, we may not be able to process your application or offer our programmes and/or services to you. According to the relevant laws in UK, if a data subject is below 13 years old, we will request their parents or guardian to indicate their consent to the collection, holding, use, processing, and disclosure of their personal data. We may collect, hold, use and process your personal data, for the following purposes:
• Providing our services, programmes and products to you;
• Processing your application/enrolment;
• Responding to your application/enrolment;
• Conducting surveys, research and analysis for improvement of our services, programmes and products and our websites;
• (Subject to your consent) offering you our services, programmes and products, including sending you marketing and promotional materials relating to our services, programmes and products (Please refer to section 4) Use of personal data in direct marketing in PICS);
• Making such disclosures as required by law; and
• Any other incidental or associated purposes relating to the above, or any other purpose which you may from time to time agree.
Types of Personal Data collected for the above purposes
• Applicant information, including your name, contact information (such as mobile number, email addresses), date of birth;
• Academic information, such as current school, grade and ability;
• Records of correspondence between you and us; and
• Information about your family, personal interests, experiences with our services, programmes or products.
2) Legal Grounds for Processing Your Personal Data
We may collect, hold, use and process your personal data, for the purposes stated in the Addendum. The legal basis for processing your personal data is as follow:
• Necessary for the performance of a contract (e.g. Admissions Agreement);
• Consent of parents/guardians of the student to provide our programmes and services;
• Consent of parents/guardians to the use in direct marketing, where individuals always have the right to withdraw consent;
• Our legitimate interest in attracting, identifying and evaluating students;
• Our legitimate interest to communicate with you and respond to any enquiries;
• Our legitimate interest to provide better service to our parents and students, including providing better learning experience; and
• Compliance with legal obligations or regulatory obligations.
3) Disclosure and Transfer of Personal Data
We may disclose and/or transfer your personal data to third parties to fulfil the purpose of collection, including without limitation to:
a. Third parties (within or outside Hong Kong) engaged by us, including but not limited to any agent, contractor, or third-party service provider who provides administrative, legal, telecommunications, computer, payment, data processing or other services to ARCH; and
b. Any competent court of law, law enforcement agencies and/or regulators and government departments for compliance with applicable laws and regulations and protection of our legal rights.
Subject to your consent, ARCH may use and include names, student works, student awards, video/audio recordings and photographs of you and/or your child taken by ARCH or provided by you for the purposes of publications and promotional activities and direct marketing (including but not limited to ARCH’s brochures, newsletters, website, social media platform and, promotional and marketing materials).
4) Transfer of Personal Data to a Third Country or International Organization
In order to achieve the purposes stated in this Addendum, we may disclose, transfer or assign your personal data outside the UK. In case it is to a place outside the UK, while ARCH will take appropriate steps to protect the privacy of the personal data, it should be noted that such place may not have in place data protection laws which are substantially similar to, or serve the same purposes as, the UK GDPR so personal data located outside the UK may not be protected to the same or similar level as in the UK.
5) Minors
ARCH classes, lessons, programmes and courses are mainly children and minors oriented. A child or a minor shall not register to the programmes or services without consent of his/her parents or guardians. The personal data of children that is collected with their parents or guardians’ consent will only be used or publicly disclosed when it is permitted by laws, explicit consent is obtained, or is essential to protect the children.
Although the definition of child or minor varies in local laws and regulations, in general, it is noted that individual below 13 years old is regarded as a child under the provision of the UK GDPR. If we find that a child’s personal data has been collected without his/her parents or guardians’ prior consent, we will stop processing and remove relevant data as soon as practicable.
6) Retention of Personal Data
ARCH will retain your personal data only for so long as is necessary for the fulfilment of the purpose for which the data is or is to be used, and generally for a maximum period of 7 years. Once this period has expired, we will delete or erase from our systems your personal data which are no longer required, unless we are under any legal obligation to retain the same for a longer period.
7) Yours Rights
In accordance with relevant laws, regulations and standards in the UK, we will ensure that you can exercise the following data subject rights entitled:
Right to access
• You are entitled to ascertain whether or not personal data concerning you and/or your child are being processed, and access to the personal data and other related information, from us;
• You are entitled to obtain a copy of the personal data relating to you and/or your child held by us.
Right to correction and rectification
• You are entitled to request any correction of any inaccuracies contained in such data, pertaining to you and/or your child.
Right to object/withdraw
• You are entitled to withdraw any previously provided consents to the collection and the use of the personal data, prevent further processing of the personal data;
• You are entitled to object to the processing of personal data concerning you and/or your child, where processing is justified on the basis of legitimate interests, including profiling.
Right to be forgotten
• You are entitled to remove any personal data concerning you and/or your child collected by us.
Right to data portability
• You are entitled to have your personal data transmitted from one data user to another, where technically feasible.
Right to restriction of processing
• You are entitled to restrict the processing of your personal data.
Right to object to automated decision making
• You shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you and/or your child or similarly significantly affects you and/or your child;
• You shall have the right to obtain human intervention to express your point of view and to contest the decision.
If you wish to exercise any of the above-mentioned rights, please find our contact details at section 8) Contact Us. All such requests will be handled as soon as practicable in accordance with the requirements of the applicable laws and regulations in relation to personal data protection, and we will respond to you within one month. ARCH may charge a reasonable fee for processing your data subject request.
8) Contact Us
If you have any questions about this Addendum, how we process your personal data, exercise your data subject rights entitled, or are not satisfied with our handling of a request you have made in relation to your rights, please do not hesitate to contact us through the following means:
a. By post, to: ARCH Education Group Limited
3/F, Phase I & II, China Taiping Tower, 8 Sunning Road, Causeway Bay, Hong Kong.
b. Using our website contact form at www.arch-education.com/contact-us ;
c. By telephone, on +852 3568 0406 from 10am to 7pm (Except Sundays); or
d. By email, to info@arch-education.com.
You can also make a referral to or lodge a complaint with the Information Commissioner’s Office (ICO), although the ICO recommends that steps are taken to resolve the matter with us before involving them. You can also find out more about your rights under data protection law from the ICO website available at: www.ico.org.uk. If there is any inconsistency or conflict between ARCH Personal Information Collection Statement, ARCH Privacy Policy Statement and this Addendum, this Addendum shall prevail.