Privacy Policy

Personal Information Collection Statement

“Mindgym”, “we”, “our”, or “us” means Mindgym Limited (Company No. 2763346), a company registered and incorporated under the laws of Hong Kong and whose registered office is at Room 302, 3/F, Winsome House, 71-73 Wyndham Street, Central, Hong Kong.

We recognise our responsibilities in relation to the collection, holding, processing, use and/or transfer of personal information under the Personal information (Privacy) Ordinance (Cap. 486 of the laws of Hong Kong) (the “PDPO”). We will use your personal information which we may collect from you from time to time in accordance with this privacy policy. Nothing in this privacy policy shall limit your rights under the PDPO.

The Data We Collect About You

From time to time we may collect your personal information, including when you apply for, enquire about, receive products and services from us, give us feedback or contact us, or when you apply to amend your application and/or services.

The data we collect may include, but are not limited to your name, mailing address, email address, telephone number, date of birth, identity card number (and copy of identity card) and academic background (“personal information”, “data”, or “information”). It is entirely voluntary for you to provide your personal information. However, failure to provide your personal information when requested may result in Mindgym being unable to process your request fully or at all.


By providing your personal information to us through our website or otherwise, you are permitting the Mindgym Group to store, maintain, process and use this information in accordance with this privacy policy, as amended from time to time, for various purposes, including but not limited to:

• processing your application, subscription and registration for our products and services;
• providing you with our products and services;
• sending you information regarding Mindgym products and services;
• responding to your service requests;
• responding to your enquiries;
• billing purposes;
• notifying you about Mindgym products, services, events and promotions;
• conducting research and statistical analysis;
• processing your application for employment or engagement within Mindgym to assess your suitability as a candidate for such position and to conduct reference checks with your previous employers; and
• other purposes relating to any of the above.

Direct Marketing

Where you have given your consent and have not subsequently opted out, we may also use your name, mailing address, email address and telephone number to send promotional materials to you and conduct direct marketing activities in relation to Mindgym’s products and services.

If you do not wish to receive any promotional and direct marketing materials from us or do not wish to receive particular types of promotional and direct marketing materials or do not wish to receive such materials through any particular means of communication, please contact us through one of the communication channels set out in the “Contact Us” section below. To ensure that your request can be processed quickly, please provide us with your full name and email address of the product and/or service you have subscribed to.

Other Transfers of Personal Information

For any of the purposes as indicated in this privacy policy, we may disclose your personal information to third parties (within or outside Hong Kong), including without limitation third party service providers (including any agent, contractor, or third party service provider who provides administrative, legal, telecommunications, computer, payment, debt collection, data processing or other services to Mindgym), regulators, government departments and agencies and law enforcement agencies.

Access and Correction of Personal Information

You are entitled to request access to your personal information or correction of your personal information at any time by addressing such requests in writing and sent to us by post (see the “Contact Us” section below). It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.

A reasonable fee may be charged to offset our administrative and actual costs incurred in complying with your data access requests.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Changes to the Privacy Policy

We keep our privacy policy under regular review and may from time to time revise it or add specific policies and terms. Where any changes to this privacy policy are material, we will notify you using the contact details you have provided us with and provide you with the opportunity to opt out of these changes by means notified to you at that time.

In relation to personal information supplied to us through our website or otherwise, continued use by you of the Mindgym website or your continued relationship with us shall be deemed to be your acceptance of and consent to this privacy policy, as amended from time to time.

Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact our administrative department in the following ways:

• Email address:
• Postal address: Room 302, 3/F, Winsome House, 71-73 Wyndham Street, Central, Hong Kong

Last updated: January 2019