Privacy Policy

Last Updated: October 6, 2025

Introduction

Fleur de Lys Academy Limited ("we", "us", or "our") is committed to protecting the privacy and security of your personal data. This Privacy Policy Statement explains how we collect, use, disclose, and protect personal data in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") of the Hong Kong Special Administrative Region ("Hong Kong").

This policy applies to personal data collected through our website fdlys.com (the "Website"), as well as through other means such as enrollment forms or communications related to our tutoring and educational services. By using our Website or providing personal data to us, you consent to the practices described in this policy.

For the purposes of the PDPO, Fleur de Lys Academy Limited is the data user responsible for the personal data we hold.

Personal Data We Collect

We may collect the following types of personal data (as defined under the PDPO) when you interact with us:

Contact Information: Name, email address, telephone number provided when you contact us, register for tutoring services, or subscribe to newsletters.

Student Information: Details such as student names, ages, or academic records provided during enrollment or course registration.

Payment Information: Credit card details or other payment data if you make payments for our services (handled securely by third-party processors).

Usage Data: Automatically collected information such as your IP address, browser type, device information, pages visited, and time spent on the Website.

Other Data: Any additional information you voluntarily provide, such as feedback, inquiries, or preferences related to our tutoring services.

We collect personal data only for lawful purposes and by lawful means, in line with Data Protection Principle 1 (DPP1) of the PDPO.

Purposes of Collection and Use

Personal data is collected and used for the following main purposes:

To provide and manage our tutoring and educational services, including processing enrollments, scheduling classes, and communicating with parents or students.

To respond to inquiries, provide customer support, or send updates and newsletters (with your consent).

To improve our Website and services through analysis of usage data.

To comply with legal obligations, such as record-keeping or reporting requirements.

For any other purposes directly related to the above or as notified to you at the time of collection.

We will not use your personal data for any new purpose without your consent, in accordance with DPP3 of the PDPO.

Disclosure of Personal Data

We do not sell, trade, or rent personal data to third parties. Disclosure may occur only in the following circumstances:

To our service providers (e.g., hosting, email, payment processors, or analytics providers) who are contractually bound to protect the data and use it only for the services they provide.

Where required by law, court order, or government authority in Hong Kong.

In connection with a business transfer, such as a merger or acquisition (with notice to you).

All disclosures are made in compliance with DPP3 of the PDPO.

Security of Personal Data

We implement appropriate technical and organizational measures to protect personal data against unauthorized access, processing, loss, or misuse, as required by DPP4 of the PDPO. This includes encryption for sensitive data transmission (e.g., SSL), access controls, and regular security reviews. However, no system is completely secure, and we cannot guarantee absolute protection.

Retention of Personal Data

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected (e.g., duration of a student’s enrollment) or as required by Hong Kong law, in accordance with DPP2 of the PDPO. Once no longer needed, data is securely deleted or anonymized.

Cookies and Similar Technologies

Our Website may use cookies and similar technologies to enhance user experience and analyze traffic. Cookies are small files stored on your device. You can manage cookie preferences through your browser settings.

Your Rights

Under the PDPO, you have the right to:

Access your personal data (via a Data Access Request - DAR) to check its accuracy.

Correct inaccurate personal data (via a Data Correction Request).

Withdraw consent for certain uses (where consent was the basis for collection), though this may affect our ability to provide services.

To exercise these rights, please contact us using the details below. We may charge a reasonable fee for processing access requests, as permitted by the PDPO.

Children's Privacy

Our Website and tutoring services are designed for students of various ages, but we do not knowingly collect personal data from individuals under the age of 18 without verifiable parental or guardian consent. If we become aware that we have collected such data without consent, we will delete it promptly. Parents or guardians should contact us if they believe their child has provided personal data without consent.

Third-Party Supplier: SimplyBook.me Ltd.

SimplyBook.me Ltd. acts as our supplier for booking and payment processing. They process personal data on our behalf in accordance with their Privacy Policy (available at simplybook.me) and our Data Processing Agreement, ensuring compliance with PDPO standards. We are not liable for their data handling practices; refer to their policy for details.

Transfer of Personal Data

If personal data is transferred outside Hong Kong (e.g., to cloud service providers), we ensure adequate protection through contractual clauses or other measures compliant with PDPO requirements.

Changes to This Policy

We may update this Privacy Policy Statement from time to time to reflect changes in our practices or legal requirements. Significant changes will be notified via the Website or email. Continued use of our services after changes constitutes acceptance.

If you have questions, concerns, or wish to make a data access or correction request, please contact our Data Protection Officer:

Fleur de Lys Academy Limited
Data Protection Officer
Email: support@fdlys.com

For more information on the PDPO, visit the Office of the Privacy Commissioner for Personal Data (PCPD) website: www.pcpd.org.hk.