Privacy & Cookie Notice (PDPO-aligned)
We maintain consent records for cookie preferences as part of our compliance processes.
​
Consent Records
Certain third-party services (e.g., analytics, measurement, or embedded tools) may place cookies that they control and are subject to their own privacy policies. See our cookie banner/settings for cookie categories and vendors.
​
Third-Party Cookies
Version: 2025-10-01 (rev2 — security measures & cookie consent clarified; aligned with the Glossary of Defined Terms)
Who We Are & Contact
JC Human Resources Limited (the “Platform”). Data protection contact: info@jchrhk.com
If you have questions or requests regarding this Notice, please contact us.
Personal Data We Collect
We collect personal data that you provide directly (e.g., account sign-up, checkout, contact forms, support tickets), data generated through your use of the Platform’s course system (PCS) (e.g., progress and assessments), and data collected automatically via cookies and similar technologies (see Cookie Notice). We may also receive limited data from payment processors (e.g., transaction reference IDs).
How We Collect Information
• Account & identity: name, email, phone; employer (if corporate cohort).
• Usage & learning data (via the Platform’s course system (PCS)): enrolments, progress, watch time, quiz attempts/scores, certificate IDs.
• Billing & transactions: order IDs, payment processor reference IDs (payment credentials are handled by our payment providers).
• Device/technical: IP address, device/browser metadata, logs and cookies (see Cookie Notice).
How We Use Data (Purposes & Legal Bases)
We may contact you about your account, transactions, service updates, security notices, and support matters. With your consent, we may also send marketing messages (you can unsubscribe at any time using the link in the email or by contacting info@jchrhk.com).
Communications
• Provide services & fulfil contracts (enrolment, access, certificates) — Contract.
• Fraud/security, troubleshooting, service analytics — Legitimate interests.
• Direct marketing (email/newsletter) — Consent (you can withdraw any time).
• Corporate cohorts: share limited progress/completion with employer for compliance — Contract/Legitimate interests.
• Provider sharing: learner‑level data is shared with Providers only if the learner has given explicit consent in checkout or account settings; otherwise only aggregated statistics are shared.
Sharing & International Transfers
• Service providers (processors): payment gateways, cloud hosting, email delivery, analytics, and support tools.
• Employers (cohorts): with your employer, where they are the customer, to evidence training/attendance.
• Legal and safety: where required by law, court order, or to protect rights, safety, or security.
• Cross‑border: personal data may be processed outside Hong Kong; we apply appropriate safeguards (e.g., contractual protections).
Retention
• Account data: as long as your account is active and as needed for legal/accounting.
• Learning records & certificates: typically 7 years (audit/compliance).
• Marketing data: until consent is withdrawn or per our retention policy.
Security
We implement reasonable technical and organisational measures appropriate to risk, including:
• Encrypted transmission (TLS) and encryption at rest for stored data where supported.
• Access controls based on least privilege and role‑based permissions; periodic access reviews.
• Multi‑factor authentication for administrative access where supported.
• Network protections (e.g., firewalls and web‑application protections) from our infrastructure partners.
• Secure development practices, vulnerability management, and regular patching.
• Backups and business continuity for critical systems.
• Incident response procedures, including investigation and notification where required by law.
You can withdraw consent for non-essential cookies at any time via the cookie banner/settings on our site. You can withdraw consent for marketing at any time via the unsubscribe link or by emailing info@jchrhk.com. We will then stop processing based on consent unless another legal basis applies.
Withdrawing Consent
Your Rights
Subject to applicable law (e.g., Hong Kong PDPO, and where relevant GDPR), you may request:
• access to and correction of your personal data;
• deletion/erasure where applicable;
• restriction or objection to certain processing (including direct marketing opt‑out);
• a copy of your data (portability, where required by law).
Requests: info@jchrhk.com. We may need to verify your identity before acting on a request.
​
Cookie Notice
We use cookies and similar technologies to operate our site, understand usage, and (with your consent) improve marketing. Non‑essential cookies are set only with your consent via our cookie banner. You can change preferences at any time in cookie settings.
Types of cookies:
• Strictly necessary — required for login, checkout, and course access; cannot be disabled.
• Analytics — help us understand usage and improve services (set only with consent).
• Functional/marketing — enhance features or personalise content/ads (set only with consent).
Managing cookies: Use our cookie banner/settings to review, accept, or reject categories. Your choices are stored and honoured for future visits until you change them.
​
Direct Marketing
You can opt in or out of marketing emails at checkout or in your account. You can withdraw consent at any time via unsubscribe links or by contacting info@jchrhk.com.
Our services are not directed to children under the age required by applicable law (e.g., 13 or 16). We do not knowingly collect personal data from such children. If you believe a child has provided personal data, please contact us and we will take appropriate steps to delete it.
​
Children
We do not sell personal information as defined by the California Consumer Privacy Act (CCPA). If our practices change, we will update this Notice and provide a 'Do Not Sell My Personal Information' link.
​
US (California) – Do Not Sell
​
Updates to this Notice
We may update this Notice from time to time. Material changes will be notified in advance via the Platform.
Contact
Questions or requests: info@jchrhk.com
​