Privacy Policy
This policy explains how Pavilion Vault collects, uses, and looks after your personal information. It is written in plain language and governed by Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486).
Last updated: January 2026
Contents
1. Who we are
Pavilion Vault is an independent property income education company registered and operating in Hong Kong. Our registered address is 30/F, The Gateway Tower 6, 9 Canton Road, Tsim Sha Tsui, Hong Kong. We are the data controller for personal information collected through our website and course enrolment process.
We do not provide financial advice, and the collection of your personal data is limited to what is needed to deliver our educational programmes and respond to your enquiries.
2. Information we collect
We collect only what is necessary for the purpose at hand. Depending on how you interact with us, this may include:
Information you give us directly
- Your name and email address when you submit an enquiry or register interest in a course
- Your phone number, if you choose to provide it
- Any questions or notes you include in correspondence with us
- Payment details, processed through our third-party payment provider — we do not store card numbers ourselves
Information collected automatically
- Browser type, device type, and approximate location (city-level) via server logs
- Pages visited and time spent on pages, via analytics tools
- Referring website, where applicable
We do not collect sensitive personal data such as identity card numbers, financial account details, health information, or similar categories.
3. How we use your information
We use personal data for the following purposes:
- To respond to your enquiries and follow up as appropriate
- To process course enrolments and manage your participation
- To send course materials, updates, and relevant communications
- To inform you of forthcoming courses where you have indicated interest
- To understand how our website is used and improve it over time
- To meet our legal and compliance obligations
We do not use your data for automated decision-making, profiling, or targeted advertising. We do not sell personal information to third parties.
4. Legal basis for processing
Under the Personal Data (Privacy) Ordinance (Cap. 486), we process your personal data on the following grounds:
Consent — where you have submitted a form or agreed to hear from us
Contractual necessity — to deliver a course you have enrolled in
Legitimate interests — to maintain reasonable records and improve our services, where this does not override your rights
6. How long we keep data
We keep personal data only as long as it is needed for the purpose for which it was collected, or as required by law:
- Enquiry records: up to 24 months from last contact, unless you have enrolled in a course
- Course enrolment records: up to 7 years, in line with standard business record requirements
- Payment records: as required by the Inland Revenue Ordinance and our payment processors
- Analytics data: in aggregate or anonymised form, with no fixed retention limit
When data is no longer needed, it is securely deleted or anonymised.
7. Your rights
Under the Personal Data (Privacy) Ordinance, you have the right to:
- Request a copy of the personal data we hold about you
- Request correction of any inaccurate data
- Withdraw consent for marketing communications at any time
- Ask us to delete data we hold about you, subject to legal retention obligations
- Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (Hong Kong)
To exercise any of these rights, please contact us using the details in section 11. We will respond within 40 days, as required by the Ordinance. There is no charge for a standard data access request.
9. Security
We take reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Our website uses HTTPS throughout. Payment processing is handled by PCI-compliant third parties, and we do not store card details on our own systems.
No online transmission is entirely without risk, but we take the steps within our control to keep your information safe.
10. Changes to this policy
We may update this policy from time to time. When we do, the revised version will be published on this page with an updated date. If the changes are material, we will contact enrolled participants directly. We encourage you to review this page periodically.
11. How to reach us
If you have questions about this policy, or wish to exercise your rights, you are welcome to contact us:
Pavilion Vault
30/F, The Gateway Tower 6, 9 Canton Road
Tsim Sha Tsui, Hong Kong
You also have the right to contact the Office of the Privacy Commissioner for Personal Data (Hong Kong) if you believe your data has been handled contrary to the Ordinance: www.pcpd.org.hk