Pearson Education North Asia Limited
Policy and Practices relating to the Personal Data (Privacy) Ordinance of Hong Kong SAR

Last updated: 20/10/2000


Objectives of this Privacy Policy Statement

This statement sets out the obligations and policies of Pearson Education North Asia Limited ("PENA") formulated in accordance with the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (the Ordinance).

Any part of this statement with an asterisk (*) applies to the on-line media only.


Personal Data

PENA holds personal data collected from various types of sources (including on-line media) for the purposes laid out in Part IV below, and ensures that the aforementioned personal data will be handled in accordance with the provisions of the Ordinance

A. Types of personal data that may be held by PENA:
  • Name
  • Contact details including contact name, address, telephone number, fax number, e-mail address, pager number
  • Longman Teachers' Club identification details including name and membership number
  • Education level
  • Details of school attending/attended including school name, school address, subjects interested in
  • Details of school employed at including school name, school address, academic subjects of interest, academic subjects taught
  • Occupation, employment position, number of years working experience
  • Suggestions, personal opinions, enquiries
  • Interests and hobbies
  • Internet browser type and version*
  • Personal computer operating system*
B. How personal data is collected by PENA?

(i) PENA may collect personal data from visitors to the web site when they:
  • visit the PENA web site ( (including the Teaching Resource Centre, Longman Teachers' Club, Longman Teachers' Club (Pre-school), Home Study Programme, Game, Current Issues & Forum, Dictionary World and other web pages in the site)*
  • download application forms, make on-line subscription of particular subject(s)' information from PENA web site,*
  • complete questionnaires, respond to surveys, or
  • participate in competition, enroll seminars, promotional events or training courses
(ii) PENA may conduct desk research to collect personal data. This source includes information posted in world wide web, government publication, newspaper, magazine, registered associations' release, and any other information which is released to public.
(iii) PENA also obtains personal data from all kinds of primary research such as sales visit, personal and telephone interview, focus group discussion and so on.



Cookies & Domain Name Server (DNS) Address*

A. PENA web server may also collect data relating to visitors' online session, the use of which is to provide aggregated, anonymous, statistical information on the server's usage so that PENA may better meet the demands and expectations of visitors to our sites. This type of data includes:
  • the browser type and version
  • operating system, or
  • the DNS address and/or domain name
B. Certain PENA web pages may place a "cookie" on visitors' browser in order to provide personalised services and/or maintain their identity across multiple pages within a single session.



Purpose of Collecting Personal Data

Purposes for which personal data may be used include:
  • marketing of books, CD-ROMs, cassettes and other related teaching resources
  • conducting customers, products and services surveys, activities and joint-promotions with third parties (please refer to Section V.C)
  • evaluation and further enhancement of the company's products and services
  • processing games, lucky draws and promotional events
  • provision of on-line teaching resources and useful web linkage*


Transfer of Personal Data

A. Personal data will be kept confidential but PENA may provide such information to:
  • its subsidiaries and associated companies in order to provide information on products, training courses as well as promotional and sales events
  • any person who owes a duty of confidentiality to PENA who has undertaken to keep such information confidential

PENA does not sell or share personal data to any party unrelated to Pearson Education unless disclosure is required under applicable law.



Although PENA may conduct joint-promotional activities of products and services with a third party that is unrelated to Pearson Education, no transfer, sharing or disclosure of personal data, in hard or soft copy, to such third party will be made. The third party may only access the personal data of those customers who participate in services or purchases (e.g. competition, lucky draw, coupon or gift voucher) from a specific joint-promotional campaign that requires a direct response from each customer.




Data Access and Correction Requests

A. As a data subject, any individual has the right under the Ordinance:
  • to check whether PENA holds any personal data, to obtain a copy of that data and to correct any data that is inaccurate. Requests for access to data or correction of data should be in writing and made to:
    The Data Protection Officer
    Pearson Education North Asia Limited
    18th Floor Cornwall House,
    Taikoo Place,
    979 King's Road,
    Quarry Bay, Hong Kong.
    Fax: 2565 7440

  • to ascertain PENA's policy and practice in relation to such data and to be informed of the type of personal data held by PENA

PENA will respond to such requests of access or correction within 40 days in compliance with the Ordinance.

C. A reasonable fee may be charged to cover administrative expenses for the access request.



Security Precautions


PENA will use encryption for transmission of sensitive data. While PENA strives to protect all personal information, PENA cannot ensure or warrant the security of any information transmitted to PENA in any form*.



Access to personal data is restricted to those PENA employees who need to use the data and who have been trained to handle such data properly and to observe confidentiality.


C. Any person who has access to personal data held by PENA is duty bound under an act of confidentiality to PENA, which has in turn undertaken to keep such information confidential.



Protection of Children*

A. Visitors to the web site who are under the age of 18 must obtain permission from parents or legal guardians before undertaking any of the following activities:
  • sending any individual personal information or any information about others
  • entering any contest, game or lucky draw
B. It should be noted that once permission is obtained, the user should only submit a first name or initials to be publicly posted on the web site. A full name should never be used.




Nothing stated in this Policy shall limit the rights of any data subject under the Ordinance. However, there are certain exemptions. They include exemptions from subject access and use limitation requirements of the Ordinance where their application is likely to prejudice certain competing public or social interests, such as: security, defence and international relations; prevention or detection of crime; assessment or collection of any tax or duty; news activities; and health.


PENA reserves the right to change this policy at any time by notifying the parties concerned, through a notice posted on the Homepage, or by e-mail, fax, or mail, of any updates.

Copyright © 2001 Pearson Education North Asia Limited
All rights reserved.

If you do not wish to receive any promotional material other than that relating to PENA's products and services, please write to our Data Protection Officer:

Pearson Education Asia Limited
18th Floor Cornwall House,
Taikoo Place,
979 King's Road,
Quarry Bay, Hong Kong.
Fax: 2565 7440

If there is any inconsistency or conflict between the English version and Chinese version of this statement, the English version shall prevail.

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