Tribune Way

Legal

Privacy Policy

Last updated: 1 May 2025

Tribune Way is committed to handling personal data responsibly and in accordance with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 592) ("PDPO"). This policy explains what data we collect through our website and programme enquiries, how we use it, and the choices available to you.

1. Who we are

Tribune Way operates as a corporate governance education provider based at 22/F, 8 Queen's Road Central, Central, Hong Kong. For the purposes of this policy, Tribune Way is the data controller of personal data submitted through this website and through programme enrolment.

2. Data we collect

We collect personal data in the following circumstances:

  • Enquiry and contact forms: name, email address, telephone number (optional), and the content of your message.
  • Programme enrolment: name, organisation, job title, contact details, and payment information (processed through a third-party payment processor — we do not retain card numbers).
  • Subscription registration: name and email address for the Reader's Annual Subscription.
  • Website usage: IP address, browser type, pages visited, and session duration — collected via analytics cookies where you have consented.

We do not collect data from individuals we know to be under eighteen years of age, and our programmes are directed exclusively at senior professionals.

3. How we use your data

Personal data submitted through this website is used for the following purposes:

  • Responding to enquiries and providing information about our curriculum.
  • Processing enrolment, issuing confirmation, and managing programme participation.
  • Delivering the Reader's Annual Subscription and associated communications.
  • Sending programme updates, cohort announcements, and written commentaries — where you have expressed interest or enrolled, and subject to your preferences.
  • Improving the functionality and content of our website using aggregated, anonymised analytics data.
  • Complying with any legal or regulatory obligation to which Tribune Way is subject.

We do not use your data for automated decision-making or profiling.

Under the PDPO, personal data must be collected for a lawful purpose directly related to the activity of the data user and must not be excessive. We collect only data that is reasonably necessary for the purposes described above. Where we send communications beyond an initial response, we do so on the basis of your prior consent or an existing relationship, and you may withdraw at any time.

5. Disclosure to third parties

We do not sell, rent, or share personal data with third parties for their own marketing purposes. Data may be disclosed in the following limited circumstances:

  • Service providers: payment processors, email delivery services, and website hosting providers engaged by Tribune Way who are bound by confidentiality obligations.
  • Legal requirements: where disclosure is required by law, court order, or regulatory authority in Hong Kong.
  • Business transfers: in the event of a merger or acquisition of Tribune Way, subject to equivalent privacy protections being maintained.

6. Data retention

We retain personal data for as long as is necessary for the purpose for which it was collected, or as required by applicable law:

  • Enquiry data not resulting in enrolment: up to 12 months.
  • Enrolment and programme records: 7 years, consistent with Hong Kong record-keeping obligations.
  • Subscription data: for the duration of the subscription plus 12 months.
  • Analytics data: aggregated and anonymised; not retained in identifiable form beyond 26 months.

When data is no longer required, it is securely deleted or anonymised.

7. Your rights

Under the PDPO, you have the right to:

  • Request access to personal data we hold about you (a Data Access Request).
  • Request correction of inaccurate personal data (a Data Correction Request).
  • Withdraw consent for marketing communications at any time.
  • Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.

Requests should be submitted in writing to [email protected]. We will respond within 40 days, as required by the Ordinance.

8. Cookies

This website uses cookies. A detailed explanation of the cookies we use and your choices is set out in our Cookie Policy. You can manage your cookie preferences at any time through the consent settings on this website.

9. Third-party links

Our website may contain links to external websites, including professional associations or reference publications. This privacy policy applies only to the Tribune Way website. We are not responsible for the privacy practices of external sites and encourage you to review their policies before submitting personal data.

10. Security

We take reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These include use of HTTPS for data transmission, access controls, and regular review of our data handling practices. No method of transmission over the internet is entirely without risk, and we cannot guarantee absolute security.

11. Changes to this policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we do, we will revise the "last updated" date at the top of this page. We encourage you to review this policy periodically. Continued use of the website after an update constitutes acceptance of the revised policy.

12. Contact

If you have questions about this Privacy Policy or wish to make a data access or correction request, please contact us:

You may also contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong if you have concerns about our handling of your data: www.pcpd.org.hk.