Privacy Policy

1. Introduction

Voyager Sextant is committed to protecting the personal data of everyone who interacts with our courses and services. This policy explains what data we collect, how we use it, how we protect it, and what rights you have in relation to it. It applies to all personal data collected through our website, enquiry forms, and course administration processes.

We process personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO"). Where participants are located in other jurisdictions, we also take account of applicable local data protection requirements.

If you have questions about this policy, please contact us at [email protected].

2. Data We Collect

We collect personal data in the following ways:

• Enquiry and contact forms: Name, email address, telephone number (if provided), and the content of your message.
• Course enrolment: Name, email address, telephone number, country of nationality (for course customisation purposes), and payment information (processed by our payment provider — we do not store card details).
• Website analytics: If you have consented to analytics cookies, we collect anonymised information about pages visited, session duration, and referral source.
• Communications: Records of correspondence between you and Voyager Sextant, including emails and enquiry responses.

We collect only what is necessary for the purposes described in this policy. We do not collect sensitive personal data (such as financial account details beyond payment processing, health data, or political opinions).

3. How We Use Your Data

We use personal data for the following purposes:

• Responding to enquiries about our courses and programmes
• Managing course enrolments and delivering programme materials
• Processing payments for courses (via third-party payment processors)
• Sending course-related communications during and after the programme
• Seeking participant feedback on completed programmes (optional)
• Improving our course content and delivery based on aggregated, anonymised participant information
• Complying with legal and regulatory obligations applicable in Hong Kong

We do not use participant data for marketing purposes without explicit consent, and we do not share personal data with financial product providers, advisers, or other third parties for commercial purposes.

4. Legal Basis for Processing

We process personal data on the following bases:

• Contract: Where processing is necessary to deliver the course or service you have enrolled in or enquired about.
• Legitimate interest: Where processing is necessary for our legitimate interest in operating and improving our services, and where this interest is not overridden by your rights.
• Consent: Where you have provided explicit consent, including for analytics cookies and optional marketing communications.
• Legal obligation: Where processing is required to comply with applicable law.

5. Data Retention

We retain personal data for as long as is necessary for the purposes for which it was collected:

• Enquiry records: up to 12 months from the date of the last communication
• Course participant records: up to 5 years from the date of course completion (for administrative and legal compliance purposes)
• Payment records: as required by Hong Kong tax and accounting obligations (typically 7 years)
• Analytics data: in anonymised, aggregated form with no retention limit

When retention periods expire, personal data is securely deleted or anonymised.

6. Data Protection Measures

We take reasonable and appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit (TLS) and at rest where applicable
• Access controls limiting personal data access to authorised staff only
• Regular review of data handling processes and security measures
• Use of reputable third-party service providers with appropriate data protection commitments

In the event of a data breach that is likely to affect your rights, we will notify affected individuals and relevant authorities as required under applicable law.

7. Third-Party Services

We use the following categories of third-party services in connection with our operations:

• Payment processing: Handled by third-party payment providers operating under their own privacy policies and security standards.
• Website analytics: If you have consented, analytics data is processed by analytics service providers. Data is anonymised and aggregated before we review it.
• Email delivery: Communications are sent via email service providers operating appropriate data protection standards.

We do not sell or rent personal data to third parties. We do not share your data with financial advisers, product providers, or marketing companies.

8. Cookies

Our website uses cookies for essential functionality and, with your consent, for analytics purposes. For full details of the cookies we use and how to manage your preferences, please see our Cookie Policy.

9. Your Rights

Under the Personal Data (Privacy) Ordinance and, where applicable, other data protection legislation, you have the following rights:

• Access: You may request a copy of the personal data we hold about you.
• Correction: You may request that inaccurate or incomplete personal data be corrected.
• Erasure: You may request deletion of your personal data where there is no longer a legal basis for its retention.
• Objection: You may object to processing based on legitimate interest.
• Withdrawal of consent: Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Portability: Where applicable, you may request that personal data be provided in a structured, machine-readable format.

To exercise any of these rights, please contact us at [email protected]. We will respond within 30 days. In Hong Kong, you may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data.

10. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their policies before providing any personal data.

11. Children's Privacy

Our courses and services are intended for adults aged 40 and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.

12. Policy Updates

We may update this policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will update the "Last updated" date at the top of this page. Continued use of our website or services after updates constitutes acceptance of the revised policy.

13. Contact Us

Data controller: Voyager Sextant
Address: 21/F, Champion Tower, 3 Garden Road, Central, Hong Kong
Email: [email protected]
Telephone: +852 3649 7152