Privacy Policy

1. Purposes of Collecting Personal Data

We will use your personal data and, if applicable, your child’s personal data for the following purposes:

• To process your purchases of our online products and programme registrations for ABC Pathways Group's educational institutions, including learning centres, international kindergartens, and education foundation. 
• To undertake various school administration, accounting and operation tasks related to your purchase. 
• To manage student records and provide educational services related to your purchase.
• To communicate with you, the parents or guardians regarding school activities, events, and emergencies.
• To conduct surveys, research, and statistical analysis for school improvement.
• To comply with legal and regulatory requirements.
• For any other purposes directly related to the above.

2. Types of Information Collected and How We Use It

We may collect the following types of personal data about you and/ or your children (as the case may be):

• Name, occupations, and contact details (e.g., phone number, email address, mailing address).
• Date of birth, gender, attended schools and school grades.
• Academic records, attendance records, and performance reports.
• Medical information, special educational needs, and dietary requirements.
• Credit card(s) and or bank account details.
• Emergency contact information. This includes contact details for designated individuals who may be reached in case of emergencies involving your child.

We only collect personal data when you voluntarily provide it after being fully informed. For example, we may collect personal data to obtain your feedback on our website and services or to enable your participation in school events, activities, or competitions.

We abide by certain restrictions when we collect, hold or use Hong Kong Identity Card (the “HKID”) card numbers and/or copies of HKID cards of individuals.

The general principle is that we will first consider alternatives to collecting HKID numbers/copies, such as using a passport number.

Where we are required or permitted to collect HKID numbers or copies, we will take reasonable steps to ensure:

• HKID numbers and copies are verified against the actual HKID card.
• HKID numbers and copies are only used for permitted purposes under privacy regulations.
• HKID numbers are not publicly displayed.
• HKID numbers and copies are retained only as necessary.
• Adequate security measures are implemented for HKID copies.
• Copies of HKID cards are marked “copy” across the image.

3. Direct Marketing

With your consent, we may use your personal data (e.g., name, email address, phone number) for direct marketing purposes, including:

• Promoting any school events, programmes, and activities.
• Providing information about educational products and services offered by ABC Pathways Group or its affiliated institutions.
• Sharing special offers, discounts, and updates from ABC Pathways Group.

If you do not wish to receive direct marketing communications, please indicate your preference on the relevant application form or contact our Marketing Department at marketing@abcpathways.com. Please keep in mind that by opting out of receiving this information, you or your son or daughter may miss important information related to school activities that may affect his or her participation in the school community.

4. Sharing of Personal Data

We highly value the confidentiality of your personal data and will not sell, rent, or lease your information to third parties without your consent. However, we may share your personal data with the following parties under the circumstances described below:

• Regulatory bodies, law enforcement agencies, or courts as required by law.

• Medical professionals or emergency services in case of emergencies.
  
  

In addition, with your consent, we may share or receive personal data about you or your child with affiliated companies or partner institutions for the purposes of managing school records and undertaking other administration/ operations tasks for schools and programmes operated by below institutions, which are our parent and affiliated entities: 

• ABC Pathways Group Limited (https://www.abcpathways.com) – To  provide course recommendations, as well as to coordinate curriculum continuity based on educational needs. 
  
• ABC Pathways Education Foundation Limited (https://www.abcpathways.edu.hk) – To process kindergarten admissions and school transfers, and to improve educational offerings. 
  
• Juniorversity Education Group Limited (https://www.juniorversity.com.hk) – To coordinate franchise operations and maintain educational standards, and to provide consistent educational experiences across all franchise locations.
• ABC Education Foundation (https://www.abcfoundation.hk) – To process applications for our kindergarten assistance programmes and other charitable initiatives supporting families and children in need.
• Bread & Butter Strategic Consultancy Company Limited (https://www.breadnbutter.com.hk) – To provide you with marketing materials, subject to your consent as outlined in section 4.

We encourage you to refer to the privacy policies of these affiliated companies or partner institutions for more details about how they collect, process, and share personal data. We treat all personal data received from these parties in accordance with this Privacy Policy and ensure it is used solely for the purposes outlined in this Privacy Policy.

Lastly, we may share your personal data with third-party vendors who assist us in handling certain aspects of personal data, such as data processing, IT support, or other operational services. We ensure that these vendors are compliant with applicable privacy laws and regulations and that appropriate agreements are in place to safeguard your data.

We reserve the right to use or disclose any information to comply with legal requirements, protect the integrity of our website, fulfil your requests, or cooperate with law enforcement investigations.

5. Security Measures and Data Retention

We are committed to ensuring the security and confidentiality of your personal data. To prevent unauthorised access, loss, or disclosure, we have implemented appropriate electronic and administrative safeguards, including:

• Firewall protection and antivirus software on servers.
• Encryption of data during transmission using SSL protocol. 
• Restricted access to personal data by authorised personnel only. 

We will retain your personal data only for as long as necessary to fulfil the purposes for which it was collected, unless otherwise required by law.

6. Cross-Border Data Transfers

Your personal data will be stored in Hong Kong. Unless required by law or with your explicit consent, we will not transfer your personal data to other countries or regions.

7. Children’s Privacy Policy

We are highly sensitive to privacy issues, especially concerning children. We will never knowingly collect personal data from children under the age of 18 without parental consent.

This website is not intended for individuals under 18 years of age. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at marketing@abcpathways.com or at 3469 1169 to request deletion.

We strongly encourage parents to monitor and supervise their children’s online activities.

8. How to Contact Us

You have the following rights regarding your personal data:

• To access and inquire about your personal data.
• To correct your personal data.
• To withdraw your consent (if processing is based on your consent).
• To request deletion of your personal data.
• To object to the use of your personal data for direct marketing.
• To lodge a complaint with the relevant authorities.

If you have any questions about this Privacy Policy or wish to exercise any of the above rights, please contact us at:

ABC Smile
Address: Unit 2503-05, 25/F, No. 148 Electric Road, North Point, Hong Kong

Phone: 57083824
WhatsApp: 5708 3824
Email: abcsmileorder@gmail.com

You may also use the above information to request modifications or deletion of your account and personal data.

9. Cookies 

For information about our use of cookies on this website, please refer to our separate Cookie Policy. If you do not wish to receive cookies or want to be notified when cookies are received, you may adjust your browser settings. Please refer to the “Help” section of your browser for instructions on changing cookie preferences. Note that disabling all cookies may affect the functionality of this website. 

10. Links to Other Websites

This website may contain links to third-party websites not operated by ABC ePathways Limited. Please note that we have no control over these websites. If you visit any linked websites, please review their privacy and other policies. We are not responsible for the policies or practices of other companies, and any information you provide to them is subject to their privacy policies.

11. Other ABC Smile Websites

All websites operated by us will adhere to this Privacy Policy. However, certain websites may have policies that differ due to laws, or specific circumstances. In any case, websites operated by ABC Smile will comply with the commitments outlined in this policy regarding the collection and use of personal data.

12. Changes to Our Privacy Policy

This Privacy Policy is effective as of June 2, 2025 and may be amended from time to time to reflect updates in accordance with the Personal Data (Privacy) Ordinance (Cap. 486). ABC ePathways Limited may revise this Privacy Policy as necessary. Any changes will be posted here, and we recommend that you check this page periodically for the latest version of our Privacy Policy. Please rest assured that any changes will not be applied retroactively and will not alter how we handle previously collected information. In the event of any inconsistency or conflict between the English and Chinese versions of this Privacy Policy, the English version shall prevail.at https://www.abc-smile.com.