Personal Information Collection Statement

This Personal Information Collection Statement (this “Statement”) is made by BTW Management Limited (“BTW”, “we”, “us”, or “our”), which manages and operates the Right Path (“RIGHTPATH”). This Statement applies between us and you (“you”, or “your”). It should be read together with the Terms and Conditions of the relevant mobile application operated by us or hosting our service (“Application”) and the website at www.rightpath.hk (“Website”). In the event of any inconsistency between this Statement and the Terms and Conditions concerning matters relating to personal data, this Statement shall prevail.

Commitment to Privacy

At RIGHTPATH, we are committed to the protection of your privacy and personal information. This Statement describes what information we collect, how we process and share it, and how you can manage and control the information we collect through RIGHTPATH.

By using RIGHTPATH, you agree to the terms of this Statement and trust us with your personal information.

Kinds of Personal Data We Collect

The kinds of personal data we may collect from you include:

• Name
• Gender
• Age (or age range), month and year of birth
• Contact details (email address, mailing/residential address, contact number)
• Username and password
• Membership number
• Marital status and family status
• Educational level and occupation
• Log Files (IP address, domain name, browser type, access time)
• Interests and favorite activities
• Tracking information about your use of the Application/Website
• Social media account information

Purposes for Using Personal Data

The personal data collected from you will be used for the following purposes (the “Purposes”):

• Processing your inquiries about RIGHTPATH and our services
• Managing bookings, purchases, and applications made by you
• Identifying and verifying your identity
• Registering you as a user of the Application/Website
• Improving our services and user experience
• Conducting research and analysis regarding user behavior
• Sending you direct marketing communications (with your consent)
• Managing and maintaining the Application/Website

Sharing of Personal Data

We may share your personal data with:

• Our Affiliates and Marketing Partners for the Purposes outlined above
• Agents, contractors, suppliers, and service providers
• Regulatory bodies, courts, or governmental authorities as required by law

In the event of a business transfer or restructuring, your personal data may be transferred to the new entity, provided that they adhere to this Statement.

Direct Marketing

With your consent, we may use your personal data to send you direct marketing communications about our services and those of our Affiliates and Marketing Partners. You can opt-out of direct marketing at any time by contacting us at privacy@rightpath.hk.

Your Rights

You have the right to:

• Check whether we hold any of your personal data
• Access your personal data held by us
• Request correction of any inaccurate personal data
• Inquire about our policies regarding personal data

To make a request or for general inquiries, please contact our Personal Data Privacy Officer at:
Email: privacy@rightpath.hk

Privacy Policy Statement

We adopt the RIGHTPATH Privacy Policy Statement. For further details on our policies related to personal data protection, please visit RIGHTPATH Privacy Policy. In case of any inconsistency between this Statement and the RIGHTPATH Privacy Policy Statement, this Statement shall prevail.

Updates to This Statement

This Statement may be updated periodically to reflect changes in our privacy practices. Significant changes will be communicated to you, and your continued use of RIGHTPATH after such changes constitutes acceptance of the revised Statement.

Governing Law

This Statement shall be governed by and construed in accordance with the laws of Hong Kong.