KEEP Privacy Policy

Last updated 14 Feb, 2019. Replaces all prior versions

We respect your right to privacy. This Privacy Policy is meant to help you understand of the information that we may collect from you and how we may use that information. This Privacy Policy should be read alongside, and in addition to, the Terms of Service.

1. What Information We Collect

We collect a variety of information that you provide directly to us. We collect information from you through, but not limited to, the following ways:

• using our Service through any media, including website and mobile apps;
• signing up for a KEEP user account;
• updating a KEEP user Profile;
• creating a course or question (poll) on KEEP;
• enrolling and participating in online courses hosted on KEEP;
• posting to public forums included through the Services, such as providing comments to online learning materials in KEEPCourse and KEEPCatalog; or
• sending email messages to KEEP.

The types of information we collect directly from you include:

• log-in credentials (email and password) and username, if you create a KEEP account;
• your name, birthday, education history and other personal information provided in your Profile;
• your activities on using our Services, including page visits and learning activities;
• information about your user service and maintenance interactions with us;
• user-generated content you upload or post to public forums, such as course discussions and comments on courses or educational tools, through the Services;
• information needed in order to comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
• any other information you choose to directly provide to us in connection with your use of the Services.

When you use our Services, we and our service providers (which are third parties that work on our behalf) may use cookies, and similar technologies to track, collect and aggregate certain information including, among other things, which pages of our websites were visited, the order in which they were visited, when they were visited, the URLs from which you linked to our websites, and which hyperlinks were “clicked”. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Service. Through such information, we may be able to determine from an IP address a user’s Internet Service Provider and the general geographic location of his or her point of connectivity.

2. How We Use the Information

We use your information for various purposes depending on the types of information we have collected from and about you and the specific services you use, in order to:

• provide Services to you, such as delivering website content, online courses and services that you request in conjunction with the online courses;
• manage and process online courses, including but not limited to tracking visits, progress and completion; administering exams, projects, and other assessments;
• send you information in connection with the Services;
• respond to your communications and requests;
• contact you by email, postal mail, or phone (including via SMS messages) regarding KEEP and third-party products, services, surveys, research studies, promotions, special events and other subjects that we think may be of interest to you;
• customize the content we provide through the Services;
• help us better understand your interests and needs, and improve the Services;
• engage in analysis, research, and reports regarding use of the Services;
• secure the Services;
• comply with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others; and
• establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others.

We may aggregate and/or anonymize any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/Anonymous Information”). We may use Aggregate/Anonymous Information for any purpose, including without limitation for research and marketing purposes, statistical analyses of Service usage, and may also share such data with any third parties, including researchers, promotional partners, and sponsors.

3. How We Share and Disclose Your Information

KEEP will share your information in the following ways:

• provide access to or share your information with operations and maintenance contractors and other third parties who perform services on our behalf. They have access to perform these services but are prohibited from using your information for other purposes;
• allow the course teams (usually the course instructors and administrators) of the online courses you enrolled in to track your learning activities, such as visits, watching videos, question attempts, as well as your progress and performance;
• share with other participants in the same course you have enrolled to create an interactive learning environment, support class participation, and share course information. This includes sharing comments, coursework, or other information or content that you submit to KEEP designed for viewing by other class members or for public communication;
• display your comments to online courses and educational tools that you leave in publicly accessible areas of our Services;
• share course, user and Service usage data with our collaborating researchers so that they may use the data for research related to online education. Whenever applicable, the data would be shared anonymously;
• share Aggregate/Anonymous Information about use of the Services, such as, but not limited to, publishing a report on usage trends or survey results, as well as participation rates, graduation rates, and other demographic information provided to us by KEEP users. The sharing of such data is unrestricted; and
• any other way with your explicit consent.

Data users other than KEEP, such as course teams and researchers, need to comply with this Privacy Policy and any additional data protection requirement as laid down by KEEP.

4. Updating or Deleting Your Information

Except for login credentials (email and password) and username which are bonded to your KEEP account, you can always update or delete your personal data you provided in your Profile. Since login credentials and username are critical identifiers in our Services, you cannot modify or delete them manually.

To request deletion of your KEEP account and personal information, you should contact us using the information in the “Contacting KEEP” section below. Your personal information associated with the account, including login credentials and username, would be deleted while your activity logs would be anonymized. Deleting a KEEP account is a permanent action and cannot be reversed.

If you are requesting deletion of your KEEP account, please also note that:

• the associated personal information stored in the operation environment of our Services would be deleted within 60 days;
• the associated personal information in system backups are not deleted together with those in the operation environment of our Services; those in system backups are protected from unnecessary accesses and would eventually be deleted within 12 months; and
• communications of user services, such as email enquiries, are not deleted for service needs. You may raise a separate request to delete such communication records.
5. Confidentiality & Security

We consider the confidentiality and security of your information to be of the utmost importance. KEEP takes a variety of technical, administrative, and physical measures to protect your information from disclosure to or access by third parties. Please note that we do not guarantee the security of information, as no method of internet transmission or storage is completely secure. Also note that we may retain and store your information in our databases and systems even after your KEEP account is deleted as long as we have a legitimate purpose to do so and in accordance with applicable law.

6. Your Rights

You have certain rights in relation to your personal information. You can access your personal information and make updates if necessary. You can also choose whether or not you wish to receive direct marketing material from us.

Your local laws, such as in the European Union, may permit you to request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct marketing purposes (including any direct marketing processing based on profiling);
• update information which is out of date or incorrect;
• delete certain information which we are holding about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information.

We will consider all requests related to personal information and provide our response within the time period stated by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation.

If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contacting KEEP” section below at any time.

7. Changes To Our Privacy Policy

Please note that we review our privacy practices from time to time, and that these practices are subject to change. Any change, update, or modification will be effective immediately upon posting on our website(s). You can know if the Privacy Policy has changed since the last time you reviewed it by checking the “Effective Date” included at the beginning of the document. If we make a material change to the Policy, you will be provided with appropriate notice in accordance with legal requirements. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. Be sure to return to this page periodically to ensure familiarity with the most current version of this Privacy Policy.

8. Contacting KEEP

If you have any questions, comments or complaints about this Privacy Policy, please contact us: privacy@keep.edu.hk

Knowledge & Education Exchange Platform
Attn: Privacy

6/F, Hui Yeung Shing Building,
The Chinese University of Hong Kong,
Shatin, New Territories, Hong Kong