🔒 Privacy Policy

1. About This Privacy Policy

This Privacy Policy applies to personal data collected, used and protected by APASS ("we", "us" or "the platform") through the website apasscar.com and related services.

We comply with the Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region and are committed to safeguarding all users' personal data privacy.

2. Personal Data We Collect

To provide driving instructor matching and related services, we may collect the following categories of personal data:

2.1 Information You Provide

• Contact details: Name, telephone number, email address and WhatsApp number
• Driving lesson requirements: Preferred vehicle type (private car / light goods vehicle / motorcycle), area and available lesson times
• Enquiry details: Messages you submit through our contact form, WhatsApp or telephone
• CEF-related information: Relevant documents and information that may be required if you apply for Continuing Education Fund support

2.2 Information Collected Automatically

• Device information: IP address, browser type and version, and operating system
• Usage information: Pages viewed, time spent, click records, and dates and times of visits
• Location information: Approximate geographical location based on your IP address, rather than precise location tracking
• Cookie information: See the Cookies and Tracking Technologies section below

3. How We Use Personal Data

We use the personal data we collect for the following purposes:

1. Instructor matching: Matching you with a suitable driving instructor according to your requirements
2. Customer service: Responding to enquiries, handling complaints and providing after-sales support
3. Service improvements: Analysing usage data to improve platform features and the user experience
4. Communications: Sending service confirmations, booking reminders and important notices
5. Marketing: With your consent, sending driving lesson offers, new articles and promotional information; you may unsubscribe at any time
6. Legal compliance: Complying with applicable laws and regulations

4. Sharing and Disclosure

We do not sell your personal data to third parties. We may need to share your data in the following circumstances:

• Driving instructors: To complete a match, we provide your contact details and lesson requirements to the matched instructor
• Service providers: Technical providers helping us operate the platform, such as website hosting and analytics providers, who are contractually required to protect your data
• Legal requirements: We may disclose your data where required by law, regulations, legal proceedings or government authorities
• Protection of rights: Where necessary to protect the rights, property or safety of the platform, users or the public

5. Cookies and Tracking Technologies

The platform uses cookies and similar technologies to improve your browsing experience:

5.1 Types of Cookies We Use

• Essential cookies: Cookies necessary for the website to function properly
• Analytics cookies: Tools such as Google Analytics help us understand website usage and improve our services
• Functional cookies: Remembering your preferences, such as language selection
• Advertising cookies: Used by advertising platforms such as Google Ads to display relevant advertisements and measure their effectiveness

5.2 Managing Cookies

You can manage or delete cookies in your browser settings. Please note that disabling certain cookies may affect some website features.

6. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes for which it was collected:

• Customer information: No more than 3 years after the service relationship ends
• Enquiry records: 1 year from the last contact
• Website analytics data: Up to 26 months, with anonymisation
• Legal requirements: We will follow any longer retention periods required by law

After the retention period, we securely delete or anonymise the relevant data.

7. Data Security Measures

We take reasonable technical and organisational measures to protect your personal data, including:

• SSL/TLS encryption throughout the website (HTTPS)
• Regular server security updates
• Restricting employees' access to personal data
• Regular backups and security reviews

Although we make every effort to protect your data, internet transmission cannot be guaranteed to be 100% secure. If we discover a data breach, we will notify affected users and take remedial action as soon as possible.

8. Your Rights

Under the Personal Data (Privacy) Ordinance, you have the following rights:

• Access: Request access to the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete personal data
• Deletion: Request deletion of your personal data to the extent permitted by law
• Opting out of marketing: Stop receiving marketing communications at any time

To exercise these rights, contact us using the details below. We will respond within 40 days of receiving your request.

9. Third-Party Links

The platform may contain links to third-party websites, such as driving schools, the Transport Department and the CEF website. We are not responsible for their privacy policies and recommend reviewing those policies before visiting them.

10. Minors

Our services are intended for people aged 18 or over, consistent with Hong Kong's minimum age for applying for a learner's driving licence. We do not knowingly collect personal data from anyone under 18. If we discover that we have collected a minor's data, we will delete it as soon as possible.

11. Policy Updates

We may update this Privacy Policy from time to time. The updated policy will be published on this page and its "Last updated" date revised. We will notify you of significant changes through a website notice or email.

We recommend checking this page regularly for the latest Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy or wish to exercise your personal data rights, please contact us using the following methods:

• Telephone: 6932 9632
• Email: info@apasscar.com
• WhatsApp：Contact Us Here
• Website: apasscar.com

You may also contact Hong Kong's Office of the Privacy Commissioner for Personal Data with a complaint or enquiry: www.pcpd.org.hk