Privacy Policy


2BeGuru Company Limited



2BeGuru Company Limited (軲轆軲轆有限公司) (“2BeGuru”, “we”, “us” or “our”) recognizes our responsibilities in relation to the collection, use, disclosure and other processing and storage of personal data. We are concerned to ensure that all personal data submitted through our website [and/or Apps] are handled in strict adherence to the relevant provisions of the Personal Data (Privacy) Ordinance (“PDPO”). We ask that you read this Privacy Policy (“Policy”) carefully before using our website [and/or Apps] as it explains how we collect, use, disclose, process and storage of your personal data.


By using and/or signing up as a member in our website [and/or Apps], you consent to and accept our collection, use, disclosure, process and storage of your personal data in accordance with the terms of this Policy.


1   Application of Privacy Policy

This Policy applies to our past, current and prospective customers, our customers’ customers, users and visitors to [name of website] which is operated by 2BeGuru.


2    Provision of Services

Any mention of “Services” in this Policy is a reference to the website [and/or Apps] and its/their related service of design, production, post production, promotion, learning effectiveness enhancement, sales, after-sales and follow-up arising from and/or in relation to, including but not limited to, video courses, electronic books, animation, motion graphics, audio books, counselling, consultation, coaching sharing sessions, forums, tutorial sessions, lectures, workshops, conferences, meetings and webinars.


3    Personal Data We Collect

3.1 The personal data we collect (which includes sensitive personal data as defined under relevant applicable laws and regulations), includes the following:

3.1.1  your name, identification number, passport number, photograph, telephone number(s), date of birth, email address, mailing address and any other information relating to you which you may have submitted to us;

3.1.2 information on your professional background such as the name of your employer, your job title, your industry, skills and area(s) of professional expertise;

3.1.3 payment information such as your credit card information and billing address;

3.1.4 basic account information from your social media or Google account where you sign-up for membership and/or login to our website [and/or Apps] using such accounts;

3.1.5 information on your usage of and interaction with our website [and/or Apps]; and

3.1.6 information on your general or specific geographical location where you specifically enable the collection of such location data when you install our App.

3.2 Occasionally we may receive information about you from other sources (such as credit reference agencies) which we will add to the information which we already hold about you in order to help us to provide our Services.


4    How Your Data is Collected

Generally, we may collect, use, disclose, process and storage your personal data in the following ways:

4.1 when you submit information to us through our website, [Apps], and/or paper forms;

4.2 when you access our website [and/or Apps] and/or perform and online transaction;

4.3  when you sign-up for alerts, newsletters and/or email mailing lists;

4.4   when you interact with any of our employees either in-person or online; and

4.5 when you communicate with us or third parties engaged by us. 


5 Why We Collect, Use, Disclose, Process and Storage Your Personal data

We may collect, use, disclose, process and storage your personal data for the following purposes: -

5.1  to provide and improve our Services;

5.2 to prevent, detect, investigate and take measures against criminal activities, fraud, misuse and damages to our website; 

5.3   to provide you with further information and details concerning the Services which you have purchased and/or signed up for;

5.4    to respond to any queries or request made by you, or to investigate and handle any complaints;

5.5     to communicate with you to inform you of changes and updates to our policies, terms and conditions, and other administrative information in relation to our Services;

5.6 to conduct market and statistical research in order to better understand customer preferences and demographics, and/or to improve our operations, systems and Services;

5.7   to verify your identity for the purpose of providing you with our Services;

5.8   to facilitate and/or process any payments between you and us;

5.9  to enforce and/or manage legal claims;

5.10 any other purpose for which we have specifically obtained your consent; and

5.11 any purpose directly relating to the above.


6  Use of Personal Data for Direct Marketing Purposes

6.1  In addition to the purposes set out above, where permitted by law, we may collect, use, disclose and storage your personal data for promotional or marketing purposes including sending you promotional materials and conducting direct marking in relation to our Services.


6.2    For the purpose of direct marketing, we may, where permitted by law, provide your personal information to providers whether within or outside of 2BeGuru and its marketing or research services so that they can send you promotional materials and conduct direct marketing in relation to the products and services they offer (these materials may be sent to you by postal mail, email or other means).


6.3   Before using or providing your personal data for the purposes and to the transferees set out in this Policy, we may be required by law to obtain your written consent, and in such cases, only after having obtained such written consent, may we use and provide your personal data for any promotional or marketing purpose.


6.4   If your consent is required, and you provide such consent, you may thereafter withdraw your consent to the use and provision to any transferees set out in this Policy by 2BeGuru of your personal data for direct marketing purposes and thereafter 2BeGuru shall cease to use or provide such data for direct marketing purpose.


6.5  If you have provided consent and wish to withdraw it or if you prefer not to receive marketing communications from us in any form, please inform us by postal mail or by email through the ways as specified in the section of “How to Contact Us” below. Any such request should clearly state details of the personal data in respect of which the request is being made.


7  Use of Cookies and other Gathering Technologies

7.1  Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the website and to compile statistical reports on website activity. A cookie, however, does not have the function of identifying an individual user of the website.


7.2   We may use cookies and other tools on the website. By continuing to use the website, you are agreeing to us placing cookies on your computer. The information collected (including but not limited to: your IP addresses (and domain names), browser software, types and configurations of your browser, language settings, geo-locations, operating systems, referring website, pages and content viewed, and duration of visit) will be used to ensure operation of the website and enable you to log in securely, for compiling aggregate statistics on how our visitors reach and browse our websites for web enhancement and optimization purposes, and to help us understand how we can improve your experience on it.


7.3  You may choose to accept or reject cookies. If you decide to reject cookies from our website, you can block cookies by activating the setting within your browser that allows you to refuse and setting of all or some cookies. Please be aware if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.


7.4  If you wish to withdraw your agreement at any time, you will need to delete your cookies using your browser settings for each browser you use.


8     Retention of your Personal Data

8.1 We may retain your information for as long as necessary to fulfill the purpose(s) for which it is collected or as otherwise required to ensure compliance with applicable laws and regulations. Reasonable security measures have been applied to prevent unauthorized or accidental access, processing, erasure, loss or use including limiting physical access to data within our systems and encryption of sensitive data when transferring such data.


8.2     Reasonable steps will be taken to delete or destroy the information when it is no longer necessary for any of the purposes above.


9     Who may be provided with your Personal Data

9.1     Personal data will be kept confidential but may, where permitted by law or where such disclosure is necessary to satisfy the purpose or a directly related purpose for which the personal data was collected, provide such personal data to the following parties: -

(a)  any personal authorized to act as an agent of 2BeGuru in relation to the services offered by 2BeGuru;

(b) any agent, contractor or third-party service provider (within or outside 2BeGuru) who provides administration, data processing, telecommunications, computer, payment, debt collection or securities clearing, technology outsourcing, mailing and printing services in connection with the operation of our business and our provision of services to you;

(c)  any member company of 2BeGuru in relation to the provision or marketing of our services;

(d) any subsidiary company, associated company and/or affiliate company of 2BeGuru (including but not limited to ROCK Training Consultants Limited (研石企業管理咨詢有限公司), 3 CIRCLES VR LEARNING SOLUTIONS LIMITED (川品虛擬學習有限公司), Lime Knowledge Technology Asia Limited (來問知識科技有限公司) and Rock Training Consultants China Limited in relation to the provision or marketing of our services;

(e) any agent, contractor or third-party service provider (within or outside 2BeGuru) including companies that help deliver our services;

(f)  other companies that help gather your information or communicate with you, such as research companies, in order to enhance the services we provide to you; and

(g) government or regulatory bodies in any jurisdiction or any person to whom the 2BeGuru must disclose data:

(i) under a legal and/or regulatory obligation in that or any other jurisdiction applicable to that particular company; or

(ii)  pursuant to an agreement between that particular company and the relevant government, regulatory body or other person.

(h)  Our partners in joint promotional activities, and

(i) Persons who may be entitled to disclosure under circumstances described in Part 8 of the PDPO (meaning personal data exempt from Data Protection Principal 3 of the PDPO). 


10   How We Protect Your Data [Please confirm]

10.1  Personal data supplied by you will be retained in one or more of our databases and in different formats and be secured with restricted access by our authorized personnel through appropriate security protocols for authentication and authorization, including but not limited to the use of SSL/TLS, encryption, firewalls and data backup.


10.2  Your personal data will be kept in the strictest confidence and for a reasonable period necessary to attain the purposes specified in this Privacy Policy unless otherwise required or permitted by law.


11   Overseas Transfers

Your personal data may be transferred to countries outside the Hong Kong Special Administrative Region (HKSAR) that do have similar protections in place regarding your personal data and restrictions on its use as set out in this Policy.


12 Access & Correction of your Personal Data

12.1 You have rights to request access to your personal data which we have in our possession or under our control at any time.


12.2  We are also endeavor to ensure your personal information is accurate and up to date. We may request, or upon your request, make corrections to your personal data or remove information which is inaccurate.


13   Sale of Business

From time to time, we may purchase a business or sell one or more of our business (or portions thereof) and your personal data may be transferred or disclosed as part of the purchase or sale or a proposed purchase or sale. In the event that we purchase a business, the personal data received with that business would be treated in accordance with this Policy if it is practicable and permissible to do so.


14 Your Consent and Withdraw

14.1 By submitting your personal information you consent to the use of that information as set out in this Policy.


14.2 You may at any time withdraw your consent for our collection, use, disclose, process and/or storage of your personal data by contacting us through ways specified in “How to Contact Us” Section.


14.3  Please note however that depending on the nature and extent of the consent which you seek to withdraw, this may affect our ability to continue with our provision of Services to you. Where our ability to continue such Services is adversely affected, this may result in the termination of any/all contractual arrangements we have with you.


15  Amendments to this Policy

We reserve the right, at any time, to add to, change, update or modify this Policy, simply by notifying you of such change, update or modification. If we decide to change our personal data policy, those changes will be notified on our website [and/or Apps] so that you are always aware of what information we collect, how we use the information and under what circumstances the information is disclosed. Any such change, update or modification will be effective immediately upon posting.


16    How to contact us

If you have nay questions relating to this Policy or your personal data, or would like to make any requests concerning your personal data, please contact us using the contact information provided below:-


The Data Protection Officer

2BeGuru Company Limited (軲轆軲轆有限公司)

Room 712, 7/F,

Kwong Sang Hong Centre,

151-153 Hoi Bun Road,

Kwun Tong,


Hong Kong.

Email: [ [email protected]  ]


17    External Links

If any part of this website contains links to other websites, those sites may not operate under this Policy. You are advised to check the privacy policy on those websites to understand their policies on the collection, usage, transferal, disclosure and storage of personal data.