The Certified Strategic Marketer® programme is operated by The Outwit Company Limited (“we”, “us”, “our”), a company registered in the Hong Kong Special Administrative Region. For the purposes of the Personal Data (Privacy) Ordinance (the “Ordinance” or “PDPO”), we are the data user responsible for the personal data described in this policy.

We collect personal data in three ways: information you give us, information created as you use the programme, and information collected automatically when you visit our website.

Providing personal data is voluntary, but some data is necessary to create an account, process a purchase or issue a certificate. If you choose not to provide it, we may be unable to deliver the programme to you.

We use personal data only for purposes directly related to running the programme and our business, namely to:

We will not use your personal data for a new purpose unless that purpose is directly related to the one for which it was collected, or unless we obtain your consent.

We may use your name and email address to send you information about our courses, offers and related content. In line with the Ordinance, we will only do so where you have not objected, and we will always tell you clearly how to opt out.

We do not sell your personal data. We share it only with the service providers that help us operate the programme, and only to the extent needed for them to perform their role. These include:

These providers act on our instructions and are required to keep your data secure and use it only for the services they provide to us. We may also disclose personal data where required by law, a court order, or a request from a regulator or law-enforcement authority.

Some of our service providers store or process data on servers outside Hong Kong. Where personal data is transferred outside Hong Kong, we take reasonable steps to ensure it continues to be protected to a standard comparable with the Ordinance, including through the contractual terms we hold with those providers.

Our website uses cookies and similar technologies. Strictly necessary cookies keep the site working and secure. Analytics cookies, including those set by Google Analytics, help us measure traffic and improve the site; the data they generate is aggregated and does not identify you directly.

We keep personal data only for as long as necessary for the purposes set out in this policy. Your access to the programme runs for six months from enrolment. We retain your account and certification records for a reasonable period after that to verify your certification and meet our legal and accounting obligations, after which we securely delete or anonymise the data.

We take practicable steps to protect personal data against unauthorised or accidental access, loss, use or disclosure. These include encryption in transit, restricted access to accounts and records, and relying on reputable service providers that maintain their own security controls. No online service can be guaranteed to be completely secure, but we work to protect your data and to respond promptly to any incident.

Under the Ordinance you have the right to:

To make a data access or correction request, email us at info@outwitcompany.com. We will respond within 40 days, as required by the Ordinance. We may charge a reasonable fee for complying with a data access request. If we cannot meet a request in full, we will tell you why.

The programme is intended for working professionals. It is not directed at children, and we do not knowingly collect personal data from anyone under 18. If you believe a minor has provided us with personal data, please contact us and we will delete it.

We may update this policy from time to time to reflect changes in our practices or the law. When we do, we will revise the “last updated” date above and, where the change is significant, we will take reasonable steps to notify you.

For any question about this policy or about how we handle your personal data, please contact: