Expivotal Consultancy strictly complies with the Personal Data (Privacy) Ordinance (PDPO), Chapter 486 of the Laws of Hong Kong. Expivotal Consultancy will ensure compliance by following the highest standards of security and confidentiality in respect of all personal information and data submitted by the Users of Expivotal Consultancy (“Users”) via the Site.

Users are strongly recommended to read this Privacy Policy Statement carefully to have a clear understanding of Expivotal Consultancy’s policy and practices regarding the collection and use of Users’ personal information and data on the Site. The Privacy Policy Statement is applicable to all Users, and the terms herein may be updated, revised, and amended from time to time as Expivotal Consultancy may consider necessary and/or appropriate.

To properly perform Expivotal Consultancy Services (“Services”), it may be necessary for Users to provide Expivotal Consultancy with their personal information and/or data. Failure to provide such personal information and/or data may result in Expivotal Consultancy being unable to provide the Services to Users. The Policy set out hereunder regarding the use of personal information and/or data is applicable to all Services provided and maintained by Expivotal Consultancy.

In this Privacy Policy Statement, the following terms shall have the respective meanings specified below unless the context otherwise requires:

• “Expivotal Consultancy” refers to Expivotal Consultancy Limited
• “User(s)” refers to users who have access to the site and receive services offered by Expivotal Consultancy
• “Site” refers to any website, member portal owned and operated by Expivotal Consultancy
• “POLAR Assessment” refers to personality-based competency assessment constructed by Expivotal Consultancy

By registering for or using the Service, User hereby agrees to:

• Expivotal Consultancy collecting, using, disclosing and/or processing Users’ personal data for the purposes as described below;
• Expivotal Consultancy disclosing Users’ personal data to third-party service providers or agents (whether within or outside Hong Kong) for the purposes as described below and;
• that any information provided by User to Expivotal Consultancy is on a voluntary basis and is true, accurate, and complete. If this is not the case or Expivotal Consultancy has reasonable grounds to suspect as such, Expivotal Consultancy has the right to cancel and/or refuse providing Services to User

What personal data we collect

Whether you are a customer, supplier or other business contact, respondent, or staff, we will collect and use your personal data in the manner and for the reasons set out in this Privacy Policy.  We collect most personal data directly from you however if we collect personal data indirectly, we refer to this explicitly in this Privacy Policy.  We have listed the types of personal data likely to be collected from persons according to the relationship that person has with us as follows:

• Identity data (including full name, username or similar identifier, title/ gender, region)
• Contact data (including billing address, delivery address, email address, telephone numbers)
• Financial data (including bank account, payment card details)
• Transaction data (including details about payments to and from you and/or your organisation and other details of products and services you have purchased from us)
• Technical data (including internet protocol (IP) address, login data, browser type and version and other technology on the device used to access our websites websites and other platforms, systems and technologies made available by us)
• Profile data (including username, password, purchases or orders made by you, your interests, preferences, feedback and survey responses)
• Usage data (including information about how you use our websites, products and services)
• Marketing and communications data (including your preferences in receiving marketing from us and your communication and cookie preferences)

• where provided within responses to optional questions in the POLAR Assessment:
  • Age
  • Qualification
  • Nationality
  • Ethnic origin
  • Employment status
  • Occupational level
  • Job type

Data will be collected in order for Users to receive or supply products and services, as applicable, to manage contractual relationships on an ongoing basis, for account administration, and to provide updates and news about our products and services, events and other information that we think may be of interest to you. We also collect data through the use of cookies. You can find more information on cookies in section 4.3 and our Cookies Statement.  

Data will also be collected from respondents taking our psychometric assessment questionnaires to complete the questionnaire, and for scoring and report generation.  Additionally, where feedback is given and/or where you participate in an assessment or development centre or other consultancy engagement run by Expivotal Consultancy, additional data to that set out above may be provided by you and this will be collected by a practitioner and/or associated organisation or our team, respectively, and used for the purposes of provision of services. 

How and when we collect your personal data

Data will be collected: 

• prior to, at commencement, and during the term of a contractual relationship when you request our products and services
• when you complete forms on our site or for our products and services, including registering to use our site, subscribing to our services, or using further services
• when you enter a competition or promotion sponsored by us
• when you contact us or report a problem to us, or provide feedback to us, or complete a survey
• when you transact with us through our website or when you place orders with us over the phone or by email

Respondents

Data will be collected when you complete a psychometric assessment questionnaire via SurveyPlanet or otherwise. Data may also be collected from your associated organisation. Where feedback is given and/ or where you participate in an assessment or development centre or other consultancy engagement run by Expivotal Consultancy, additional data to that set out above may be provided by you to the practitioner and/or associated organisation or our team respectively, at the time of such feedback, assessment or engagement. 

Visitors to the Site

Simply visiting the Site does not require you to submit personal data (although our cookies may collect certain personal data for statistical and analytical purposes). If however you ask us for information, register with us, sign up to attend any of our events or virtual offerings receive our marketing material or otherwise express an interest in our products or services or report a problem, via our website or other platforms and technologies made available by us, we collect any personal data submitted to us at that time.

How and why we use your personal data

Personal data of Users (including Identity, Contact, Technical, Usage and Profile Data) will be used:

• to provide you with products and services that you request from us
• to manage our contractual relationship on an ongoing basis
• for customer administration including carrying out our obligations arising from any contracts entered into between you and us and including retention of correspondence if you contact us
• to provide, on request from practitioners and/or your associated organisation, personalised computer-generated reports from completion by respondents of our psychometric assessment questionnaires, including via our web-based scoring and delivery platform, SurveyPlant, or otherwise.  Sometimes we may combine respondent data with that of other respondents, for example to create team reports
• where feedback is given, for the purposes of the feedback session between the respondent and practitioner
• where you participate in an assessment or development centre or other consultancy engagement run by our team, additional data provided by you may be used for the purposes of provision of our services
• for research and product development purposes. Such data is collected through completion of our psychometric assessment questionnaires, including via SurveyPlant or otherwise, for research and product development purposes in order to produce statistics of the type described in our technical product manuals, e.g. psychometric norms and validity data. You may be asked, as part of the testing process, to give your consent to the use of your personal data for research and product development purposes, and to answer additional optional research questions. If you decline from doing so, certain data is not collected or used for research and product development purposes. If you do consent, the personal data collected may include special category data where you have submitted such but this will only be disclosed to third parties or published in the form of aggregated data, so no person will be identified or identifiable.
• for us to form a view on what we think you may want or need, or what products, services or offers may be of interest to you (referred to as marketing) in order to provide you with information about our other products and services in which you may be interested, including our catalogue, where you have not opted-out to be contacted for such purposes
• to personalise our service to you, including ensuring that content from our site is presented in the most effective manner for you and your computer
• to seek your views on products and services
• to enable you to participate in interactive features of our service, when you choose to do so, including live chat features
• for technical administration of our sites including notifying you about changes to our service
• with further information on our products and services

Who we transfer your personal data to

We share your personal data with third parties and for the purposes as set out below:

Third parties (acting as processors):

• suppliers who provide IT, database and system administration services as well as suppliers providing web, logistics, event organisation, video-conference facilities and other technologies or services to you connected to the service we provide
• associates and partners based in Europe who provide training services on our behalf
• enquirers requiring information about practitioners’ certification
• professional advisers including lawyers, bankers, auditors, debt collection agencies and insurers who provide banking, legal, insurance and accounting services
• suppliers who provide analytics services
• potential acquirers to whom our business or business assets may be transferred
• law enforcement agencies or regulators where we believe, in good faith, that it is necessary to comply with the law or regulatory obligation or to protect the safety of The Myers-Briggs Company, our customers or their clients, or the public or to enforce or apply our terms of business or other contracts

Third parties (acting as controllers):

• where a respondent completes one of our psychometric assessments under the direction of a practitioner, we will share the respondent’s results with that practitioner in order that they may give appropriate feedback to the respondent. The practitioner may also share the results or a summary, with another practitioner within the same organisation employing the respondent, as applicable and with the organisation employing the respondent as applicable
• where a respondent also attends an assessment or development centre and/or consultancy engagement run by our team, personal data may be shared with the practitioner from our team, with another practitioner within the same organisation employing the respondent, as applicable, and with the organisation employing the respondent as applicable
• where respondent data is combined with that of other respondents, for example for the purposes of team reports, this may be similarly shared
• enquirers requiring information about practitioners’ certification (including customer organisations by whom practitioners are employed)

We require all third party suppliers to respect the security of your personal data and to treat it in accordance with the law. We do not allow our suppliers to use your data for their own purposes, and we require that processing is in accordance with our instructions. We enter into written data processing agreements with suppliers that receive personal data from us.

Cookies and Log Files

Expivotal Consultancy does not collect any personally identifiable information from any Users whilst they visit and browse the Site. When Users access the Site, Expivotal Consultancy records their visits only and does not collect their personal information or data. The Site’s server software will also record the domain name, server, address and track the pages Users visit and store such information in “cookies”, and gather and store information like internet protocol (IP) addresses, browser type, referring/exit pages, operating system, date/time stamp, and clickstream data in log files. All these are done without the Users being aware that they are occurring.

Users can choose to accept or decline cookies. Most web browsers automatically accept cookies, but Users can modify their individual browser settings to decline cookies if they prefer. However, Users should note that disabling cookies on their browser may prevent them from taking full advantage of the Site.

Expivotal Consultancy does not link the information and data automatically collected in the above manner to any personally identifiable information. Expivotal Consultancy generally uses such automatically collected information and data to estimate the audience size of the Site, gauge the popularity of various parts of the Site, track Users’ movements and the number of entries in Expivotal Consultancy’s promotional activities and special events, and measure Users’ traffic patterns and administer the Site. Such automatically collected information and data will not be disclosed except in accordance with the section headed “Who we transfer your personal data to”.

How we keep your data secure

Expivotal Consultancy values the security of Users’ personal information and data and therefore will strive to protect Users’ personal information and data against unauthorized access. Expivotal Consultancy has implemented appropriate electronic and managerial measures in order to safeguard, protect and secure Users’ personal information and data.

All personal information and data provided by Users are only accessible by the authorised personnel of Expivotal Consultancy or its authorised third parties, and such personnel shall be instructed to observe the terms of this Privacy Policy Statement when accessing such personal information and data. Users may rest assured that their personal information and data will only be kept for as long as is necessary to fulfil the purpose for which it is collected. Registered User should safeguard his/her unique username and password by keeping it secret and confidential and never share these details with anyone.

Expivotal Consultancy follows generally accepted industry standards to protect the personal information and data submitted by Users to the Site, both during transmission and once Expivotal Consultancy receives it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while Expivotal Consultancy strives to protect Users’ personal information and data against unauthorised access, Expivotal Consultancy cannot guarantee its absolute security.

Request for Correction Data

Any User is entitled to request access to or make amendments to his/her own personal information and data kept with Expivotal Consultancy by contacting the Customer Service Executive of Expivotal Consultancy at whose contact details are set out under the section headed “Enquiries”. In the event that a User wishes to access or amend his/her personal information and data, Expivotal Consultancy may request him/her to provide personal details in order to verify and confirm his/her identity. Identity card number or passport number or business registration certificate number or details in POLAR assessment report cannot be amended unless such data is proved to be inaccurate. Expivotal Consultancy is required to respond to User’s requests within 40 days of his/her request but Expivotal Consultancy reserves the rights to charge the User a reasonable fee for doing so.

Retention of Personal Data

Once Expivotal Consultancy has obtained a User’s personal information and/or data, it will be maintained securely in Expivotal Consultancy’s system for the period necessary to fulfil the purposes for which the data was collected as set out under the section headed “How and why we use your personal data”. Expivotal Consultancy may retain User’s personal information even after the User has requested to remove their information if retention is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between Users, prevent fraud and abuse, or enforce this Privacy Policy Statement and the Terms and Conditions.

Changes in this Privacy Policy Statement

Expivotal Consultancy reserves the right to update, revise, modify or amend this Privacy Policy Statement at any time as Expivotal Consultancy considers necessary, so Users are strongly recommended to review this Privacy Policy Statement frequently. If Expivotal Consultancy decides to update, revise, modify or amend this Privacy Policy Statement, Expivotal Consultancy will post those changes to this webpage and/or other places Expivotal Consultancy considers appropriate so that Users would be aware of what information does Expivotal Consultancy collect, how does Expivotal Consultancy use it, and under what circumstances, if any, Expivotal Consultancy discloses it.

If Expivotal Consultancy makes material changes to this Privacy Policy Statement, Expivotal Consultancy will notify Users on this webpage, by email, or by means of a notice on the homepage of Expivotal Consultancy and/or take further action as required by law. To the extent permitted by law, such changes to this Privacy Policy Statement shall apply from the time that Expivotal Consultancy posts the same on this webpage, and Users’ continued use of the Site and services on the Site shall constitute acceptance of the changes to this Privacy Policy Statement.

Enquiries

Should you have any enquiries relating to this Privacy Statement, please email the Customer Service Department of Expivotal Consultancy at info@expivotal.com.