Project Heha – Privacy Policy Statement

Last updated: 7 June 2021

Project Heha Limited (“Project Heha”, “our company” and “we”) are committed to protecting the privacy of your personal data.

In order to provide better service and handle the orders submitted by users, users are advised to regularly check the latest published version of this Privacy Policy Statement. This Privacy Policy Statement aims to explain what personal data our company collects from you, how they would be used and the relevant privacy policy adopted by our company.

Please refer to the latest Privacy Policy Statement. By continuing to visit this website, you agree to accept and be bound by this Privacy Policy Statement.

1. Our commitment to privacy protection

Project Heha respect your privacy and will ensure its services comply with the requirements of the Personal Data (Privacy) Ordinance (Cap.486) of the Hong Kong Special Administrative Region (“HKSAR”). For more information, please visit the official website of the Office of the Privacy Commissioner for Personal Data (

2. What personal data do we collect?

“Personal data” refers to information that can identify an individual, it includes but not limited to:

  1. Your personal data and contact information, such as name, gender, date of birth, phone number, social media links, email address, occupation/position, address, mailing address and/or billing address and profile picture;
  2. Your business information, such as company name and title;
  3. Your bank account information, such as bank account number or username and PayMe information;
  4. The IP address of your computer or mobile device, information relating to your live locations, browser settings, browsing records and/or other internet records;
  5. Your phone book including phone numbers and email addresses in it. When you provide your phone book contacts to us, you confirm that you have obtained consent from the contacts; and
  6. Data collected by other technologies of cookies.

3. How do we collect personal data?

We collect personal data by different means, including but not limited to:

3.1 Provided voluntarily by users

Users can share their personal data with us through various ways, including:

(1) Registration for our workshops;

(2) Participation in our activities;

(3) Purchase of any products or books through Project Heha; and

(4) Interaction with us through other ways which share personal data.

When users choose to provide their personal data by any of the above means, it means that they give consent to us to retain and handle their personal data in accordance with this Privacy Policy Statement.

3.2 Saved automatically

When users visit our website, we receive and save certain information. For example, “cookies”, cookies allow server to transmit data to computers or devices for retaining records and other purposes.  If users do not want their data to be collected by Cookies, users may refuse the use of cookies, but this may affect the use and experience of this website by users. By continuing to visit this website, you agree to the use of cookies.   For more details, please visit

In order to provide a smooth and convenient usage to our users, certain information will be saved automatically. Such information is anonymous and, under normal circumstances, is not able to identify the user. Examples of such information are, IP address and/or URL, browser type and its settings, language, location, computer operation system, browsing time or other related information.

3.3 Through user’s browser or device:

Certain data is data collected by most browsers or personal data automatically collected through the user’s device. We will use this data for statistical purpose and to ensure the smooth operation of this website.

4. Why do we collect personal data and what is it for?

We have appropriate procedures to ensure the personal data provided by users is handled legally, fairly and transparently. The personal data that we collect from or provided by users may be used for one or more of the following purposes (and subject to the user’s prior consent (which includes indication of no objection) in certain circumstances) to support our mission to “co-create a happier world”:

(1) To handle and respond to the user’s order, issue invoice and to maintain and manage the daily operation of orders;

(2) To follow up the information or service request provided by users to Project Heha through any means;

(3) To handle and respond to user’s inquiries, opinions, applications, complaints, suggestions, payment or payment arrears;

(4) To allow this website to save user’s personal data so that they do not need to enter the information as requested every time they make purchase or request service;

(5) To confirm users’ participation in courses;

(6) To provide better service, conduct market research, statistical and behavioral analysis or random telephone interview;

(7) To mail workshop materials, tools or gift to users;

(8) To distribute internal communications or electronic newsletter to users to encourage ongoing mindset and habit change;

(9) To allow users to find out our updates, activities and courses;

(10) To collect suggestions or opinions from users for the mission of co-creating a happier world;

(11) To help improving our website and to upgrade the quality of our projects and related services by analyzing personal data;

(12) When permitted or required by law or regulation or as requested by government authorities, to use user’s data for the protection of persons or property, or to establish or exercise our legal rights, or to defend, claim in legal claims and/or commence legal proceedings;

(13) For audit purpose; and

(14) For direct marketing. Unless we have obtained your consent or an indication of no objection, we will not use your personal data for direct marketing. Even if you do not object to the use of your personal data for direct marketing now, you may opt out of direct marketing from us at any time by contacting us at   

Personal data retention

We will retain your personal data only for so long as is necessary for fulfilling the purpose for which they were collected. Personal data that is no longer needed will be destroyed.

5. Personal data security

We use reasonable organization, technology and management measures to protect the personal data controlled by us. Nevertheless, there is no guarantee on the security of the information transmitted in our website. Our company is not able to guarantee the security of the personal data transmitted by you in this website. The transmission of such data is at your own risk. When we receive the personal data transmitted by you, only our designated employees or vendors could access your personal data.

6. Transaction security

When users order products, books or services from our website, Project Heha shall use the user’s personal data listed in this Privacy Policy Statement to process the said order or provide relevant services. We endeavor to ensure the data related to the transaction is handled legally, fairly and transparently.

7. Personal data transfer/disclosure

In order to provide services to the users, we may transfer/disclose users’ personal data to the business partners of Project Heha, including but not limited to our technical and personal database consultants, legal and financial consultants etc., and all service providers working with us. Unless authorized by us and the user or permitted by law, the user’s personal data shall not be sold to a third party or used for direct marketing purposes.

Without the express consent from users, we will not disclose to any organization the personal data provided to us by the users.

8. Access or update personal data

Users have the right to access or update their personal data kept by us. Please contact us via email  at to access or update your personal data.

For processing any personal data access or update request, our company reserves the right to charge a reasonable fee.

9. Links to other websites

Our website contains links to other websites and resources, when clicking on these links to leave our website, users should be aware that we do not exercise any control over these other websites. As such, we shall not be responsible for protecting any data provided by users and their privacy while visiting those websites. Those websites are not bound by this Privacy Policy Statement. Users are advised to check the relevant privacy policy statement of those website.

10. Revision and update of this Privacy Policy Statement

Project Heha may update, revise and/or make addition to this Privacy Policy Statement from time to time. Users are advised to regularly check the latest published version of this Privacy Policy Statement.

11. Contact us
If user has any questions about this Privacy Policy Statement, please contact us via email at

We take the privacy of users seriously and will do our best to respond to any questions raised.

The English translation is for reference only. In case of any discrepancy between the English version and the Chinese version, the Chinese version shall prevail.

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