This Privacy Policy was last updated on June 22, 2017.

Geoswift Limited and its subsidiaries and affiliates (“Geoswift”, “we”, “us”, “our”, and similar terms) respects your privacy and values the confidence of its customers, partners, and employees. This Privacy Policy explains, among other things, the types of information collected about you when you visit Geoswift sites and (the “Websites”), how your information may be used and when it may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.

Geoswift complies with the data protection principles and all relevant provisions of the Hong Kong Personal Data (Privacy) Ordinance. In doing so, we will ensure that all Geoswift employees and third party service providers/partners involved in handling personal data comply with appropriate standards of security and confidentiality.

This Privacy Policy applies to Geoswift Websites, as well as any online services that link to this Privacy Policy (the “Services”). Please read the entire Privacy Policy before using our Services. By using the Services, you agree to abide by the terms of this Privacy Policy.

If you have questions or concerns about our Privacy Policy or practices, please contact us at [email protected] If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact TRUSTe at

1. Personal Information Collection

Nature and Purpose of the Collection

In order to carry out some of our Services, we may collect the following personal information from you on one or more of our Websites covered under this Privacy Policy:

  • Payment information for transfer of funds on, including payment reference number, name, student id, national id number, email address, phone number, and date of birth.
  • Your email address, physical address, company name and telephone number.

In addition, we may also collect the following third party personal information from you, should the identity of the payer be different from the student, as part of our transfer services offered on

  • Third party’s Chinese name
  • Third party’s China National ID number
  • Third party’s China phone number

We may use information that we collect through the Services for a variety of purposes, including to:

  1. Processing various service applications, including financial services requested on;
  2. Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
  3. Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
  4. Contact you via email and otherwise about products, services, and events that we believe might be of interest to you;
  5. Customize and personalize your use of the Services; and
  6. As otherwise described to you at the point of collection or pursuant to your consent.

Sharing of Information

We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. Again, we will not sell your personal information to any third parties.

We may share some or all of your personal data with the following parties and for the following purposes:

  • Corporate Parents, Affiliates, and Subsidiaries. We may share your information with our subsidiaries and other affiliated entities for a variety of purposes, including for business and operational purposes.
  • Service Providers. We may share your information with service providers that perform certain functions or services on our behalf (such as to host the services or manage databases). These third parties are authorized to use your personal information only as necessary to provide these services to us.
  • Various government agencies and/or officials as required by law or as necessary to protect our business and services. We may disclose your information to third parties in order to protect the legal rights, safety, and security of Geoswift and/or any of our affiliates and subsidiaries, and the users of our Services, including sharing data and information within Geoswift or its related associates and/or any other use of data and information in accordance with any group-wide programs for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities; investigate fraud, enforce our Terms of Use; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement, legal process or a request for cooperation by a government or other entity, whether or not legally required.
  • In Connection with a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction. You will be notified via email and/or prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
  • Other Parties with Your Consent. We may share information about you with third parties when you consent to such sharing or as required by law, including when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tools.

Any disclosures in connection with requirements of the law or as necessary to protect the services, the obligations and/or requirements shall stem from the following basis:

  • Any law binding or applying to it within or outside the Hong Kong Special Administrative Region existing currently and in the future;
  • Any guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers within or outside the Hong Kong Special Administrative Region existing currently and in the future;
  • Any present or future contractual or other commitment with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on Geoswift of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;

2. Use of Cookies, Log Files and Other Tracking Technologies


Cookies are small data files which are placed on data subject’s device when data subject visit certain parts of Geoswift’s Website or click on Geoswift’s online advertisements.

Cookies and similar technologies are used to identify data subject’s device for the following purposes:

1. Essential cookies. These essential cookies are set throughout Geoswift’s Website and are required for the operation of the Website to:

  • allow Geoswift’s web server to determine whether the cookies setting on data subject’s web browser has been enabled or disabled. This allows Geoswift to know whether data can be collected from data subject’s web browser;
  • temporarily allow data subject to retain certain information/preferences between pages of Geoswift’s Website to avoid having to re-enter that information;
  • temporarily identify data subject’s device after data subject has logged in to a secure page on Geoswift’s Website so that Geoswift’s web server can maintain a dialogue with data subject’s web browser in order for data subject to carry out certain activities.

2. Analytical/performance cookies. These are used to help Geoswift improve Geoswift’s Website by tracking data subject’s visits to Geoswift’s Website and recognizing data subject’s web browser when data subject is repeat visitor so that Geoswift can gather statistics on new and repeat visitors to evaluate site effectiveness.

3. Functionality cookies. These are used to recognize data subject when data subject return to Geoswift’s Website. This enables Geoswift to:

  • personalize content for data subject and remember his/her preferences (for example, choice of language and region);
  • store his/her login and other preferences so he/she does not have to re-enter that information when he/she returns to Geoswift’s Website.

4. Targeting / Advertising cookies. These cookies record data subject’s visits to Geoswift’s Website, his/her response to Geoswift’s online advertisements, track the pages he/she have visited and the website links he/she have followed. Geoswift use this information to:

  • make Geoswift’s Website more relevant to data subject’s interests;
  • provide online advertisements or offers on Geoswift’s Website or third-party websites which are most likely to interest he/she;
  • evaluate the effectiveness of Geoswift’s online marketing and advertising programs.

The above cookies may be placed on data subject’s device by Geoswift or by third parties on Geoswift’s behalf (for example, advertising networks and providers of external services like web traffic analysis services). Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites in order to provide you tailored advertisements based on your browsing activities and interests. If you wish to not have this information used for the purpose of serving your interest-based ads, you may contact us at [email protected] No personally identifiable information about data subject is collected or shared with third parties as a result of this.

Most web browsers are initially set up to accept cookies. If you do not want information collected through the use of cookies, there is a simple procedure in most browsers that allows you to decline the use of cookies. Please be aware that if you reject cookies or other similar technologies, you may still use our Website, but your ability to use some features or areas of our site may be limited. To learn more about cookies, please visit

Log Files and Other Tracking Technologies

As true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you.

In addition to cookies, technologies such as beacons and scripts are used by Geoswift and our third-party service providers who may use these technologies to collect information that helps us with traffic measurement, research, and analytics. We will use these types of technologies to analyze trends, administer the sites, track users’ movements throughout the sites, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

3. Personal Information Security

Geoswift takes all reasonably practicable means to protect the data, such as, by restricting the access of data by authorized personnel only and incorporating security measures into equipment in which data is held. Encryption technology is employed for sensitive data transmission.

We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide to us. Security procedures include, restricting the access of data by authorized personnel only and incorporating security measures into equipment in which data is held. Encryption technology is employed for sensitive data transmission.
However, please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while we strive to protect your information and privacy, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information. If you have any questions about the security of your personal information, you can contact us at [email protected]

We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements.

4. Social Media Features (Widgets)

Our Services includes Social Media Features, such as the Twitter and LinkedIn follow icons. These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the privacy policy of the company providing the Feature.

5. Co-Branding

Geoswift and its branding partner work in coordination with each other to provide tuition payment services to customers in China. Personally identifiable information may be passed between partners for the purpose of effecting payment to the beneficiary. In the event unusual or activity is detected, an investigation may also lead to the sharing of personal information between branding partners. In the event customers would like to limit the sharing of information, Geoswift can be contacted as indicated in Sections 8 and Section 9 below.

6. Minors

We do not knowingly collect, use, or disclose personal information from children under the age of 13. We request that these individuals do not submit such information to us. If you believe that we have inadvertently collected the information of a child, please contact us at [email protected]

7. Privacy Policy Updates

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by means of a notice on our site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

8. Links to Third Party Sites

The Services may contain links to other websites or online services that may be operated and maintained by Geoswift or third parties and that are not under the control of or maintained by Geoswift. This Privacy Policy does not apply to this third-party content. We encourage you to review the privacy policies of these third-party websites or services.

9. Your Choices and Your Information

Geoswift provides you with the ability to review and correct certain information that you have provided to us. If you wish to update or delete inaccuracies within your contact information that you provided to us, you may contact us at [email protected] We will respond to your access request within 30 days.
You may also “opt-out” of receiving promotional or marketing communications by using the unsubscribe feature included in the emails that we send, or contact us at [email protected] Should you later request to receive promotional or marketing communications, that request will override this opt-out.

10. Contact Us

If you have any questions about this Privacy Policy, you may contact us at +852 2312 2168, by e-mail at [email protected], or by mail to Suite 2116 – 2118, The Metropolis Tower, 10 Metropolis Drive, Hung Hom, Kowloon, Hong Kong. Please ensure you include this in your inquiry: Attention: Compliance Department.