PRIVACY POLICY
私隱政策

This Privacy Policy explains how Cogni Solutions Limited, trading as Triplicity Astrology 占星館, collects, uses, stores, and protects your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO"). Please read this policy carefully before using our websites or Platform.


1. Who We Are / Data Controller

Legal entity

Cogni Solutions Limited

Trading name

Triplicity Astrology 占星館

Jurisdiction

Hong Kong Special Administrative Region

Contact email

hello@triplicityastrology.com

Main website

triplicityastrology.com

Academy

academy.triplicityastrology.com



Cogni Solutions Limited is the data controller responsible for your personal data collected through our websites and the Academy Platform. We are committed to protecting your privacy and handling your personal data in accordance with the PDPO and applicable Hong Kong law.

2. What Personal Data We Collect

2.1 Data You Provide Directly
When you interact with our websites or Platform, you may provide us with:

Account registration data: full name, email address, and password
Profile information: display name (which appears on your certificate — we encourage use of your full legal name for this reason)
Purchase information: billing name, email address, and payment card details (processed directly by Stripe — we do not store card numbers)
Assignment submissions: written work, chart analyses, case studies, and any files you upload as part of your coursework
Birth details: date, time, and place of birth submitted voluntarily by Tier 3 students for personal chart preparation
Inquiry form submissions: name, email, background information, and course interests submitted via our contact or enrolment inquiry forms
Community posts: messages, comments, and content you post in our LearnWorlds Spaces community
Email correspondence: any emails you send to hello@triplicityastrology.com

2.2 Data Collected Automatically
When you visit our websites or use the Platform, we automatically collect:

Device and browser information: IP address, browser type and version, operating system, device type
Usage data: pages visited, time spent on pages, links clicked, course lessons accessed, video watch progress
Cookie data: as described in our Cookie Policy above
Transaction data: purchase history, access periods, and enrolment records

2.3 Data From Third Parties
If you choose to register or log in using Google (Google OAuth), we receive your name and email address from Google as part of the authentication process. We do not receive your Google password.

3. How We Use Your Personal Data

We use your personal data for the following purposes, each of which has a lawful basis under the PDPO:

Purpose

Details

Account creation and management

To create and manage your student account on the Platform, authenticate your identity, and provide you with access to purchased Courses.

Course delivery

To enrol you in Courses, track your learning progress, deliver Content, process assignment submissions, and issue certificates upon completion.

Payment processing

To process your purchase transactions securely through Stripe. Card details are transmitted directly to Stripe and never stored by us.

Communications

To send you enrolment confirmations, course access notifications, expiry reminders, certificate award notifications, and responses to your inquiries.

Community management

To facilitate your participation in our LearnWorlds Spaces community, including displaying your posts and profile to other community members.

Personal chart preparation (Tier 3)

To generate a personalised natal chart PDF for Tier 3 students who submit their birth details. Birth details are used solely for this purpose.

Platform improvement

To analyse how students use the Platform using aggregated, anonymised data, enabling us to improve our courses, interface, and user experience.

Legal compliance

To comply with applicable Hong Kong laws and regulations, respond to lawful requests from authorities, and enforce our Terms and Conditions.

Security and fraud prevention

To detect, investigate, and prevent fraudulent transactions, unauthorised access, and other illegal activities on the Platform.



4. Birth Details — Special Note for Tier 3 Students

Tier 3 students who opt to submit their birth details (date, time, and place of birth) for personal chart preparation do so voluntarily. This information is sensitive personal data and is handled with heightened care:


Birth details are used solely to generate your personalised natal chart and for no other purpose.
Birth details are not shared with any third party other than the astrology chart generation tool used to produce the chart (astro.com or equivalent).
Birth details are not added to marketing lists or used for any purpose beyond chart preparation.
If you wish to have your birth details deleted from our records, please contact hello@triplicityastrology.com and we will delete them within 14 days.

5. Who We Share Your Data With

We do not sell, rent, or trade your personal data to any third party for commercial purposes. We share your data only with the following trusted service providers, solely to the extent necessary to operate the Platform and provide our services:

Provider

Role

Data Shared

LearnWorlds

Learning management system (Platform host)

Name, email, course progress, assignment data, community posts. LearnWorlds hosts and processes all Platform data under their data processing agreement.

Stripe

Payment processor

Name, email, billing address, and payment card details — transmitted directly by your browser to Stripe. We receive only a transaction confirmation reference.

Google Analytics

Website analytics

Anonymised usage data via cookies. No personally identifiable information is shared with Google Analytics.

Google (OAuth)

Authentication service (if Google login used)

Email and name received from Google when you authenticate using Google login. We do not share data back to Google for marketing purposes.

MailerLite

Email marketing platform (when activated)

Name and email address of students who have enrolled in courses, for sending course-related and promotional emails. Unsubscribe links are included in all marketing emails.



All third-party service providers are required to handle your data in accordance with applicable data protection laws. We do not authorise any service provider to use your data for their own purposes beyond the services they provide to us.

6. How Long We Keep Your Data

Data Type

Retention Period

Account data (name, email)

For the duration of your account plus 3 years after account closure, or longer if required by law.

Course progress and completion data

For the duration of your account plus 3 years, to support certificate verification requests.

Assignment submissions

For the duration of your account plus 3 years.

Payment and transaction records

7 years from the date of transaction, in accordance with Hong Kong tax and accounting obligations.

Certificate records

Indefinitely, to support verification of issued credentials.

Birth details (Tier 3)

Until you request deletion, or until 12 months after your last active course access, whichever is earlier.

Community posts

For the duration of your account. If your account is closed, posts may be anonymised rather than deleted to preserve community discussion integrity.

Email correspondence

3 years from the date of the last communication.

Website analytics data

26 months (Google Analytics default retention period).



7. How We Protect Your Data

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

HTTPS encryption on all web properties (triplicityastrology.com and academy.triplicityastrology.com)
Secure password hashing — passwords are never stored in plain text
Payment data handled exclusively by Stripe under PCI-DSS Level 1 certification — we never handle or store raw card numbers
Access to student data is restricted to authorised personnel only
The Platform is hosted by LearnWorlds on secure cloud infrastructure

While we take all reasonable precautions, no method of data transmission over the internet is 100% secure. We cannot guarantee the absolute security of data transmitted to or from our websites. You transmit data at your own risk, and we encourage you to use a secure and private internet connection when accessing the Platform.

8. Your Data Rights Under the PDPO

Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, you have the following rights in relation to your personal data:

Your Right

What It Means

Right of access

You have the right to request a copy of the personal data we hold about you.

Right of correction

You have the right to request correction of any inaccurate or incomplete personal data we hold about you.

Right to delete

You may request deletion of your personal data. Note that we may be required to retain certain data for legal, accounting, or fraud prevention purposes even after an account closure request.

Right to object

You may object to our processing of your personal data for direct marketing purposes at any time. You may unsubscribe from marketing emails at any time using the unsubscribe link in any such email.

Right to data portability

You may request a copy of your personal data in a structured, commonly used format where technically feasible.

Right to complain

You have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong if you believe your data rights have been violated. Website: pcpd.org.hk



To exercise any of these rights, please contact us at hello@triplicityastrology.com with the subject line 'Data Rights Request'. We will respond within 40 days as required by the PDPO. We may ask you to verify your identity before processing your request.

9. Children's Privacy

Triplicity Astrology does not impose a minimum age restriction on enrolment. However, if a student is under the age of 18, we strongly recommend that a parent or guardian review these policies and supervise the student's use of the Platform. We do not knowingly market our Courses or Memberships to children. If you believe that a child under the age of 18 has provided us with personal data without appropriate parental consent, please contact us at hello@triplicityastrology.com and we will take appropriate steps to address the matter.

10. International Data Transfers

Our Platform is hosted by LearnWorlds, which may process and store data on servers located outside Hong Kong, including in the European Union and the United States. Stripe, Google, and MailerLite similarly operate internationally. When your data is transferred internationally, it is subject to the data protection laws of the countries in which those providers operate.

We ensure that any international transfer of your personal data is carried out with appropriate safeguards, including contractual data processing agreements with our service providers that require them to protect your data to at least the standard required by Hong Kong law.

11. Third-Party Websites and Links

Our websites and Platform may contain links to third-party websites, including YouTube, external astrology resources, and other educational tools. We are not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies only to our websites and Platform. We encourage you to review the privacy policies of any third-party websites you visit.

12. Direct Marketing

We may use your name and email address to send you information about our Courses, new content releases, promotions, and other Academy-related news. We will only do so where you have enrolled in a Course or Membership (giving rise to a legitimate interest in communicating with you as a student) or where you have opted in to receive marketing communications.

You may opt out of marketing communications at any time by:

Clicking the 'Unsubscribe' link in any marketing email we send you
Emailing hello@triplicityastrology.com with the subject line 'Unsubscribe'

Please note that opting out of marketing emails will not affect transactional emails related to your active courses or account (such as enrolment confirmations, expiry reminders, and certificate notifications) — you will continue to receive those.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make material changes, we will update the 'Last updated' date at the top of this document and, where the changes are significant, notify you by email. Your continued use of our websites or Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

14. Contact Us and How to Complain

If you have any questions, concerns, or requests relating to this Privacy Policy or our handling of your personal data, please contact us:

Entity

Cogni Solutions Limited

Trading as

Triplicity Astrology 占星館

Email

hello@triplicityastrology.com

Response time

Within 40 days of receipt (as required by the PDPO)


If you are not satisfied with our response, or believe that we have not complied with the PDPO, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD):

Name
Office of the Privacy Commissioner for Personal Data
Website
pcpd.org.hk
Phone
+852 2827 2827
Address
Units 1303-1305, 13/F, Dah Sing Financial Centre, 248 Queen's Road East, Wan Chai, Hong Kong


Both policies on this document are issued by Cogni Solutions Limited, trading as Triplicity Astrology 占星館.
For all privacy and cookie inquiries: hello@triplicityastrology.com
Governed by the laws of the Hong Kong Special Administrative Region.


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