Privacy Policy

1. Your data

   1. Website support / enquiry information (information we receive when you get in touch with us via our website):

      • Name;
      • Work email address and, if you choose to provide it, phone number;
      • The company or organisation you are contacting us on behalf of;
      • Details of your enquiry, such as the service you are interested in, your project goal, target launch timing and budget range; and
      • The page of the Website from which you submitted the form.

      How we use it

      In line with the legitimate interest we have in promoting our business, we will process your enquiries to provide you with information about the services we offer.

      This might include replying to your enquiry. We may also process enquiries to take steps you ask of us with a view to entering into an agreement to provide you with our services.

      You are under no obligation to provide us with any details, but if you don’t provide all relevant information, we may not be able to help.

      Third Party Recipients

      Google (Google Sheets and Google Apps Script, used to receive and store enquiries submitted through our contact form).

      Website analytics and usage information

      (collected automatically when you visit the Website):

      When you visit our Website, we collect log and analytical information, such as your anonymised internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform and other technology on the devices you use.

      How we use it

      We process this information to understand how visitors use our Website and to compile statistical reports regarding that activity (for example, your IP address is anonymised and then used to approximate the country from which you access our Website. We aggregate this information together so we know that, for example, most of the visitors to our Website are in Hong Kong). In many cases the data would be aggregated and/or anonymised so that it would not identify you.

      Where this processing requires consent to the use of cookies or similar technologies, we process this information on the basis of consent. Otherwise we rely on the basis we are pursuing our legitimate interest of understanding the use of our Website and in order to run our business.

      Third Party Recipients

      Google (Google Analytics, our website analytics provider, and Google’s advertising services linked to it, which help us measure our advertising and may be used to show our ads to people who have visited the Website). Google may process this data outside of Hong Kong.

      Meta Platforms (Meta Pixel, which helps us measure how our advertising on Facebook and Instagram performs, including whether a visit leads to an enquiry through our contact form, and may be used to show our ads to people who have visited the Website). When you submit an enquiry, we also send the same event to Meta from our server through Meta’s Conversions API, together with your IP address, browser information and the Meta Pixel cookie identifiers, so the enquiry can still be measured if the Pixel is blocked in your browser. We do not send your name, email address, phone number or message to Meta. Meta may process this data outside of Hong Kong.

      Vercel, our website hosting provider, which processes technical server logs (such as IP address and browser type) to deliver and secure the Website.

2. Your rights in relation to your personal data

   1. You have certain rights over the way we process personal data relating to you. We aim to comply without undue delay, and within one month at the latest, in response to any requests submitted by you to us:

      • for a copy of personal data we are processing about you and/or to have inaccuracies corrected;
      • to restrict, stop processing, or to delete your personal data;
      • for a machine-readable copy of your personal data, which you can use with another service provider. Where it is technically feasible, you can ask us to send this information directly to another provider if you prefer; and
      • to make a complaint to a data protection regulator. You may contact them at: the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD): https://www.pcpd.org.hk
   2. To make a request in relation to any of the aforementioned rights, please submit your request via the Contact form on our Website.
   3. You may request deletion of your personal data by submitting a request via the Contact form on our Website. Please note that some information may remain in our private records after deletion. We may use any aggregated data derived from or incorporating your personal data but not in any manner that would identify you personally.

3. Disclosure of your personal data

   1. We will share your personal data with third parties only in the ways that are described in this Policy.
   2. Group, suppliers, subcontractors, service providers. We keep your personal data confidential, but may disclose it to any member of our corporate group, our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy.
   3. Government authorities. In addition, we may disclose your personal data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).
   4. Potential acquirers or investors. If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the personal data we hold may be included as part of that sale, in which case you will be notified via email and/or a prominent notice on the Website of any changes in ownership or use of your personal data, as well as any choices you may have.
   5. Enforcement. We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of us, our personnel or customers, or others.
   6. We only permit our suppliers and subcontractors to process your personal data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your personal data.

4. Data Retention

   1. We will only hold data about you for as long as necessary, bearing in mind the purpose for which that data was collected, or as otherwise described in this Policy.
   2. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

5. Security

   1. We will take commercially reasonable, appropriate technical and organisational measures to ensure a level of security appropriate to the risk that could be encountered via the use of our Website taking into account the likelihood and severity those risks might pose to the rights and freedoms of our Website visitors and customers.
   2. In particular, we will take precautions to protect against the accidental or unlawful destruction, loss or alteration, and unauthorised disclosure of or access to the personal data transmitted, stored or otherwise processed by us.

6. International Data Transfers

   1. Where necessary, there are agreements in place to ensure that personal data is processed using appropriate safeguards that meet the requirements of data protection laws. Such appropriate safeguards may include standard data protection clauses adopted by a data protection regulator and approved by the European Commission, such as the European Commission’s standard contractual clauses, or other appropriate measures.
   2. If you would like to find out more about these safeguards or if you have any other queries or comments in relation to this Policy, please let us know via the Contact form on our Website.

7. Children

   1. We do not use the Website to knowingly solicit data from or market to children. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, they should contact us via the Contact form on our Website. We will delete such information within a reasonable time.

8. General

   1. If you follow a link from the Website to any third party websites, you should be aware that those websites may have their own privacy policies. We do not accept any responsibility or liability for those websites. Please check the policies of any third party websites before submitting any personal data to those websites.
   2. We may make changes to this Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes by email.
   3. All questions, comments or enquiries should be directed to us. We will respond to you within a reasonable time.

Contact us

You can reach us via the Contact form on our Website.