Privacy Policy
Last Updated: 3 February 2025 | Pagoda Edge Consulting
1. Introduction
Pagoda Edge ("we", "us", "our") is committed to responsible handling of personal data in line with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) (PDPO). This policy explains what data we collect, why we collect it, how we use it, and the rights available to you. It applies to all personal data processed through our website, our contact forms, and in the course of client engagements.
2. Data We Collect
We may collect the following types of personal data:
- Name and job title
- Email address and telephone number
- Organisation name and address
- Message content submitted through our contact form
- Website usage data collected via cookies and analytics tools (see Section 7)
We collect only what is necessary for the purposes described below. We do not collect sensitive personal data (as defined under the PDPO) unless explicitly required and agreed in writing for specific engagements.
3. How We Use Your Data
- Responding to enquiries submitted through our contact form
- Scoping, managing, and delivering consulting engagements
- Sending service-related communications (engagement updates, invoices)
- Improving our website and understanding how it is used
- Complying with legal obligations
We do not use your data for unsolicited marketing. Any direct marketing would require your explicit consent and would be subject to a clear opt-out mechanism.
4. Legal Basis for Processing
Processing is carried out under one or more of the following bases as recognised under the PDPO and applicable guidance: consent (when you submit a contact form), performance of a contract (when an engagement is underway), compliance with a legal obligation, and our legitimate interests in operating and improving our consulting practice — balanced against your rights and expectations.
5. Data Retention
We retain personal data only for as long as necessary. Enquiry data from contacts who do not proceed to engagement is deleted within 12 months. Client engagement data is retained for seven years following completion to comply with standard commercial record-keeping obligations. Website analytics data is retained in aggregated, anonymised form indefinitely.
6. Data Sharing
We do not sell, rent, or share your personal data with third parties for their own purposes. We may share data with service providers who process it on our behalf (for example, email hosting or analytics tools) under data processing agreements that require appropriate protections. We may disclose data where required by law.
7. Cookies and Analytics
Our website uses cookies to understand how visitors interact with it. This may include tools such as Google Analytics, which processes usage data on our behalf. You can manage your cookie preferences through the banner on our homepage or via our Cookie Policy.
8. Data Security
We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. Our website uses HTTPS encryption. Access to personal data within our team is restricted to those with a legitimate need. We review our security practices periodically.
9. Your Rights
Under the PDPO, you have the right to:
- Request access to personal data we hold about you
- Request correction of inaccurate data
- Request deletion of your data where we have no legal basis to retain it
- Object to processing for direct marketing
- Withdraw consent where processing is based on consent
- Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong
To exercise these rights, contact us at [email protected]. We will respond within 40 days as required by the PDPO.
10. External Links
Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.
11. Children's Privacy
Our services are directed at business organisations and professionals. We do not knowingly collect personal data from individuals under 18 years of age.
12. Changes to This Policy
We may update this policy from time to time. Changes will be published on this page with a revised date. Continued use of our website or services following any update constitutes acceptance of the revised policy.
13. Contact
For data-related enquiries or to exercise your rights, please contact: [email protected]
Pagoda Edge Consulting
Unit 03, 20th Floor, Sovereign Court
173 Yee Wo Street, Causeway Bay, Hong Kong