Legal

Privacy Policy

Last Updated: 12 March 2025 · Effective: 12 March 2025

Vossway ("we", "us", "our") is a business consulting firm registered in Hong Kong. This Privacy Policy explains how we collect, use, store, and protect personal data in connection with our website and consulting services. It is prepared in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO").

If you have questions about this Policy, contact us at [email protected].

1. Data We Collect

We collect personal data only when it is necessary for a defined purpose. This may include:

• Contact information: name, email address, telephone number, provided via our contact form or during scoping discussions
• Organisation details: employer name, role, or sector context shared during engagement enquiries
• Communication records: correspondence by email or telephone related to service enquiries or active engagements
• Website usage data: IP address, browser type, pages visited, session duration — collected via analytics cookies where consent has been given

We do not collect sensitive personal data (such as financial account details, identification numbers, or health information) through the website.

2. How We Use Your Data

Personal data is used for the following purposes:

• Responding to enquiries and scoping engagement conversations
• Managing active consulting engagements and delivering contracted services
• Maintaining records of correspondence for operational purposes
• Improving the functionality and relevance of our website (analytics, with consent)
• Complying with applicable legal obligations in Hong Kong

We do not use your data for unsolicited marketing communications. We will not share your data with third parties for their own marketing purposes.

3. Legal Basis for Processing

We process personal data on the following bases:

• Consent: for analytics cookies and any optional communications you've opted into
• Contract performance: to fulfil obligations under a consulting engagement agreement
• Legitimate interests: to respond to enquiries and manage our business operations
• Legal obligation: where required by Hong Kong law

4. Data Retention

We retain personal data for no longer than necessary:

• Enquiry data (not leading to an engagement): up to 12 months
• Engagement-related correspondence and documents: up to 7 years after engagement conclusion, in accordance with Hong Kong statutory requirements
• Analytics data: aggregated and anonymised; session-level data up to 26 months

5. Data Sharing

We do not sell personal data. Data may be shared with:

• Service providers: email delivery, website hosting, and analytics providers operating under appropriate data processing agreements
• Professional advisers: where legally required, such as legal or accounting services
• Regulatory authorities: where required by applicable Hong Kong law

Where data is transferred outside Hong Kong, we take steps to ensure appropriate protections are in place consistent with PDPO requirements.

6. Data Security

We maintain technical and organisational measures to protect personal data, including:

• Encrypted transmission (HTTPS) for all website communications
• Access controls limiting internal access to personal data to those who require it
• Secure storage practices for engagement documentation
• Processes for identifying and responding to data incidents

7. Cookies

Our website uses cookies to understand how visitors engage with the site and to maintain user preferences. Please see our Cookie Policy for full details including how to manage your preferences.

8. Your Rights Under PDPO

Under the Personal Data (Privacy) Ordinance, you have the right to:

• Request confirmation of whether we hold personal data about you
• Access the personal data we hold about you
• Request correction of inaccurate personal data
• Object to or restrict processing in certain circumstances
• Withdraw consent where processing is based on consent

To exercise any of these rights, contact us at [email protected]. We will respond within the timeframe required by applicable law.

You may also raise a concern with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.

9. Third-Party Links

Our website may contain links to third-party sites. We are not responsible for the privacy practices or content of those sites. We encourage you to review their privacy policies before providing any personal data.

10. Children's Privacy

Our services are directed at business professionals and organisations. We do not knowingly collect personal data from individuals under the age of 18.

11. Changes to This Policy

We may update this Policy from time to time. Material changes will be communicated via a notice on our website. Continued use of the site after changes constitutes acceptance of the updated Policy. The date of the most recent revision is shown at the top of this document.

12. Contact

Data Controller: Vossway
15/F, China Hong Kong Tower, 8-12 Hennessy Road, Wan Chai, Hong Kong
Email: [email protected]