1. Our Commitment
HK Web Systems Dev Limited (“we”, “us” or “our”), a company incorporated in Hong Kong, is committed to protecting the privacy, confidentiality and security of the personal data we hold. We comply with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of the laws of Hong Kong (the “Ordinance”) and its Data Protection Principles, and we require our staff and service providers to do the same.
This Privacy Policy Statement explains what personal data we collect, why we collect it, how we use and protect it, and the rights you have in relation to it. It applies to personal data collected through this website (hkwebsys.com) and in the course of our business dealings with clients, prospective clients and suppliers.
2. Personal Data We Collect
We only collect personal data that is necessary for our business activities. This may include:
- Enquiry data – your name, email address, the subject and content of your message, and any other information you choose to provide through our contact form or by email;
- Business contact data – name, job title, company name, business address, email address and telephone number of contact persons at our clients, prospective clients, partners and suppliers;
- Contract and billing data – information needed to enter into and perform service agreements, issue invoices and maintain accounting records;
- Technical data – IP address, browser type and settings, operating system, referring pages and pages visited on this website, collected automatically as described in Section 4.
We do not intentionally collect sensitive personal data (such as health information or identity card numbers) through this website. Please do not submit such information through our contact form.
3. Purposes of Use
Personal data we collect will be used for the following purposes:
- responding to your enquiries and providing information or quotations you request;
- entering into, performing and managing contracts for our web development, e-commerce, cloud/IT and consulting services;
- communicating with you about projects, support, maintenance and service notices;
- invoicing, accounting, record-keeping and business administration;
- maintaining the security, operation and improvement of this website and our systems;
- complying with legal, regulatory and audit requirements applicable to us, including requests from banks, auditors or government authorities that we are legally obliged to meet.
We will not use your personal data for any purpose other than the above or a directly related purpose without your prior voluntary and express consent.
4. Website Visits & Cookies
Server logs
When you visit this website, our web server automatically records technical information such as your IP address, browser type, operating system, date and time of access and the pages visited. We use this information only for maintaining the security of the website, diagnosing technical problems and compiling aggregate statistics to improve the website. We do not use it to identify individual visitors.
Cookies
Cookies are small text files stored on your device by your browser. This website itself does not use cookies to identify you or to track you across other websites.
Our Contact page displays an embedded map provided by Google. Google may set its own cookies and collect information (such as your IP address) when the map loads, in accordance with Google’s Privacy Policy.
Most browsers accept cookies by default. You can refuse or delete cookies by changing your browser settings. If you do so, you can still browse this website, although the embedded map may not display correctly.
5. Disclosure & Transfer of Personal Data
We do not sell, rent or trade your personal data. We will keep your personal data confidential, but may provide it to the following classes of persons where necessary for the purposes in Section 3:
- IT and hosting service providers – data centre, cloud hosting, email and website hosting providers that store or process data on our behalf;
- Professional advisers – our accountants, auditors, company secretary and lawyers;
- Banks and payment institutions – for the purpose of receiving and making payments and meeting their compliance requirements;
- Subcontractors engaged by us to deliver part of a client project, where you are informed of this in the relevant service agreement;
- Government, regulatory and law enforcement authorities – where required or permitted by law or court order.
Where we engage a service provider to process personal data on our behalf, we adopt contractual or other means to require that provider to keep the data secure and confidential, to use it only for the purposes we specify, and not to retain it longer than necessary.
6. Transfers Outside Hong Kong
As we serve clients in Asia and Europe and work with hosting and cloud infrastructure providers located in Europe, your personal data may be stored or processed in places outside Hong Kong, including member states of the European Union. When we transfer personal data outside Hong Kong, we take reasonably practicable steps — including contractual safeguards with reference to the Privacy Commissioner’s Recommended Model Contractual Clauses — to ensure that the data receives a level of protection comparable to that required under the Ordinance.
7. Direct Marketing
We do not use your personal data for direct marketing, and we do not provide your personal data to any other person for use in direct marketing. Should we wish to do so in the future, we will first notify you and obtain your consent as required under Part 6A of the Ordinance, and you may withdraw your consent at any time free of charge.
8. Security Measures
We take reasonably practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use, including:
- encryption of data transmitted through this website using SSL/TLS (HTTPS);
- access to personal data restricted to authorised staff on a need-to-know basis;
- password protection, access control and security updates on our systems and hosting environments;
- regular backups and the use of reputable hosting and cloud providers;
- confidentiality obligations for staff and contractors who handle personal data.
In the event of a data breach that is likely to cause harm to the individuals concerned, we will take prompt steps to contain it and will notify the affected individuals and, where appropriate, the Office of the Privacy Commissioner for Personal Data.
9. Retention of Personal Data
We keep personal data only for as long as necessary to fulfil the purposes for which it was collected. In general, enquiry data that does not lead to a business relationship is deleted within [24] months of our last communication. Contract, billing and accounting records are retained for at least seven years as required under Hong Kong law (including the Companies Ordinance and the Inland Revenue Ordinance). After the retention period, personal data is securely deleted or destroyed.
10. Your Rights of Access and Correction
Under the Ordinance, you have the right to:
- check whether we hold your personal data;
- request access to a copy of your personal data held by us;
- request the correction of any personal data that is inaccurate;
- ascertain our policies and practices in relation to personal data and the kinds of personal data we hold.
Requests should be made in writing to our Data Protection Officer (see Section 15). You may use the Data Access Request Form (OPS003) published by the Office of the Privacy Commissioner for Personal Data. We may need to verify your identity before processing a request, and we will respond within 40 days of receiving it as required by the Ordinance. In accordance with the Ordinance, we may charge a fee for processing a data access request; any such fee will not be excessive.
11. Visitors and Clients in the EEA / UK
If you are located in the European Economic Area or the United Kingdom, we process your personal data on the basis of (a) the performance of a contract with you or steps taken at your request before entering into a contract, (b) our legitimate interests in operating our business and responding to enquiries, or (c) compliance with legal obligations. In addition to the rights above, you may have the right to request erasure or restriction of processing, to object to processing, to data portability, and to lodge a complaint with your local data protection authority. Please contact us to exercise these rights.
12. Minors
Our services are intended for businesses. This website is not directed at persons under 18, and we do not knowingly collect personal data from minors.
13. Third-Party Websites
This website may contain links to websites operated by third parties. We are not responsible for the privacy practices of those websites, and we encourage you to read their privacy policies.
14. Changes to This Policy
We may update this Privacy Policy Statement from time to time. The updated version will be posted on this page with a revised “Last updated” date.
15. Contact Us
Enquiries about this policy, and requests for access to or correction of personal data, should be addressed to:
Data Protection Officer
HK Web Systems Dev Limited
Personal Information Collection Statement (Contact Form)
- The personal data you provide through our contact form (name, email address, subject and message) will be used to respond to your enquiry and, where applicable, to prepare proposals and enter into a business relationship with you.
- Fields marked with an asterisk (*) are obligatory. If you do not provide this information, we may not be able to respond to your enquiry.
- Your personal data may be transferred to our IT, email and hosting service providers for the above purposes, as described in Section 5. It will not be used for direct marketing.
- You have the right to request access to and correction of your personal data. Please contact our Data Protection Officer at the address above or at .