Privacy Policy

1. Introduction

Cossway ("we", "us", "our") is committed to protecting the privacy of individuals who interact with our business. This Privacy Policy explains how we collect, use, store, and protect personal data in connection with our consulting services and website. We operate under the laws of the Hong Kong Special Administrative Region, including the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

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

2. Data We Collect

We may collect the following types of personal data:

Information you provide directly: When you contact us via our website form, email, or phone, we may collect your name, email address, phone number, company name, and any details you include in your message.

Engagement-related data: During consulting engagements, we may collect business information, strategic documents, and other materials shared by your organisation for the purposes of delivering our services.

Website usage data: We use cookies and similar technologies to collect information about how you interact with our website, including pages visited, time spent, browser type, and referring URL. See our Cookie Policy for more details.

3. How We Use Your Data

We use personal data for the following purposes:

Service delivery: To respond to your enquiries, provide consulting services, and manage our client relationships.

Communication: To send you information related to our services, respond to your questions, and provide updates relevant to your engagement.

Website improvement: To understand how visitors use our website and to improve its functionality and content.

Legal compliance: To comply with applicable laws, regulations, and legal processes.

4. Legal Basis for Processing

Under the PDPO, we process personal data based on the following grounds: your consent (where you have provided it, for example by submitting a contact form), the necessity of processing to perform a contract or take steps at your request, and our legitimate business interests where these do not override your rights.

5. Data Sharing

We do not sell or rent your personal data to third parties. We may share data with trusted service providers who assist us in operating our website and conducting our business, such as web hosting providers and analytics services. These providers are contractually required to protect your data and use it only for the purposes we specify. We may also disclose data where required by law or to protect our legal rights.

6. Data Protection Measures

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encrypted data transmission, secure server infrastructure, access controls limiting data access to authorised personnel, and regular review of our security practices.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected. Contact enquiries are retained for up to 24 months. Engagement-related data is retained for up to five years following the conclusion of the engagement, in line with professional and regulatory requirements. Website analytics data is retained for up to 26 months.

8. Cookies

Our website uses cookies to improve your browsing experience. For full details on the types of cookies we use and how to manage your preferences, please visit our Cookie Policy.

9. Your Rights

Under the PDPO, you have the right to request access to the personal data we hold about you, request correction of any inaccurate data, request deletion of your data (subject to legal and contractual obligations), withdraw consent where processing is based on consent, and lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 40 days, as required under the PDPO.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party site you visit.

11. Children's Privacy

Our services are directed at businesses and professionals. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that we have collected data from a minor, we will take steps to delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically.

13. Contact Us

Cossway

28/F, The Centrium, 60 Wyndham Street, Central, Hong Kong

Email: [email protected]

Phone: +852 2573 9148