Privacy Policy

1. Introduction

Axelward ("we", "our", "us") is committed to protecting the personal data of individuals who interact with our website and services. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and applicable data protection principles.

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

2. Data We Collect

We collect personal data in the following circumstances:

• When you submit an enquiry via our website contact form (name, email address, telephone number, and message content)
• When you correspond with us by email or telephone
• When you use our website (technical data such as IP address, browser type, and pages visited, collected via analytics tools)
• When you enter into an engagement with us (business contact information, financial information relevant to the engagement, and documents shared for analysis)

We collect only the data that is necessary for the purpose stated at the point of collection.

3. How We Use Your Data

• To respond to enquiries and provide requested information about our services
• To deliver consulting engagements you have commissioned
• To comply with legal and regulatory obligations
• To understand how our website is used, in order to improve it (analytics, on an aggregated basis)
• To communicate administrative matters relating to active engagements

We do not use personal data for direct marketing without your explicit consent. We do not sell or rent personal data to third parties.

4. Legal Basis for Processing

• Consent: Where you have submitted a contact form or agreed to cookie use
• Contract: Where processing is necessary to perform services you have engaged us for
• Legitimate interests: For general business administration and communication purposes
• Legal obligation: Where required by applicable law

5. Data Retention

We retain personal data only for as long as necessary for the purpose for which it was collected:

• Enquiry data (no engagement resulting): 12 months from receipt
• Engagement records: 7 years from the close of the engagement, in accordance with Hong Kong commercial record-keeping norms
• Website analytics data: Rolling 26-month window

6. Data Sharing

We do not share personal data with third parties except in the following circumstances:

• Service providers assisting our business operations (e.g. secure cloud storage, email hosting) — subject to appropriate data processing agreements
• Professional advisers (accountants, lawyers) where engagement requirements necessitate it — with client awareness
• Regulatory or government authorities where required by law

7. Data Protection Measures

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include:

• Encrypted storage for documents shared during engagements
• Access controls limiting data access to those with a need to know
• Secure deletion of client data at the end of the applicable retention period
• Staff awareness of data handling obligations

8. Cookies

Our website uses cookies to understand how visitors use it. Please see our Cookie Policy for full details on the types of cookies used and how to manage your preferences.

9. Your Rights

Under the PDPO, you have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate personal data
• Object to the use of your data for direct marketing (if applicable)
• Withdraw consent where processing is based on consent

To exercise these rights, contact us at [email protected]. We will respond within 40 days as required by the PDPO.

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

10. International Transfers

We are based in Hong Kong. Where we use service providers located outside Hong Kong, we ensure appropriate data protection standards are maintained consistent with the PDPO.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and recommend reviewing their policies independently.

12. Children

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

13. Changes to This Policy

We may update this policy from time to time. The updated version will be published on this page with a revised "Last Updated" date. We recommend reviewing this page periodically.

14. Contact

Axelward
19/F, Berkshire House, 25 Westlands Road, Quarry Bay, Hong Kong
Email: [email protected]