Privacy Policy

1. Data Controller

halcorazxx Advisory Limited is the data controller for personal data collected through this website and during our consulting engagements. Our registered office is at 28/F, Two Pacific Place, 88 Queensway, Admiralty, Hong Kong. For data-related enquiries, contact us at privacy@{{DOMAIN}}.

2. Personal Data We Collect

We collect personal data through the following channels:

• Website enquiry form: Name, email address, phone number (optional), message content.
• Consulting engagements: Contact details, organisational information, and commercially sensitive data provided in the course of an engagement. This data is covered separately under engagement confidentiality agreements.
• Cookies and analytics: Technical data including IP address, browser type, pages visited, and time on site — collected only with your consent. See our Cookie Policy for details.

3. How We Use Personal Data

Personal data collected via this website is used to:

• Respond to your enquiry and arrange an initial conversation
• Conduct the preliminary assessment relevant to your stated consulting interest
• Send you information relevant to your stated area of interest, where you have consented
• Improve the functionality and content of this website (with analytics consent)
• Comply with our legal obligations under Hong Kong law

We do not use personal data for unsolicited marketing. We do not sell or transfer personal data to third parties for commercial purposes.

4. Legal Basis for Processing

Under the PDPO, personal data collected through our website is processed on the basis of: (a) your consent, where explicitly provided; (b) the performance of pre-contractual steps at your request; (c) our legitimate interests in responding to business enquiries. Personal data processed during consulting engagements is governed by the terms of the relevant engagement agreement.

5. Data Retention

Website enquiry data is retained for a maximum of 24 months from the date of submission unless an engagement commences, in which case retention is extended to seven years from engagement completion for legal compliance purposes. Analytics data is retained in aggregated form for up to 26 months.

6. Data Security

Personal data is stored on secure servers with access limited to authorised personnel. Data transmitted via our contact form is encrypted in transit using TLS. We conduct regular reviews of our data handling practices. In the event of a data breach that poses risk to the individuals concerned, we will notify affected parties and the relevant authorities as required under applicable law.

7. Cookies

We use cookies for essential functionality and, with your consent, for analytics. You can manage your cookie preferences at any time via our Cookie Policy page. Withdrawing consent for non-essential cookies does not affect website functionality.

8. Third-Party Services

With your consent to analytics cookies, data may be processed by:

• Google Analytics (website usage analytics)
• Google Maps (location display on our website)

These services operate under their own privacy policies. We do not share personal data with these services beyond what is technically required for their function.

9. Third-Party Links

This website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.

10. Your Rights Under the PDPO

Under the Personal Data (Privacy) Ordinance, 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 personal data for direct marketing
• Withdraw consent where processing is based on consent
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data Hong Kong (PCPD)

To exercise any of these rights, contact us at privacy@{{DOMAIN}}. We will respond within 40 days as required by the PDPO.

11. Children's Privacy

Our services are intended for business professionals and organisations. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that we have inadvertently collected such data, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via this page with an updated effective date. Continued use of our website after changes are posted constitutes acceptance of the revised policy.

13. Contact for Privacy Matters

For questions about this Privacy Policy or your personal data, contact us at: