Privacy Policy

1. Introduction

Kelmere ("we", "us", "our") is committed to handling personal data responsibly and in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO"). This Policy explains what personal data we collect, how we use it, and the rights you have in relation to your data.

This Policy applies to personal data collected via our website at {{DOMAIN_NAME}}, through our contact forms, and in the course of our business relationships. If you have questions, contact us at privacy@{{DOMAIN_NAME}}.

2. What Personal Data We Collect

We may collect the following categories of personal data:

• Contact information: name, email address, telephone number
• Business information: company name, job title, nature of enquiry
• Website usage data: IP address, browser type, pages visited, time on site (via analytics cookies where consented)
• Communications: content of messages sent through our contact form or by email

We collect personal data only when you provide it voluntarily — for example, by submitting our contact form — or when it is generated automatically by your use of our website.

3. How We Use Your Personal Data

We use personal data for the following purposes:

• Responding to enquiries and communicating about potential or current engagements
• Delivering consulting services where an engagement has been agreed
• Improving our website and understanding how it is used (analytics, with consent)
• Complying with legal and regulatory obligations applicable in Hong Kong

We do not sell personal data to third parties. We do not use personal data for unsolicited marketing without your prior consent.

4. Legal Basis for Processing

Under the PDPO, we rely on the following grounds for processing personal data: your consent (for analytics cookies and direct marketing, where applicable); the performance of a contract or pre-contractual steps; and our legitimate interests in operating and improving our business, where these are not overridden by your interests.

5. Data Sharing

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

• Service providers who assist us in operating our website or conducting our business (e.g., hosting, analytics), bound by appropriate data processing agreements
• Professional advisors or counterparties, where necessary for the delivery of a specific engagement and with your knowledge
• Where required by law, regulation, or a court order in Hong Kong

6. Data Retention

We retain personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Enquiry data is typically retained for 24 months from last contact. Engagement-related data is retained for six years from the end of the engagement, in line with standard professional practice in Hong Kong.

7. Cookies

Our website uses cookies. Essential cookies are necessary for the site to function and cannot be disabled. Optional cookies (analytics, preferences, marketing) are only activated with your consent. See our Cookie Policy for full details and your preference controls.

8. Data Security

We implement reasonable technical and organisational measures to protect personal data from unauthorised access, disclosure, alteration, or destruction. These include access controls, encrypted storage and transmission where appropriate, and regular review of data handling practices. In the event of a data breach that may affect your rights, we will notify affected individuals in accordance with PDPO requirements.

9. Your Rights

Under the PDPO, you have the right to:

• Request access to personal data we hold about you (Data Access Request)
• Request correction of inaccurate or incomplete personal data
• Request erasure of personal data where no longer necessary for its original purpose
• Withdraw consent to processing at any time, where processing is based on consent
• Lodge a complaint with the Privacy Commissioner for Personal Data (PCPD) in Hong Kong

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

10. Children's Privacy

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

11. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their respective privacy policies.

12. Policy Updates

We may update this Policy from time to time to reflect changes in our practices or applicable law. The updated version will be posted on this page with a revised "Last Updated" date. Continued use of our website after any changes constitutes acceptance of the updated Policy.

13. Contact Information

For privacy-related enquiries or to exercise your rights:

• Email: privacy@{{DOMAIN_NAME}}
• Address: 4/F, Nexxus Building, 41 Connaught Road Central, Central, Hong Kong
• Phone: +852 3195 6428

The Privacy Commissioner for Personal Data (PCPD) can be reached at www.pcpd.org.hk.