Privacy Policy

Our Commitment to Your Privacy

Confluenens is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or engage our consulting services.

By using our services or accessing our website, you acknowledge that you have read and understood this Privacy Policy. If you have any questions, please contact us at [email protected].

1. Information We Collect

Personal Information You Provide

When you contact us, request information, or engage our services, we may collect your name, email address, telephone number, company name, job title, and any other information you choose to provide in your correspondence with us.

Information Collected Automatically

When you visit our website, we may automatically collect certain technical information including your IP address, browser type, operating system, referring URLs, pages viewed, and the dates and times of your visits. This information helps us understand how visitors use our website and improve our services.

Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience, analyze website traffic, and understand where our visitors come from. For detailed information about our use of cookies, please see our Cookie Policy.

2. How We Use Your Information

We use the information we collect for the following purposes:

To respond to your inquiries and provide the consulting services you request
To communicate with you about our services, including sending project updates and relevant information
To improve our website, services, and client experience
To comply with legal obligations and protect our legitimate business interests
To analyze website usage patterns and optimize our online presence

3. Legal Basis for Processing

Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and applicable international data protection laws, we process your personal information based on the following legal grounds:

Consent: When you have given clear consent for us to process your personal data for specific purposes
Contract: When processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract
Legitimate Interests: When processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights
Legal Obligation: When processing is necessary for compliance with a legal obligation

4. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

Service Providers: With trusted third-party service providers who assist us in operating our website, conducting our business, or servicing you, provided they agree to keep this information confidential
Legal Requirements: When we believe disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request
Business Transfers: In connection with any merger, acquisition, or sale of company assets, your information may be transferred as part of the business assets
Protection of Rights: When necessary to protect our rights, privacy, safety, or property, or that of our clients or others

5. Data Security

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

Secure data transmission using SSL/TLS encryption
Regular security assessments and updates to our systems
Restricted access to personal information on a need-to-know basis
Confidentiality agreements with employees and contractors who handle personal data

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is completely secure. We cannot provide an absolute assurance of security.

6. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. The retention period may vary depending on the context of the services we provide and our legal obligations.

For client engagement records, we typically retain information for seven years following the completion of services. Website analytics data is generally retained for up to 26 months.

7. Your Rights

Under Hong Kong's Personal Data (Privacy) Ordinance and other applicable data protection laws, you have certain rights regarding your personal information:

Right of Access: You may request access to the personal data we hold about you
Right to Rectification: You may request correction of inaccurate or incomplete personal data
Right to Erasure: In certain circumstances, you may request deletion of your personal data
Right to Object: You may object to certain types of processing, such as direct marketing
Right to Data Portability: You may request a copy of your data in a structured, commonly used format
Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within a reasonable timeframe.

8. Third-Party Links

Our website may contain links to third-party websites or services that are not operated by us. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party sites or services. We encourage you to review the privacy policy of every site you visit.

9. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us so that we can take appropriate action.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will post any changes on this page and update the "Last Updated" date at the top. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.