Privacy Policy

1. Introduction

abeerdeenl ("we", "us", "our") is committed to protecting the personal data of individuals who interact with us. This Privacy Policy explains how we collect, use, store, and protect personal information in connection with our consulting services and website.

This policy applies to all personal data collected through our website at abeerdeenl.info, through contact forms, and during the course of consulting engagements. It is governed by the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO").

abeerdeenl acts as data controller for personal data processed under this policy. For questions, contact us at [email protected].

2. Data We Collect

2.1 Information You Provide

When you submit our contact form or communicate with us, we may collect your full name, email address, phone number (where provided), and the content of your message or enquiry.

2.2 Information Collected Automatically

When you visit our website, technical data may be collected including your IP address, browser type, pages visited, time and date of access, and referring URLs. This data is used for website performance analysis and security monitoring only.

2.3 Data Collected During Engagements

When we conduct a consulting engagement, we may collect and process organisational and commercially sensitive information shared by you and your colleagues. This information is handled under the confidentiality terms agreed at the outset of each engagement and is not used for any purpose other than service delivery.

2.4 Legal Basis for Processing

We process personal data on the following lawful grounds under the PDPO: your consent (where explicitly given), the performance of a contract or pre-contractual steps, our legitimate interests in operating a consulting business, and compliance with applicable legal obligations.

3. How We Use Your Data

3.1 Service Delivery

Personal data provided through contact forms is used to respond to your enquiry, arrange scoping conversations, and, where an engagement proceeds, deliver the agreed services. We do not share this data with third parties for marketing purposes.

3.2 Communications

We may contact you by email or phone in connection with your enquiry or ongoing engagement. We do not send unsolicited marketing communications. If you receive a communication from us that you did not request, you may opt out at any time by contacting [email protected].

3.3 Analytics

Where analytics cookies are accepted, anonymised usage data is collected to help us understand how visitors use the website. This data is aggregated and does not identify individual users.

3.4 Data Retention

Enquiry data is retained for 24 months from the date of last contact, unless an engagement commences, in which case the data is retained for 7 years from the end of the engagement in accordance with standard professional practice. Analytics data is retained for no more than 26 months.

3.5 Data Sharing

We do not sell personal data. We may share data with trusted service providers who assist in operating our website and business (such as email hosting and analytics platforms), subject to appropriate data processing agreements. We do not share personal data with any third party for their own marketing purposes.

4. Data Protection Measures

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

• Encrypted data transmission (HTTPS)
• Access controls limiting data access to authorised personnel only
• Regular review of data handling procedures
• Confidentiality obligations on all personnel and contractors
• Secure deletion of data at the end of its retention period

In the event of a data breach that is likely to result in significant harm, we will notify affected individuals and, where required, the Office of the Privacy Commissioner for Personal Data (PCPD) in accordance with the PDPO.

5. Cookies

Our website uses cookies to support its operation and, where you consent, to collect analytics data. Cookies are small text files stored on your device. We use the following categories:

• Essential cookies: Required for core site functionality. Always active.
• Analytics cookies: Collect anonymised data on how the site is used. Active only with your consent.
• Preference cookies: Remember your settings between visits. Active only with your consent.
• Marketing cookies: Used to personalise advertising. Active only with your consent.

You can manage your cookie preferences at any time via our Cookie Policy page.

6. Your Rights

Under the PDPO, you have the right to:

• Access: Request a copy of personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Erasure: Request deletion of your personal data, subject to applicable legal obligations
• Objection: Object to processing of your data for specific purposes
• Withdrawal of consent: Where processing is based on consent, withdraw it at any time without affecting prior processing
• Complaint: Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days as required by the PDPO. There is no charge for making a request, though we may charge a reasonable fee for manifestly excessive or repetitive requests.

7. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites and recommend that you review their privacy policies independently. The inclusion of a link does not imply our endorsement.

8. Children's Privacy

Our services are directed to organisations and business professionals. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected such data, please contact us immediately at [email protected] and we will delete it promptly.

9. Policy Updates

We review this Privacy Policy periodically and may update it to reflect changes in our practices or applicable law. The date of the most recent revision is noted at the top of this document. Continued use of our website following a policy update constitutes acceptance of the revised terms. We will notify users of material changes via a notice on our website.

10. Contact Information

For questions, requests, or complaints regarding this Privacy Policy or the handling of your personal data:

• Email: [email protected]
• Address: Unit 12, 22nd Floor, Crown Court, 129 Portland Street, Mong Kok, Hong Kong
• Phone: +852 6350 6523

If you are not satisfied with our response, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk.