Privacy Policy

Introduction

Cindra is committed to protecting the privacy and security of personal information entrusted to us by clients, prospective clients, and website visitors. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and international privacy standards.

By using our website or engaging our consulting services, you acknowledge that you have read and understood this Privacy Policy. For questions regarding this policy or our data practices, please contact us at [email protected].

Information We Collect

Personal Information Provided Directly

We collect personal information you provide when:

• Submitting contact forms or consultation requests through our website
• Engaging our consulting services and signing engagement agreements
• Communicating with us via email, phone, or in-person meetings
• Subscribing to newsletters or updates (if applicable)

This information typically includes your name, email address, phone number, company name, job title, and any details you provide about your consulting needs or business challenges.

Automatically Collected Information

When you visit our website, we may automatically collect certain technical information through cookies and similar technologies:

• IP address and general location information
• Browser type and operating system
• Pages visited and time spent on our website
• Referring website addresses

How We Use Your Information

Service Delivery and Communication

We use personal information to:

• Respond to consultation requests and provide information about our services
• Deliver consulting services under engagement agreements
• Communicate about project milestones, deliverables, and engagement matters
• Process payments and maintain financial records
• Provide post-engagement support during the three-month support period

Website Improvement and Analytics

We analyze website usage patterns to improve site functionality, user experience, and content relevance. This analysis uses aggregated, non-personally identifiable data whenever possible.

Legal Compliance

We may use and disclose personal information as necessary to comply with legal obligations, respond to lawful requests from authorities, protect our legal rights, and prevent fraud or security incidents.

Data Sharing and Disclosure

We do not sell personal information to third parties. We may share personal data in the following limited circumstances:

Service Providers

We engage trusted third-party service providers to support business operations, including website hosting, email communications, and payment processing. These providers are contractually obligated to maintain confidentiality and use personal information only for specified purposes.

Professional Advisors

We may share information with legal counsel, accountants, or other professional advisors when necessary to obtain advice or comply with legal obligations.

Business Transfers

In the event of a merger, acquisition, or sale of assets, personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

Data Security Measures

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

• Encryption of data in transit using secure protocols (HTTPS/TLS)
• Access controls limiting employee access to personal information on a need-to-know basis
• Regular security assessments and updates to protection measures
• Secure storage systems with appropriate backup procedures
• Staff training on data protection and confidentiality requirements

While we employ industry-standard security practices, no method of transmission or storage is completely secure. We cannot guarantee absolute security but maintain vigilance in protecting your information.

Cookie Usage

Our website uses cookies and similar technologies to enhance user experience and analyze site usage. Cookies are small text files stored on your device that enable certain website functions and remember your preferences.

We use the following categories of cookies:

• Essential cookies: Required for basic website functionality
• Analytics cookies: Help us understand how visitors use our site
• Preference cookies: Remember your settings and choices

You can manage cookie preferences through your browser settings or our cookie consent tool. For detailed information, please review our Cookie Policy.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Specific retention periods include:

• Client engagement records: Retained for seven years following engagement completion for professional liability and tax compliance purposes
• Contact form submissions: Retained for two years unless you request earlier deletion
• Financial records: Retained in accordance with Hong Kong tax and accounting requirements (typically seven years)
• Marketing communications: Retained until you unsubscribe or request deletion

When personal information is no longer required, we securely delete or anonymize it according to established data disposal procedures.

Your Rights and Choices

Under Hong Kong's Personal Data (Privacy) Ordinance and applicable privacy laws, you have specific rights regarding your personal information:

Access and Correction

You have the right to request access to the personal information we hold about you and to request correction of inaccurate or incomplete data. We will respond to access requests within 40 days as required by Hong Kong law.

Data Portability

You may request a copy of your personal information in a structured, commonly used format for transfer to another service provider.

Erasure and Restriction

You may request deletion of your personal information, subject to legal and contractual obligations that require retention. You may also request restriction of processing in certain circumstances.

Objection to Processing

You have the right to object to processing of your personal information for direct marketing purposes. We will cease such processing upon receiving your objection.

Withdrawal of Consent

Where processing is based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

To exercise these rights, please contact us at [email protected]. We may require verification of your identity before processing requests.

Children's Privacy

Our services are directed to business organizations and professionals. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have collected information from a minor without parental consent, we will take steps to delete such information promptly.

International Data Transfers

While our operations are based in Hong Kong, some of our service providers may be located outside Hong Kong. When we transfer personal information internationally, we ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy and applicable laws.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will post the updated policy on our website with a revised "Last Updated" date. Material changes will be communicated through prominent notice on our website or direct communication to active clients.

Continued use of our services following policy changes constitutes acceptance of the revised policy.

Complaints and Regulatory Contact

If you have concerns about our privacy practices or wish to file a complaint, please contact us first at [email protected]. We will investigate and respond to your concerns promptly.

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data in Hong Kong:

Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact: