Privacy Policy

1. Introduction

Spire Consulting ("we", "our", or "us") is committed to protecting the privacy and personal data of our clients, website visitors, and other individuals who interact with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO").

This policy applies to personal data collected through our website, consulting services, and any other interactions with our organisation. By using our services or providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy.

For questions about this policy or your personal data, please contact us at [email protected].

2. Data We Collect

We may collect the following types of personal data:

Contact Information: Name, email address, telephone number, business address, and job title when you contact us, complete our forms, or engage our services.

Business Information: Company name, industry, organisational role, and other professional details relevant to our consulting engagements.

Communication Records: Records of correspondence, meeting notes, and other communications between you and our team during consulting engagements.

Technical Data: IP address, browser type, device information, and website usage data collected through cookies and similar technologies when you visit our website.

Payment Information: Bank account details and payment records when processing consulting fees, though we do not store complete payment card numbers.

3. How We Collect Data

We collect personal data through:

Direct Interactions: When you fill in forms on our website, correspond with us by phone, email, or letter, or engage us for consulting services.

Automated Technologies: As you navigate our website, we may collect technical data about your equipment, browsing actions, and patterns through cookies and similar technologies.

Third Parties: Occasionally, we may receive personal data about you from third parties, such as referrals from existing clients or publicly available sources, in connection with potential consulting opportunities.

4. Legal Basis for Processing

Under Hong Kong's PDPO, we process your personal data based on the following grounds:

Contractual Necessity: Processing required to perform our consulting services or to take pre-contractual steps at your request.

Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services, marketing, and business development, provided these interests do not override your data protection rights.

Legal Obligations: Processing required to comply with applicable laws, regulations, or legal processes.

Consent: Where we rely on your consent for specific processing activities, you have the right to withdraw consent at any time.

5. How We Use Your Data

We use your personal data for the following purposes:

Service Delivery: To provide our consulting services, including assessments, advisory work, and workshop facilitation.

Communication: To respond to your enquiries, provide updates on engagements, and maintain our business relationship.

Administration: To process payments, manage contracts, and maintain accurate business records.

Website Operation: To operate, maintain, and improve our website, and to ensure a positive user experience.

Marketing: With your consent, to send you information about our services, industry insights, and events that may be of interest.

6. Data Sharing and Disclosure

We may share your personal data with:

Service Providers: Third parties who provide services on our behalf, such as IT support, website hosting, and professional advisors, under appropriate confidentiality agreements.

Professional Advisors: Lawyers, accountants, and auditors who require access to your data in connection with their professional services to us.

Legal Requirements: When required by law, regulation, or legal process, or to protect our rights, privacy, safety, or property.

We do not sell your personal data to third parties for their marketing purposes.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

Client Records: Consulting engagement records are retained for seven years after the completion of services, in accordance with professional and legal requirements.

Marketing Data: If you have opted in to receive marketing communications, we retain your contact details until you opt out or ask us to delete them.

Website Data: Technical data collected through cookies is retained for periods specified in our Cookie Policy.

8. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

Secure servers and encrypted data transmission for sensitive information.

Access controls limiting data access to authorised personnel only.

Regular security assessments and updates to our systems.

Staff training on data protection responsibilities.

In the event of a data breach that may affect your rights and freedoms, we will notify you and the relevant authorities as required by law.

9. Cookies

Our website uses cookies and similar technologies to enhance your browsing experience. We use:

Essential Cookies: Required for basic website functionality.

Analytics Cookies: To understand how visitors interact with our website.

Preference Cookies: To remember your settings and preferences.

For detailed information about our cookie practices, please see our Cookie Policy.

10. Your Rights

Under the PDPO, you have the following rights regarding your personal data:

Right of Access: You may request access to your personal data that we hold.

Right to Correction: You may request correction of any inaccurate personal data.

Right to Erasure: In certain circumstances, you may request deletion of your personal data.

Right to Object: You may object to processing of your personal data for direct marketing purposes.

To exercise these rights, please contact us at [email protected]. We will respond to your request within 40 days as required by the PDPO.

11. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these external sites. We encourage you to read the privacy policies of any third-party websites you visit.

12. Children's Privacy

Our services are directed at businesses and professionals. We do not knowingly collect personal data from individuals under 18 years of age. If you believe we have inadvertently collected such data, please contact us immediately.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last Updated" date. We encourage you to review this policy periodically. Continued use of our services after changes constitutes acceptance of the revised policy.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your data rights, please contact us:

15. Supervisory Authority

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data in Hong Kong at www.pcpd.org.hk.