Privacy Policy

1. Introduction

Pulsemind ("we", "us", "our") is committed to protecting the personal data of individuals who interact with our website and services. This policy explains how we collect, use, store, and protect personal data in accordance with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and, where applicable, supplementary international standards.

By using our website or engaging with our services, you acknowledge the practices described in this policy. For questions, contact us at [email protected].

2. Data We Collect

We collect personal data through the following means:

• Contact forms: Name, email address, phone number (optional), and any details you include in your message.
• Analytics tools: Aggregated, non-identifiable browsing data such as page visits, session duration, and referral sources (subject to your cookie consent).
• Direct correspondence: Any information you provide when contacting us by email or telephone.
• Client engagement: Data shared during project scoping and delivery, governed separately by a mutual NDA.

We do not collect sensitive personal data (such as identity card numbers or financial account details) through our website.

3. How We Use Your Data

Personal data collected through our website is used for the following purposes:

• Responding to enquiries and requests submitted via our contact form
• Assessing whether a project engagement may be suitable
• Sending service-related communications where you have requested information
• Improving our website through aggregated analytics (with your consent)
• Complying with legal obligations under Hong Kong law

We do not use personal data for unsolicited marketing, and we do not sell or rent your data to third parties.

4. Legal Basis for Processing

Under the PDPO, we process personal data on the following bases:

• Consent: Where you have provided explicit consent, such as accepting optional cookies.
• Contractual necessity: When processing is necessary to respond to or fulfil a service engagement.
• Legitimate interest: For general enquiry response and service improvement, where these interests are not overridden by your rights.

5. Data Retention

We retain personal data only for as long as necessary for the purpose it was collected:

• Enquiry data: up to 12 months from last contact, unless a project engagement is initiated
• Project-related data: as specified in the project agreement and NDA
• Analytics data: 26 months (standard analytics retention)

After applicable retention periods, data is securely deleted or anonymised.

6. Data Sharing

We do not sell personal data. We may share data with:

• Service providers: Hosting, analytics, and email service providers who process data on our behalf under data processing agreements.
• Legal authorities: Where required to comply with applicable law or a lawful order.

All third-party providers are selected with data privacy in mind and are contractually required to handle data appropriately.

7. Data Security

We implement appropriate technical and organisational measures to protect personal data:

• TLS encryption for data transmitted via our website
• Access controls limiting data access to authorised personnel
• Regular review of security practices and data handling procedures
• Secure deletion protocols for data no longer required

In the event of a data breach that is likely to result in risk to individuals, we will notify the affected parties and the Office of the Privacy Commissioner for Personal Data (PCPD) as required by law.

8. Cookies

We use cookies on our website. For detailed information about the types of cookies we use and how to manage your preferences, please read our Cookie Policy.

9. Your Rights

Under the PDPO, you have the right to:

• Request access to personal data we hold about you
• Request correction of inaccurate personal data
• Object to the use of your personal data for direct marketing
• Withdraw consent where processing is consent-based
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk

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

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies independently.

11. Children's Privacy

Our services are intended for organisations and professionals. We do not knowingly collect data from individuals under 18. If you believe we have inadvertently received data from a minor, please contact us promptly.

12. Changes to This Policy

We may update this policy from time to time. Material changes will be indicated by an updated "Last Updated" date at the top of this page. Continued use of our website after changes constitutes acceptance of the revised policy.

13. Contact

For privacy-related enquiries or to exercise your data rights:

• Email: [email protected]
• Address: 7 Hoi Wan Street, Quarry Bay, Hong Kong
• Phone: +852 6185 4392