Privacy Policy

1. Introduction

Pyxis Hong Kong Limited ("Pyxis HK", "we", "us", or "our") is a technology company incorporated in Hong Kong. We operate the website at pyxishk.com and provide technology development and consulting services to our clients.

This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website or engage with our services. Please read this policy carefully. If you disagree with its terms, please discontinue use of our website.

We comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and, where applicable, the European General Data Protection Regulation ("GDPR").

2. Information We Collect

2.1 Information You Provide Directly

We may collect the following categories of personal information that you voluntarily provide to us:

• Contact information: name, email address, phone number, and company name when you contact us, request a quote, or submit an enquiry.
• Project information: details you share about your project requirements, budget, or business needs.
• Communications: the content of emails, messages, or other correspondence you send to us.
• Contract and billing information: information required to enter into and perform service agreements, including invoicing details.

2.2 Information Collected Automatically

When you visit our website, we may automatically collect:

• Log data: IP address, browser type and version, operating system, referring URL, pages viewed, and time/date of your visit.
• Device information: device type, screen resolution, and language preferences.
• Cookie data: information stored in cookies placed on your device (see Section 7 — Cookies).
• Analytics data: aggregated statistics about how visitors use our website, collected via third-party analytics tools.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your enquiries and communicate with you about our services.
• To prepare and deliver proposals, quotations, and service agreements.
• To provide, manage, and improve our technology services.
• To process payments and manage our client relationships.
• To send you relevant updates, newsletters, or promotional materials (only where you have consented or where we have a legitimate interest).
• To comply with legal obligations and enforce our rights.
• To analyse website usage and improve our online presence and user experience.
• To detect, prevent, and address fraud, security issues, and technical problems.

4. Legal Basis for Processing

We process your personal data on the following legal bases:

• Contractual necessity: processing required to enter into or perform a contract with you.
• Legitimate interests: processing necessary for our legitimate business interests, such as improving our services and marketing, provided these do not override your rights.
• Consent: where you have freely given us your specific consent to process your data for a particular purpose (e.g., marketing communications).
• Legal obligation: processing required to comply with applicable laws and regulations.

5. Disclosure of Your Information

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

• Service providers: trusted third-party vendors who assist us in operating our website and delivering services (e.g., cloud hosting providers, email service providers, analytics tools). These parties are contractually obligated to handle your data securely and only for the purposes we specify.
• Professional advisors: lawyers, accountants, and auditors, as necessary, under obligations of confidentiality.
• Legal requirements: where required by law, court order, or governmental authority in Hong Kong or other applicable jurisdictions.
• Business transfers: in connection with a merger, acquisition, or sale of all or part of our business, your information may be transferred to the relevant parties.

6. Data Retention

We retain your personal information for as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required by law. Specifically:

• Contact enquiry data: up to 2 years from the date of last contact.
• Client project and contract data: up to 7 years from the end of the engagement (as required under Hong Kong law).
• Website analytics data: up to 26 months in aggregated form.

When personal data is no longer required, we will securely delete or anonymise it.

7. Cookies

Our website uses cookies — small text files stored on your device — to enhance your browsing experience and help us understand how our website is used.

Types of cookies we use:

• Essential cookies: necessary for the website to function correctly.
• Analytics cookies: help us understand how visitors interact with our website (e.g., Google Analytics). Data collected is aggregated and anonymous.
• Preference cookies: remember your settings and preferences for future visits.

You can control and delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website.

8. Data Security

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

• SSL/TLS encryption for all data transmitted to and from our website.
• Access controls limiting who within Pyxis HK can access personal data.
• Regular security reviews and vulnerability assessments.
• Secure data storage on reputable cloud infrastructure providers.

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security.

9. International Data Transfers

Your information may be transferred to and processed in countries outside Hong Kong, including countries within the European Economic Area, Singapore, and the United States, where our service providers operate. We ensure that any such transfers are made in compliance with applicable data protection laws and that adequate safeguards are in place.

10. Your Rights

Under the Personal Data (Privacy) Ordinance and applicable law, you have the right to:

• Access: request a copy of the personal data we hold about you.
• Correction: request correction of inaccurate or incomplete personal data.
• Erasure: request deletion of your personal data, subject to legal obligations.
• Objection: object to the processing of your data for direct marketing purposes.
• Withdrawal of consent: where processing is based on consent, withdraw that consent at any time.
• Restriction: request that we restrict the processing of your data in certain circumstances.

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

11. Third-Party Websites

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policies of any third-party sites you visit.

12. Children's Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you believe we have inadvertently collected information from a minor, please contact us immediately.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of material changes by posting the updated policy on our website with a revised "Last updated" date. We encourage you to review this policy periodically.

14. Contact Us

If you have any questions, concerns, or complaints about this Privacy Policy or how we handle your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General enquiries: [email protected]
• Address: Pyxis Hong Kong Limited, Central, Hong Kong

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