Privacy Policy

1. Introduction

Deboss Collective Limited ("we", "us", "our") respects your privacy and is committed to protecting personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the "Ordinance"). This Privacy Policy explains what personal data we collect through www.deboss-collective.com (the "Website"), how we use it, and your rights. It should be read alongside our Terms of Use and our Cookie Notice.

2. What Personal Data We Collect

(a) Information you provide directly

When you use the contact/enquiry form on the Website, we collect the personal data you choose to submit, which may include:

• Name
• Email address
• Phone number
• Company/organisation name (if applicable)
• Enquiry type
• Any other information included in your message (e.g. project details, or CV/portfolio information if enquiring about joining our team)
• Portfolio link (if provided)

(b) Information collected automatically

If you accept analytics cookies, Google Analytics collects information when you browse the Website, including:

• IP address (may be truncated/anonymised)
• Browser type and device information
• Pages visited and time spent on the Website
• Previous page within this Website
• General geographic location (derived from IP address)

Analytics also records successful enquiry submissions without the contents of the form. We do not send your name, email address, phone number, message, portfolio link or other form values to Google Analytics. Page addresses sent to analytics exclude URL queries and fragments.

Further detail is set out in our Cookie Notice.

3. How We Use Your Personal Data

Personal data collected via the contact form is used only to:

• Respond to your enquiry
• Assess and respond to enquiries from prospective team members
• Keep records of correspondence for our internal business purposes

Analytics data collected via Google Analytics is used to:

• Understand how visitors use the Website
• Improve the Website's content and functionality

We do not use your personal data for direct marketing without your consent, and we do not sell your personal data to any third party.

4. Disclosure of Personal Data

We do not routinely disclose personal data collected via the contact form to third parties, except:

• Where necessary to respond to your enquiry (e.g. sharing it internally between our principals)
• To Resend, our email delivery provider, to deliver your enquiry to the studio and send you an acknowledgement
• Where required by law or requested by a competent authority

Data collected via Google Analytics is processed by Google LLC, which acts as a data processor for that purpose. Google's own handling of this data is described in Google's Privacy Policy.

5. Transfer of Data Outside Hong Kong

Google Analytics may process and store data on servers located outside Hong Kong, including in the United States. Where personal data is transferred outside Hong Kong, we take reasonable steps to ensure it continues to be protected to a standard comparable to the Ordinance.

6. Data Retention

Personal data submitted via the contact form is retained only for as long as necessary to respond to your enquiry and for any legitimate follow-up business purpose, after which it is deleted or anonymised. Analytics data is retained in accordance with the retention settings configured in Google Analytics. Cookie lifetimes and the duration of your saved cookie choice are described in our Cookie Notice; these are separate from the retention of data already collected by Google Analytics.

7. Data Security

We take reasonable and practicable steps to protect personal data we hold against unauthorised or accidental access, processing, erasure, loss, or use, consistent with Data Protection Principle 4 of the Ordinance.

8. Your Rights

Under the Ordinance, you have the right to:

• Check whether we hold personal data about you and request access to it (a Data Access Request)
• Request correction of any inaccurate personal data (a Data Correction Request)

To make such a request, contact us using the details in Section 12 below. We may require proof of identity before processing your request, and a reasonable fee may be charged for a Data Access Request as permitted under the Ordinance.

If you are not satisfied with how we have handled your personal data, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).

9. Cookies

The Website uses Google Analytics cookies only after you accept analytics, and local storage to remember your cookie choice. Please see our separate Cookie Notice for full details, including how to manage or disable cookies.

10. Children's Privacy

The Website is not directed at children, and we do not knowingly collect personal data from children.

11. Changes to This Policy

We may update this Privacy Policy from time to time. The updated version will be posted on this page with a revised "Last updated" date.

12. Contact Us

If you have any questions about this Privacy Policy, or wish to make a Data Access or Data Correction Request, please contact: