Legal
Privacy Policy
Last Updated: 10 February 2026 | Phosphene | 152 Queen's Road Central, Sheung Wan, Hong Kong
1. Introduction
Phosphene ("we", "us", "our") is committed to protecting the personal data of individuals who interact with our website and services. This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). If you have any questions, contact us at [email protected].
2. Data We Collect
Information You Provide
When you complete our contact form or correspond with us by email, we may collect your name, email address, phone number, and the content of your message.
Information Collected Automatically
When you visit our website, we may collect technical data including your IP address, browser type, pages viewed, time of visit, and referring URL. This occurs via cookies when you have given consent.
Client Engagement Data
For organisations engaging our AI services, we may process business data provided for the purpose of model development or diagnostics. This data is handled under a separate data processing agreement and governed by the terms of your service contract.
3. Legal Basis for Processing
- Consent: Where you have provided explicit consent, such as for analytics cookies.
- Contractual necessity: Where processing is required to deliver services you have contracted for.
- Legitimate interests: Where we have a legitimate business interest, such as improving our services, provided this does not override your rights.
- Legal compliance: Where processing is required to comply with Hong Kong law or regulatory obligations.
4. How We Use Personal Data
We use personal data to respond to enquiries and deliver our services, to improve our website and service quality, to communicate relevant service information where you have indicated interest, and to comply with legal obligations. We do not sell personal data to third parties. We do not use personal data for automated decision-making that produces legal or similarly significant effects without human oversight.
5. Data Retention
Contact form and enquiry data is retained for up to 24 months before deletion or anonymisation. Client project data is retained for the duration of the engagement plus up to 36 months following project completion, unless a different period is agreed contractually. Website analytics data is retained for 14 months.
6. Data Sharing
We may share personal data with trusted service providers who assist in operating our website and services, including analytics providers and cloud infrastructure providers. These parties are contractually obligated to handle data securely and only for the purposes we specify. We do not share personal data with advertising networks. We may disclose personal data if required by law or in response to a valid legal request from Hong Kong authorities.
7. Cookies
Our website uses cookies. Essential cookies are necessary for site function and are always active. Optional cookies — analytics and preference cookies — are only activated with your consent. You can manage your preferences via our Cookie Policy page.
8. Data Security
We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include encrypted data transmission (TLS), access controls, and regular internal security reviews. In the event of a data breach that creates a real risk of harm to individuals, we will notify affected parties and the Privacy Commissioner for Personal Data (PCPD) as appropriate.
9. Your Rights
Under the PDPO and applicable data protection principles, you have the right to request access to personal data we hold about you, to request correction of inaccurate data, to request erasure of data we are not required to retain, and to withdraw consent for optional data processing at any time. You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data Hong Kong at www.pcpd.org.hk. To exercise any of these rights, contact us at [email protected]. We will respond within 40 days as required under the PDPO.
10. Third-Party Links
Our website may contain links to third-party sites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing personal data to them.
11. Children's Privacy
Our services are intended for organisations and professionals aged 18 and above. We do not knowingly collect personal data from individuals under 18. If you believe we have inadvertently collected such data, please contact us so we can delete it promptly.
12. International Data Transfers
Where personal data is transferred outside Hong Kong, we ensure appropriate safeguards are in place consistent with PDPO requirements, including contractual protections with receiving parties.
13. Policy Changes
We may update this Privacy Policy from time to time. Material changes will be communicated via a notice on our website. The "Last Updated" date at the top of this document reflects when the policy was last revised. Continued use of our website following an update constitutes acceptance of the revised policy.
14. Contact
Phosphene
152 Queen's Road Central, Sheung Wan, Hong Kong
Email: [email protected]
Phone: +852 9217 4638