Privacy Policy

1. Introduction

Yuen Horizon ("we", "us", "our") is committed to protecting the personal data of individuals who interact with our services, website, and staff. This Privacy Policy explains how we collect, use, store, and protect personal data in accordance with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO").

This policy applies to all personal data collected through our website at yuenhori, through enquiry forms, during service engagements, and through any correspondence with our team.

Questions about this policy can be directed to: privacy@yuenhori

2. Data We Collect

We collect personal data when it is provided voluntarily or when it is necessary to deliver our services:

• Identity data: name, job title, organisation name
• Contact data: email address, telephone number, business address
• Communication data: messages sent through our contact form or by email
• Engagement data: information provided during service scoping, configuration, and delivery
• Technical data: IP address, browser type, pages visited, and cookie preferences (see Cookie Policy)
• Voice recording data (transcription clients only): audio recordings provided for transcription and structured output — handled under separate data processing agreement

We do not collect sensitive personal data (health information, financial account numbers, government identity documents) except where explicitly required by a service engagement and agreed in writing.

3. How We Use Your Data

Personal data is used for the following purposes:

• Responding to enquiries submitted through our contact form or by email
• Delivering services under signed engagement agreements
• Sending monthly or quarterly reports to named contacts at client organisations
• Maintaining service records and documentation
• Improving our website and understanding how it is used (analytics, where consented)
• Complying with applicable legal and regulatory obligations

We do not use personal data for unsolicited direct marketing. If you enquire about our services and we send a follow-up communication, this is in direct response to your contact, not a marketing campaign.

4. Legal Basis for Processing

Under the PDPO, personal data must be collected for a lawful purpose directly related to a function or activity of the data user. Our bases for processing are:

• Contract performance: processing necessary to deliver services under a signed engagement agreement
• Consent: processing based on your explicit consent, for example cookie analytics or voice recording use
• Legitimate interests: responding to an enquiry you have initiated, maintaining business records
• Legal compliance: where processing is required to meet regulatory obligations

5. Data Retention

We retain personal data for as long as necessary for the stated purpose and in accordance with applicable law:

• Enquiry records: 12 months from last contact, unless an engagement follows
• Engagement records: 7 years from engagement close, for business record purposes
• Voice recordings (transcription clients): 30 days after structured output is delivered, unless a longer retention period is agreed in writing
• Website analytics data: as determined by cookie settings and third-party service terms

6. Data Sharing

We do not sell personal data to any third party. We may share data with:

• Service providers: cloud storage, email delivery, and analytics tools used to operate our services — under data processing agreements requiring equivalent protections
• Professional advisors: legal, accounting, or compliance advisors where necessary, under confidentiality obligations
• Regulatory authorities: where required by Hong Kong law

Client voice recordings and structured records are never shared with third parties for model training, product development, or any commercial purpose without explicit written consent from the client organisation.

7. Cookies and Tracking

Our website uses cookies to understand how visitors use the site and to remember your preferences. Essential cookies are always active. Analytics and preference cookies require your consent, which you can set when you first visit the site or at any time through our Cookie Policy page.

We use analytics tools (such as Google Analytics) that may set cookies and transfer data outside Hong Kong. Where this occurs, it is governed by the terms of those services and is limited to consented analytics data.

8. Your Rights Under the PDPO

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

• Request access to personal data we hold about you
• Request correction of inaccurate personal data
• Object to certain uses of your personal data, including direct marketing
• Withdraw consent where processing is based on consent
• Request erasure of data we no longer have a lawful basis to hold
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong

To exercise any of these rights, contact us at: privacy@yuenhori. We will respond within 40 days as required by the PDPO.

9. Data Security

We implement organisational and technical measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These include access controls, encrypted storage for sensitive records, and staff training on data handling obligations. In the event of a data breach affecting your personal data, we will notify you and the PCPD as required by law.

10. Third-Party Links

Our website may include links to external websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before submitting personal data.

11. Children's Privacy

Our services are directed at organisations 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 at privacy@yuenhori.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top of this page reflects the most recent revision. Material changes will be communicated to active clients by email. Continued use of our website or services after changes are posted constitutes acceptance of the updated policy.

13. Contact Us

For privacy-related enquiries or to exercise your rights under the PDPO, please contact:

• Email: privacy@yuenhori
• Phone: +852 3615 7492
• Address: 36 Castle Peak Road, Yuen Long, New Territories, Hong Kong

You may also contact the Office of the Privacy Commissioner for Personal Data (PCPD) at pcpd.org.hk if you wish to raise a concern directly with the regulatory authority.