How we handle personal data.
This policy covers two groups of people: visitors to this website, and the people we research and contact when we run outbound campaigns for our clients. If you received a message from us, section 3 is the one for you.
1. Who we are
Growency is the trading name of [Company legal name], a company registered in Hong Kong (business registration number [BR number]), with its registered office at [Registered address].
We decide how and why the personal data described here is used. That makes us its data user under Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486), which this policy calls the PDPO.
This site and our campaigns are meant for business audiences. They are not directed at anyone under 18.
2. Visitors to this site
What this site does not collect
The site sets no cookies, runs no analytics, and does not track you across visits or across other websites. There are no accounts and no forms on it.
What your browser shares when the page loads
To display the page, your browser fetches typefaces from Google Fonts and a graphics library from jsDelivr. Like any request on the web, that sends those services your IP address and basic details about your browser. They handle that data under their own policies, which you can read at Google and jsDelivr.
Booking a call
When you book a call, we collect your name, work email, company and anything you choose to add in the booking form, through [Booking provider, for example Cal.com]. We use it to arrange the call and prepare for it.
Emailing us
If you email us, we keep your message and contact details so we can reply and continue the conversation you started.
3. People we contact for clients
We run outbound campaigns for business clients. That means researching the companies a client wants to reach, finding the person in each one whose role makes the client’s offer relevant, and contacting them. If we contacted you, this is why.
What we collect
- Your name, job title and employer
- Your business email address, and a business phone number where one is published
- Links to your public professional profiles
- Work context that makes a message relevant, such as a product launch, a new role, hiring, funding or a public company announcement
We do not look for sensitive personal data, such as your health, religion or political views, and we do not use personal addresses or personal phone numbers.
Where it comes from
- Company websites, press releases and news coverage
- Public professional profiles, such as LinkedIn
- Public company registries
- Business contact data providers
- Our clients, who tell us the kinds of companies and roles they want to reach
What we use it for
- Deciding whether a client’s offer is relevant to your role before we contact you
- Sending you a small number of messages about it, by email, LinkedIn or introduction
- Reading and answering your replies
- Recording that you asked us to stop, so that you are not contacted again
If you reply with interest or agree to a meeting, we pass your name, contact details and reply to the client we contacted you for, so they can continue the conversation.
4. Stopping our messages
You can ask us to stop at any time, free of charge. Reply to any of our messages saying so, or email [privacy@yourdomain]. We will stop using your data for direct marketing, as the PDPO requires, and tell the client concerned.
After that we keep your email address on a suppression list. It is the only reliable way to make sure you are not contacted again, by us or on behalf of any other client.
6. Data outside Hong Kong
Some of our service providers and clients are based outside Hong Kong, including in the United States, the United Kingdom and the European Union, so your data may be stored or accessed there. When that happens, we use providers and contract terms that require the data to be protected to a standard comparable to this policy.
7. How long we keep it
- People we contact: up to 12 months after our last message to you, unless you became a client or asked us to stop.
- The suppression list: for as long as we operate, so your request keeps being honoured.
- Bookings and email correspondence: up to 24 months after the conversation ends.
After that, we delete the data or remove anything that identifies you.
8. How we protect it
We take practical steps to protect the personal data we hold, including limiting access to the people at Growency who need it for their work and using service providers with established security practices. No system is completely secure, but we work to keep the risk low and review how we store data as our tools change.
9. Your rights
Under the PDPO, you can:
- Ask for a copy of the personal data we hold about you. This is called a data access request. We will respond within 40 days, and may charge a fee that is not excessive.
- Ask us to correct personal data about you that is inaccurate.
- Ask us to stop using your personal data for direct marketing, at any time and free of charge.
Send requests to [privacy@yourdomain]. We may need to confirm your identity before acting on one. If you are unhappy with how we have handled your data, you can complain to the Office of the Privacy Commissioner for Personal Data at pcpd.org.hk.
10. If you are in the UK or EU
When the people we contact are in the United Kingdom or the European Union, the UK GDPR or the EU GDPR also applies.
Our legal basis for contacting you is legitimate interests: our clients’ interest, and ours, in reaching businesses that may benefit from their offer, balanced against your interests. We keep that balance by writing only when a message is relevant to your role, keeping messages few, and making them easy to stop.
In addition to the rights in section 9, you can ask us to erase your data, restrict how we use it, or give you a copy in a portable format, and you can object to our use of it. If you object to marketing, we stop. You can complain to the Information Commissioner’s Office in the UK, or to the data protection authority in your EU country.
11. Changes to this policy
If we change this policy, we will update the date at the top of this page and explain any significant change here.
12. Contact us
[Company legal name], trading as Growency
[Registered address]
[privacy@yourdomain]