Legal

Privacy Policy

Last Updated: 28 March 2025

1. Who We Are

Wellwick operates as a business consulting firm based at 16/F, Silvercord Tower 2, 30 Canton Road, Tsim Sha Tsui, Hong Kong. For any data-related enquiries, contact us at [email protected].

2. Data We Collect

We collect personal data only where necessary. The categories we collect include:

• Name and job title, provided when enquiring about or entering into an engagement
• Email address and telephone number, provided through our contact form or by direct communication
• Organisational information relevant to a consulting engagement, shared by authorised representatives
• Technical data via cookies, including IP address and browser type (see Section 5)

We do not collect sensitive personal data as defined under the PDPO unless specifically required and consented to for a particular engagement.

3. Legal Basis for Processing

Under the PDPO, we collect and use personal data on the following bases:

• Consent: Where you have provided information voluntarily through our contact form or communications
• Contractual necessity: Where processing is required to fulfil a consulting engagement agreement
• Legitimate interests: For administrative and business communications that are proportionate and expected
• Legal compliance: Where required by applicable Hong Kong law

4. How We Use Your Data

Personal data collected is used for the following purposes:

• Responding to enquiries submitted through our website or by telephone
• Managing and delivering consulting engagement services
• Issuing invoices and managing payment records
• Improving our website and services based on aggregated analytics
• Complying with applicable legal and regulatory obligations

We do not use personal data for automated decision-making or profiling.

5. Cookie Usage

Our website uses cookies to support basic functionality and understand how visitors use the site. These include session cookies (which expire when you close your browser) and persistent analytics cookies. For full details, please refer to our Cookie Policy.

6. Data Sharing

We do not sell personal data to third parties. Data may be shared in limited circumstances:

• With trusted service providers (such as hosting and email platforms) who process data on our behalf under appropriate confidentiality terms
• Where required by law, regulation, or court order in Hong Kong
• With the individual's consent

Personal data shared during consulting engagements is handled under mutual non-disclosure agreements and is not shared beyond the scope agreed in the engagement.

7. Data Retention

We retain personal data only for as long as necessary for the purposes described:

• Enquiry data (non-engagement): up to 12 months from last communication
• Engagement data: up to 7 years for contractual and tax compliance purposes
• Analytics data: aggregated and anonymised, retained indefinitely

8. Data Security

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or misuse. These include access controls, encrypted communications for sensitive data, and regular reviews of our data handling practices. In the event of a data breach affecting personal data, we will notify affected individuals promptly in accordance with the PDPO.

9. Your Rights

Under the PDPO, individuals have the right to:

• Request access to personal data we hold about them
• Request correction of inaccurate personal data
• Withdraw consent to the use of personal data (where processing is consent-based)
• Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong

To exercise any of these rights, please 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 external sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.

11. Children's Privacy

Our services are directed at organisations and professional individuals. We do not knowingly collect personal data from individuals under the age of 18.

12. Changes to This Policy

We may update this policy periodically to reflect changes in our practices or applicable law. Updates will be posted on this page with a revised "Last Updated" date. Continued use of our website following a material change constitutes acceptance of the updated policy.

13. Contact

For questions or requests regarding this Privacy Policy:

• Email: [email protected]
• Address: 16/F, Silvercord Tower 2, 30 Canton Road, Tsim Sha Tsui, Hong Kong
• Phone: +852 2684 3751