1. Scope
Chiwa Digital Media Capital Group Ltd. 志華數碼媒體資本集團有限公司, trading as Chiwa (the Company), respects personal data privacy and handles personal data in accordance with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) and applicable law.
This policy explains how we collect, use, retain and disclose personal data through chiwa.ai, enquiry forms and related business communications. Please also read any collection statement or data processing agreement provided for a particular service. This policy does not replace any legal requirement to provide appropriate notice, obtain consent or fulfil other statutory duties.
2. Data we collect
Depending on your interaction with us, we may collect your name, job title, company, telephone number, email and other contact details; enquiries, service requirements, business background and correspondence you provide; and information necessary for quotations, contracts, payments and service delivery. Required form fields are marked. Other information is provided voluntarily for the relevant purpose. Without necessary information, we may be unable to process your request.
The website and related systems may also process IP addresses, device and browser information, access times, pages visited and interactions for operation, security and the analytics described in section 7.
Unless specifically requested, do not submit identity document copies, full payment card details, medical records or unnecessary sensitive data. Before submitting another person’s data, ensure you have a lawful basis and any necessary authority.
3. Purposes of use
We use data only to respond to enquiries, arrange contact and understand service needs; assess potential engagements, prepare quotations and manage client relationships; perform agreed services, process payments and maintain administrative records; operate and secure the website and detect misuse; handle complaints and disputes and meet legal obligations; or, after the required notice and consent procedures, provide the marketing described in section 4. We may also use data for purposes directly related to these purposes.
Before using data for a new purpose that is neither the original purpose nor directly related to it, we will obtain any required consent or establish another applicable lawful basis.
4. Direct marketing
If we intend to use your name, contact details or service interests to promote our reputation management, digital marketing, SEO/AEO/GEO, social media, content or related services, we will first clearly explain the intended data use, service categories and response channel, and obtain the consent required by law.
Making an enquiry, requesting a quotation or accepting our website terms does not automatically constitute consent to marketing. You may request that we stop direct marketing at any time, free of charge, using the unsubscribe method in the message or our company WhatsApp at +852 6826 5126. We will handle requests in accordance with applicable law.
5. Recipients and service providers
To the extent necessary for these purposes, data may be accessed or processed by authorised personnel with a work-related need and providers of hosting, IT, communications, email, customer management, analytics or related support. Where necessary and appropriate, it may also be provided to our legal, accounting or other professional advisers and authorities or persons entitled to receive it under law or lawful procedures.
This website uses Google Analytics. If you choose to contact us through WhatsApp or WeChat, those platforms are also involved. Other processing arrangements for a particular service will be explained as appropriate to its scope.
We will not sell personal data or provide it to third parties for their own direct marketing merely because we receive an enquiry. When engaging processors, we will adopt reasonable contractual or other safeguards proportionate to the data and risks, addressing misuse, unauthorised access and unnecessary retention.
6. Cross-border processing and AI tools
Some providers may process or store data outside Hong Kong. We will assess the arrangements and adopt appropriate safeguards in light of applicable law and risk.
The website chat function sends the message you enter to our server to provide a response. Do not enter unnecessary personal data, client secrets or sensitive information.
If a particular service involves third-party AI or automated analysis tools, we will limit inputs to what is necessary and de-identify data where appropriate. Before sharing identifiable client data with such a tool, the processing purpose, provider terms, retention arrangements and required notice or authority must be checked. This policy does not mean that all enquiries are sent to third-party AI or provide a blanket assurance about any third party’s training or retention settings.
7. Cookies, analytics and external platforms
This website uses Google Analytics to understand page views, website use and interactions with enquiry entry points. These technologies may use cookies or other identifiers and process device and browser information, pages visited and interaction events. Processing and retention depend on actual service settings and provider arrangements. You may enquire about these arrangements through the WhatsApp contact in this policy.
You can manage or delete cookies through your browser and use Google’s Analytics opt-out tool. Disabling some technologies may affect functionality; browser controls do not necessarily control every third-party processing activity. Where applicable law requires separate consent, this policy does not replace that procedure.
If you contact us through WhatsApp, WeChat or another external platform, that platform may also process data under its own privacy policy. We remain responsible under applicable law for the data we receive and use.
8. Retention and security
We do not retain personal data longer than necessary for the relevant purposes. Retention takes into account whether follow-up is required, whether services are complete, applicable legal and recordkeeping requirements and reasonable needs for resolving disputes. Data no longer needed will be deleted or anonymised through appropriate procedures.
We will implement reasonable access controls and other security measures appropriate to the data. Internet transmission and storage are not entirely risk-free; this statement does not relieve us of our legal safeguarding duties.
9. Access, correction and privacy enquiries
You may request access to or correction of personal data we hold about you in accordance with law. We may request reasonable information to verify identity and will charge an access fee or refuse a request only where permitted by law.
You may also ask us to stop a particular use or delete data no longer needed. We will assess the request against applicable law and lawful retention needs.
Contact our company WhatsApp at +852 6826 5126, mark your message “Privacy Affairs Officer” and state the type of request. We will arrange appropriate follow-up and necessary identity checks. Do not send an identity document copy or other unnecessary sensitive information in your initial message.
This policy does not limit your right to contact or complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong.
10. Updates
We may update this policy to reflect operations or legal requirements and will display its effective date. Material processing changes will be notified appropriately. If separate consent is required by law, an update or continued browsing alone will not be treated as that consent.