LAST AMENDMENT: 26.09.2022

SPS BUSINESS CONSULTING SERVICES LIMITED, registry code 2451670, registered office located at Unit G, 6/F, Neich Tower, 128 Gloucester Road, Wanchai, Hong Kong ("Company", "we", "us" or "our"), acknowledges the importance of protecting the privacy of individuals whose personal data may become available to us. References in this Policy to "you" or "your" are recognised as references to persons who are visitors to our website, suppliers of goods or services to the Company or any other persons from whom we obtain any personal data. The following policy explains our handling of personal data that we may collect about you, it will help you better understand how we collect, use and otherwise process your personal data and the rights you have in relation to our processing of that information ("Privacy Policy"). In this Privacy Policy, "Personal Data" means information which by itself or in combination with other data allows us to identify or recognise you.

The Company is responsible for ensuring that personal data processing complies with applicable data protection legislation. Our employees must comply with the data privacy rules set out in this Privacy Policy and other rules relating to data privacy.

If you have any comments or questions regarding this Privacy Policy, please contact us by email at

Data collection
There are several contact forms on our website that you can fill out. If you use any of them, we may, for example, store your name, email address and any other information that you voluntarily give us.
Personal information may be collected from you as part of an interaction, including when you use the website, when you contact us or request information from us when we provide services to you.
For the purposes of this Policy, "User Personal Information" means:
- Personal information that the User provides about themselves when using the Service (including name, surname, telephone number, email address).
- Data which is automatically collected by the Service in the course of its use with the help of the software installed on the User's device, including IP-address, data of cookies files, information about the User's browser (or other program by means of which the access to the Service is made), technical characteristics of equipment and software used by the User, date and time of access to the Service and other similar information.
This Policy only applies to information processed in the course of using the Site. We have no control over, and shall not be responsible for, the processing of information by third party websites to which the User may link through the links available on the Site.
We do not verify the accuracy of the personal information provided by the User. We assume that the personal information you provide to us is true and sufficient and that we keep it up to date.

Use of data
We may use your personal data for the following purposes:
- Providing services;
- Processing of customer enquiries;
- Sending relevant marketing messages and invitations to events/seminars;
- Improving our website;
- Ensuring the security of our website, IT systems and processes;
- Compliance with legislation.

Consent to Personal Data Processing
− EU Persons Consent to Personal Data processing
If you are an EU Person and to process your Personal Data we need to receive your consent, as it is prescribed by GDPR, we will process your Personal Data only in the case we have received from you a freely given, specific, informed and unambiguous indication of your wishes by which you signify agreement to the processing of your Personal Data ("Consent").
You may give your Consent by ticking a box when visiting the Site. In the case you tick the respective box, you irrevocably and unconditionally consent and agree that the Company shall be entitled to process your Personal Data as it is indicated by your Consent.
Your Consent covers all processing activities with your Personal Data carried out for the same purpose or purposes. When the Processing has multiple purposes, your Consent should be deemed given for all of them.
You have the right to withdraw your Consent at any time. You can submit such request by sending us an email to Your withdrawal of Consent shall not affect the lawfulness of your Personal Data processing based on Consent before its withdrawal.
Except as required or enabled by law we will not use or disclose your Personal Data for any purpose for which you refuse Consent or later withdraw your Consent. If you withdraw Consent, you agree that in spite of this withdrawal, we may continue to use those Personal Data previously provided to us to the extent that we are contractually or otherwise legally obliged to do so and to the extent necessary to enforce any contractual obligation you may have towards the Company or in any other way permitted by law.
− Non-EU Persons Consent to Personal Data processing
If you are not an EU Person, by transferring to us your Personal Data via the Site or otherwise, you irrevocably and unconditionally consent and agree that the Company shall be entitled, in accordance with this Policy:
− to Process in any manner, including to collect, store, use, disclose, share and transfer (including cross-border), your Personal Data so provided to us, as well as your Personal Data collected from your use of the Site (i.e. your Personal Data which we collect automatically and/or from other sources); and
− to use cookies to collect your Personal Data and associate the Personal Data with your computer and web browser.

Terms of processing of personal information of Users and its transfer to third parties:
The Company treats Personal Data as confidential and may not pass on or use any such data without valid legal grounds.
We keep personal information of Users in accordance with the legislation of the Special Administrative Region of Hong Kong, this Policy, respective sources of EU regional legislation and internal regulations.
Personal information of the User shall be kept confidential, except in cases where the User voluntarily provides information about itself for public access by an unlimited number of persons.
We may disclose User's personal information to third parties in the following cases:
- The User has expressed consent to such actions;
- The transfer is necessary for us to use the Site or to perform a particular agreement or contract with the User, including the transfer of personal information to our partners;
- Such transfer takes place as part of the sale or other transfer of business (in whole or in part), and the acquirer assumes all obligations to comply with the terms of this Policy with respect to the personal information it obtains;
- In order to be able to protect our rights and legitimate interests or those of third parties in cases where the User breaches the Website Agreement and this Policy, or there is a threat of such a breach.
- For everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations.
- The processing of the User's personal information by depersonalising it results in impersonal statistical data, which is transferred to a third party to carry out research, work or services on behalf of the Company.
Personal information may be processed by employees of the Company. Such employees may be involved, among other things, in providing services to the User, processing payment orders, and providing technical support services. By submitting his/her personal information, the User consents to such transfer, storage or processing. The Company will take all necessary steps to ensure that such information is treated securely and in accordance with this Privacy Policy.

Changes and deletion of personal information. Obligatory storage of data.
A user can request the termination of the processing of his or her personal information by sending a corresponding message, indicating the name of the account, to the address indicated on the Website
The rights set out in this Policy may be restricted in accordance with legal requirements. In particular, such restrictions may include the Company's obligation to retain the information modified or deleted by the User for a period of time prescribed by law and to transfer such information to a governmental authority in accordance with the legally prescribed procedure.
Personal information about the User is processed by the Company for the duration of the User's use of the Service and/or agreements and contracts with the User, taking into account the requirements stipulated by Applicable law.

Processing of personal information by means of cookies
The structure of cookies file, its content and technical parameters are defined by the Company and can be changed without prior notification of the User.

Measures used to protect personal information of users
The Company takes necessary and sufficient organizational and technical measures to protect personal information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other unauthorized actions of third parties with it.

Changes in Privacy Policy. Applicable law
The Company has the right to make changes in this Privacy Policy. The new version of the Policy becomes effective on the date of its posting, unless otherwise specified in the new version of the Policy. The current version is available on the Website at all times.
To this Policy and the relationship between the User and the Company, arising in connection with the application of privacy policy is subject to the law of the Special Administrative Region
of Hong Kong.

Feedback. Questions and suggestions
All requests and notifications regarding personal information and the Policy, under the Applicable law, user has the right to send by e-mail, indicated on the Site.
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