Privacy Policy

Last Updated: April 15, 2025

Introduction

SPARK4BRAND ("we", "our", or "us") is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data when you visit our website (www.spark4brand.com), use our services, or interact with us in any way.

We comply with the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong and other applicable data protection laws. By accessing our website or using our services, you consent to the practices described in this Privacy Policy.

Key Definitions

Before explaining our data practices, it's important to understand these key terms:

• Personal Data: Information relating to a living individual that can be used to identify that person, either directly or indirectly.
• Data Subject: The individual who is the subject of the personal data (you).
• Data User: The person or entity that controls the collection, holding, processing, or use of personal data (us).
• Data Processor: A person or entity that processes personal data on behalf of the data user.

Information We Collect

We collect personal data that is necessary and relevant for providing our marketing services. The types of information we collect include:

Information You Provide to Us

• Contact information (name, email address, phone number, business address)
• Business information (company name, job title, industry)
• Account credentials (username, password) if you create an account
• Marketing preferences and interests
• Payment information when purchasing our services
• Communications and correspondence with us
• Information provided when filling out forms, surveys, or questionnaires
• Information shared during consultations or when using our services

Information Collected Automatically

• Device information (IP address, browser type, operating system)
• Usage data (pages visited, time spent on pages, links clicked)
• Location information (general location based on IP address)
• Cookies and similar tracking technologies (see our Cookie Policy section)

Information from Third Parties

We may receive information about you from:

• Business partners or service providers
• Social media platforms (if you interact with us through them)
• Publicly available sources
• Referrals from existing clients

How We Use Your Information

We use your personal data only for purposes that are directly related to our functions and activities. These include:

Providing and Improving Our Services

• Delivering the marketing services you've requested
• Managing your account and relationship with us
• Processing payments and transactions
• Improving and personalizing our services
• Responding to your inquiries, comments, or feedback
• Providing customer support

Communication and Marketing

• Sending service-related communications
• Providing updates about our services
• Sending marketing communications (with your consent)
• Inviting you to events or webinars
• Conducting surveys or research

Business Operations

• Analyzing usage patterns and trends
• Maintaining and improving our website
• Detecting and preventing fraud or security incidents
• Complying with legal obligations
• Enforcing our terms and policies

Direct Marketing

We may use your personal data for direct marketing purposes, but only with your explicit consent. Before using your data for direct marketing, we will:

• Inform you that we intend to use your personal data for direct marketing
• Specify what kinds of personal data will be used
• Identify the classes of marketing subjects (products/services) we will promote
• Provide a free and easy way for you to opt out at any time

You may withdraw your consent for direct marketing at any time by:

• Clicking the "unsubscribe" link in our marketing emails
• Contacting our Data Protection Officer at privacy@spark4brand.com
• Writing to us at our business address

Disclosure of Your Information

We may share your personal data with:

Service Providers and Business Partners

• IT and cloud service providers
• Payment processors
• Marketing and analytics providers
• Professional advisors (lawyers, accountants, etc.)
• Other service providers who need access to such information to perform services on our behalf

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. They are only allowed to process your personal data for specified purposes and in accordance with our instructions.

Legal Requirements

We may disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal data.

Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or accidental access, processing, erasure, loss, or use. These measures include:

• Encryption of sensitive data
• Secure network architecture and firewalls
• Access controls and authentication procedures
• Regular security assessments and testing
• Staff training on data protection
• Physical security measures for our premises

While we strive to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period, we consider:

• The amount, nature, and sensitivity of the personal data
• The potential risk of harm from unauthorized use or disclosure
• The purposes for which we process the data
• Whether we can achieve those purposes through other means
• Legal, regulatory, and contractual requirements

When your personal data is no longer needed, we will securely delete or anonymize it.

Your Rights

Under the PDPO and other applicable laws, you have certain rights regarding your personal data:

Right to Access

You have the right to request access to your personal data that we hold. We will provide you with a copy of your personal data and information about how it is processed.

Right to Correction

You have the right to request correction of any inaccurate or incomplete personal data we hold about you.

Right to Erasure

In certain circumstances, you may request the deletion of your personal data, for example, when it is no longer necessary for the purposes for which it was collected.

Right to Object to Processing

You have the right to object to the processing of your personal data for direct marketing purposes at any time.

Right to Data Portability

Where technically feasible, you may request to receive your personal data in a structured, commonly used, and machine-readable format, or to have it transferred to another data user.

To exercise any of these rights, please contact our Data Protection Officer at privacy@spark4brand.com. We may need to request specific information from you to confirm your identity and ensure your right to access your personal data.

Cookies and Similar Technologies

We use cookies and similar tracking technologies to collect and use personal data about you, including to serve interest-based advertising. For more information about the types of cookies we use, why, and how you can control them, please see our Cookie Policy below.

What Are Cookies

Cookies are small text files that are stored on your device when you visit a website. They are widely used to make websites work more efficiently and provide information to the website owners.

How We Use Cookies

We use cookies for the following purposes:

• Essential Cookies: These are necessary for the website to function properly and cannot be switched off in our systems.
• Performance Cookies: These help us understand how visitors interact with our website by collecting and reporting information anonymously.
• Functional Cookies: These enable the website to provide enhanced functionality and personalization.
• Targeting Cookies: These may be set through our site by our advertising partners to build a profile of your interests and show you relevant advertisements on other sites.

Managing Cookies

Most web browsers allow you to manage your cookie preferences. You can set your browser to refuse cookies, or to alert you when cookies are being sent. However, if you disable cookies, some parts of our website may not function properly.

International Data Transfers

We may transfer your personal data to countries outside of Hong Kong. When we do, we ensure a similar degree of protection is afforded to your personal data by ensuring at least one of the following safeguards is implemented:

• Transferring to countries that have been deemed to provide an adequate level of protection for personal data
• Using specific contracts approved for use in international data transfers
• Obtaining your explicit consent for the proposed transfer after informing you of the possible risks

Children's Privacy

Our Services are not intended for children under the age of 18. We do not knowingly collect personal data from children under 18. If you are a parent or guardian and believe that your child has provided us with personal data, please contact us at privacy@spark4brand.com, and we will take steps to delete such information.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

We will obtain your consent to any material changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the "Last Updated" date at the top of this page.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the Privacy Commissioner for Personal Data in Hong Kong (www.pcpd.org.hk).