1. Who We Are
Gate.Advisory Limited ("we", "us", "our" or "gate.advisory") is the data user (as defined in the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong, the "PDPO") for the personal data collected through https://gateadvisory.llc (the "Site") and in the course of providing our professional services.
Our registered office is at Unit B, 11/F, Wah Kit Commercial Centre, 302 Des Voeux Road, Sheung Wan, Hong Kong.
We are committed to complying with the PDPO and the six Data Protection Principles ("DPPs") set out in Schedule 1 to the PDPO, and to the guidance issued from time to time by the Office of the Privacy Commissioner for Personal Data, Hong Kong ("PCPD").
2. Personal Data We Collect
Consistent with DPP1, we collect only personal data that is necessary for and directly related to the purposes set out below. Categories include:
- — Contact details you provide when you email us, book an intro call or engage our services — typically name, work email, company, role and any content of your message.
- — Engagement information — information you share with us so we can perform an engagement, including business documents, data extracts and interview notes.
- — Technical data — IP address, device type, browser, referring URL and pages viewed, collected through server logs and analytics.
- — Cookies and similar technologies — see section 7 below.
3. Purposes of Use
As required by DPP1 and DPP3, we use personal data only for the following purposes, and for purposes directly related to them:
- — Responding to your enquiries and scheduling intro calls;
- — Providing, invoicing for and managing the services you engage us for;
- — Operating, securing and improving the Site;
- — Complying with legal, tax and regulatory obligations that apply to us in Hong Kong and any other applicable jurisdiction.
4. Use of Personal Data in Direct Marketing
In accordance with sections 35A to 35M of the PDPO, we will not use your personal data in direct marketing without first obtaining your explicit consent. If we intend to do so, we will provide you with the prescribed information and an opportunity to opt in. You may at any time, and free of charge, ask us to stop using your personal data for direct marketing by emailing office@gateadvisory.llc.
5. Transfer and Disclosure of Personal Data
Consistent with DPP3, we will not disclose your personal data to any third party for a new purpose without your prescribed consent. We may transfer personal data to the following classes of transferees:
- — Service providers who process personal data on our behalf under written agreements requiring them to protect the data and use it only for the purposes we specify (for example hosting, analytics, email and accounting providers);
- — Our professional advisers, including lawyers, auditors and insurers, where necessary;
- — Regulators, courts, law-enforcement agencies and other authorities, where required by law or to establish, exercise or defend our legal rights.
6. International Transfers
We are established in Hong Kong. Some of our service providers may process personal data in jurisdictions outside Hong Kong. Where such transfers take place, we take reasonable steps to ensure the personal data receives a level of protection consistent with the PDPO, including by imposing contractual obligations on the recipient. You consent to such transfers by using the Site or engaging our services.
7. Cookies and Analytics
The Site uses a small number of cookies and similar technologies to remember your preferences (for example your theme and light/dark mode) and to understand aggregate usage so we can improve it. We do not use cookies for advertising.
You can control cookies through your browser settings. Blocking cookies may affect Site functionality.
8. Data Retention
Consistent with DPP2, we keep personal data only for as long as necessary for the purposes for which it was collected, plus a reasonable period to satisfy our legal, tax and audit obligations. Contract-related records are typically kept for seven (7) years after the end of the engagement.
9. Data Security
Consistent with DPP4, we take practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use, including access controls, encryption in transit, and written processing agreements with service providers. No system is completely secure, however, and we cannot guarantee absolute security.
10. Your Rights
Under sections 18 and 22 of the PDPO you have the right to make:
- — A Data Access Request ("DAR") — to be informed whether we hold personal data of which you are the data subject and, if so, to receive a copy of that data;
- — A Data Correction Request ("DCR") — to have any personal data of which you are the data subject and which is inaccurate corrected.
11. How to Exercise Your Rights
To make a DAR or DCR, or to withdraw a consent previously given, please email us at office@gateadvisory.llc or write to us at the postal address in section 15. We may ask you to provide sufficient information to verify your identity and locate the personal data concerned.
A fee not exceeding the amount permitted under the PDPO may be charged for complying with a DAR. We will respond within 40 days of receiving a valid request, as required by section 19 of the PDPO.
12. Children
The Site and our services are directed at business users. We do not knowingly collect personal data from anyone under the age of 16. If you believe a child has provided us with personal data, please contact us and we will delete it.
13. Governing Law
This Privacy Policy is governed by, and shall be construed in accordance with, the laws of the Hong Kong Special Administrative Region.
14. Changes to This Policy
We may update this Privacy Policy from time to time. The updated version will be posted on this page with a new "Last updated" date. Where changes are material we will take reasonable steps to notify you. We encourage you to review this page periodically.
15. Contact and Complaints
To exercise your rights, ask questions or make a complaint about how we handle personal data, please contact us at office@gateadvisory.llc, or by post to Gate.Advisory Limited, Unit B, 11/F, Wah Kit Commercial Centre, 302 Des Voeux Road, Sheung Wan, Hong Kong.
If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD). Details are available at www.pcpd.org.hk.
