Privacy Policy

Last Updated: February 1, 2026

1. Introduction

Caspeon ("we," "our," or "us") is committed to protecting the privacy and security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your data when you visit our website or engage our strategic consulting services.

This policy applies to all personal data processed by Caspeon in the course of our business operations in Hong Kong and throughout Asia. We adhere to the Personal Data (Privacy) Ordinance (PDPO) and applicable international data protection standards.

For questions about this Privacy Policy or our data practices, please contact us at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect personal data that you voluntarily provide when you:

  • Submit inquiries through our contact forms
  • Request information about our consulting services
  • Enter into consulting engagements with us
  • Subscribe to our communications or updates
  • Participate in client interviews or assessments

This information may include your name, email address, phone number, company name, position, and any other information you choose to provide in your communications with us.

2.2 Automatically Collected Information

When you visit our website, we automatically collect certain information about your device and browsing activity, including:

  • IP address and browser type
  • Pages viewed and time spent on our site
  • Referring website or source
  • Device information and operating system

We collect this information through cookies and similar tracking technologies. For more details, please see our Cookie Policy.

3. How We Use Your Information

We process your personal data for the following purposes:

3.1 Service Delivery

  • Responding to your inquiries and providing information about our services
  • Delivering consulting engagements and professional services
  • Communicating about project milestones and deliverables
  • Processing payments and maintaining financial records

3.2 Business Operations

  • Improving our consulting methodologies and service offerings
  • Analyzing client needs and market trends
  • Maintaining business records and conducting audits
  • Complying with legal and regulatory requirements

3.3 Communications

  • Sending service-related updates and important notices
  • Sharing relevant insights and industry information (with your consent)
  • Conducting client satisfaction surveys

Legal basis for processing: We process your data based on contractual necessity, legitimate business interests, legal compliance, and where applicable, your explicit consent.

4. Data Sharing and Disclosure

We do not sell or rent your personal information to third parties. We may share your data in the following circumstances:

4.1 Service Providers

We engage trusted third-party service providers to support our business operations, including website hosting, analytics, payment processing, and communication tools. These providers are bound by confidentiality obligations and may only use your data to perform services on our behalf.

4.2 Legal Requirements

We may disclose your information when required by law, legal process, or to protect the rights, property, or safety of Caspeon, our clients, or others.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections outlined in this policy.

5. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

  • Encryption of data in transit and at rest
  • Secure server infrastructure with regular security updates
  • Access controls limiting data access to authorized personnel
  • Regular security assessments and monitoring
  • Employee training on data protection and confidentiality

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security but maintain industry-standard protections.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or for legitimate business purposes.

Specific retention periods:

  • Client engagement data: Duration of engagement plus seven years for legal and tax compliance
  • Marketing communications: Until you unsubscribe or request deletion
  • Website analytics: Aggregated data retained indefinitely, individual data for up to 26 months
  • Contact form inquiries: Three years from last contact

After the retention period expires, we securely delete or anonymize your personal data.

7. Your Privacy Rights

Under applicable data protection laws, you have the following rights regarding your personal information:

7.1 Access and Portability

You have the right to request access to the personal data we hold about you and to receive a copy of this data in a structured, commonly used format.

7.2 Correction

You may request correction of inaccurate or incomplete personal information we hold about you.

7.3 Deletion

You have the right to request deletion of your personal data, subject to legal retention requirements and legitimate business needs.

7.4 Objection and Restriction

You may object to certain processing of your data or request that we restrict processing in specific circumstances.

7.5 Withdraw Consent

Where we process your data based on consent, you have the right to withdraw that consent at any time.

7.6 Lodge a Complaint

You have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data in Hong Kong if you believe we have not handled your personal data appropriately.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days.

8. Cookies and Tracking

Our website uses cookies and similar tracking technologies to enhance user experience and analyze site usage. We use the following types of cookies:

  • Essential Cookies: Necessary for website functionality and security
  • Analytics Cookies: Help us understand how visitors use our site
  • Preference Cookies: Remember your settings and choices

For detailed information about our cookie practices and how to manage your preferences, please see our Cookie Policy.

9. Children's Privacy

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child, we will take steps to delete that information promptly.

10. International Data Transfers

While our primary operations are based in Hong Kong, we may transfer your personal data to service providers located in other jurisdictions for business processing purposes. When we transfer data internationally, we ensure appropriate safeguards are in place, such as:

  • Standard contractual clauses approved by relevant data protection authorities
  • Ensuring the recipient country provides adequate data protection
  • Implementing additional security measures as necessary

11. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website with a new "Last Updated" date.

Your continued use of our services after such changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy regularly to stay informed about how we protect your data.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Caspeon

Data Privacy Officer

Email: [email protected]

Phone: +852 2738 5194

Address: 20/F, Hopewell Centre, 183 Queen's Road East, Wan Chai, Hong Kong