Privacy_Policy | New Pacific Way

Privacy Policy

Introduction

NEW PACIFIC WAY LTD (“we”, “us”, or “our”) operates this website. We are committed to protecting your privacy and handling your personal data in compliance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “Ordinance”).

This Privacy Policy explains what personal data we collect, how we use it, and your rights regarding your information. We do not collect sensitive personal information (such as identity numbers, financial details, health data, or biometric information) unless you voluntarily provide it in a context where we explicitly request it, and even then, it is not required for normal use of the Site.

Data We Collect

We only collect limited personal data that is necessary for the functioning of the Site and to respond to your inquiries. This includes:

Contact Information: When you fill out a contact form or email us, we may collect your name, email address, and any other details you choose to provide.
AI Interaction Data: When you use our AI tools (such as chatbots or AI‑powered features), we collect the text, queries, or inputs you provide, conversation logs, interaction history, and metadata such as timestamps and session identifiers.
Usage Data: We automatically collect certain non‑identifying information, such as your IP address, browser type, operating system, referring URLs, and pages viewed. This is collected through cookies and similar technologies (see Section 5).
Cookies & Tracking: We use cookies to enhance user experience, analyse site traffic, and remember preferences. You can control cookies through your browser settings.

We do not collect:

Hong Kong Identity Card numbers or any other document IDs
Financial or payment information
Health or medical data
Biometric or genetic data
Precise geolocation (unless explicitly enabled by you for a specific feature)

Purpose of Collection and Use

We collect and use your personal data only for the following purposes:

To respond to your inquiries, comments, or support requests.
To improve and optimise the Site (e.g., analysing usage trends).
To ensure the security and integrity of the Site.
To comply with legal obligations applicable in Hong Kong.

We do not use AI tools to make automated decisions that produce legal or similarly significant effects concerning you, unless we provide separate notice and obtain your explicit consent. We also do not sell, rent, or trade your personal data to third parties for marketing purposes.

Legal Basis for Processing

Under the Ordinance, we collect and use personal data only with your consent or where it is necessary for:

The performance of a requested service (e.g., responding to your message);
Compliance with a legal obligation;
Our legitimate interests (such as maintaining the Site’s security and functionality), provided those interests do not override your privacy rights.

Cookies and Tracking Technologies

We may use cookies and similar technologies to:

Recognise you when you return to the Site.
Understand how visitors use the Site (e.g., through Google Analytics or similar services).
Store your preferences.
Support the operation of AI tools where session data is required.

You may set your browser to refuse all or some cookies, but this may affect the functionality of the Site, including certain AI features. Third‑party services we use (e.g., analytics providers or AI service providers) may also place cookies; these are governed by their own privacy policies.

AI Tools and Automated Processing

We use artificial intelligence (“AI”) tools on our Site to enhance user experience, provide automated assistance, and improve our services. These tools may include:

AI Chatbots: Automated conversational agents that respond to user inquiries.
AI‑Powered Features: Tools that generate content, provide recommendations, or analyse user inputs.

When you interact with these AI tools, we collect and process the data described before. This data is used solely for:

Operating and improving the AI tools.
Responding to your requests.
Analysing usage patterns to enhance functionality.

We do not use AI tools to make automated decisions that produce legal or similarly significant effects concerning you, unless we provide separate notice and obtain your explicit consent.

AI Service Providers and Data Transfers

Our AI tools are powered by trusted third‑party service providers (e.g., [list providers if applicable, such as OpenAI, Google Cloud AI, Microsoft Azure AI, etc.]). When you use these tools, your inputs and related data may be transmitted to and processed by these providers on our behalf.

These providers may operate servers outside Hong Kong. We ensure that any cross‑border transfer of personal data complies with the PDPO by implementing appropriate safeguards, such as contractual clauses that require the recipient to protect your data to Hong Kong standards.

We do not permit our AI service providers to use your data for their own purposes, such as training their general models, unless you have given explicit consent or the provider’s own policy states otherwise (in which case we will notify you separately).

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by Hong Kong law.

Contact form submissions are typically kept for [e.g., 12 months] and then deleted.

Usage data and analytics logs are anonymised or deleted after 24 months.

Data Security

We take reasonable steps to protect your personal data from unauthorised access, loss, misuse, or disclosure. Security measures include:

Secure servers and encrypted connections (HTTPS).
Restricted access to personal data within our organisation.
Regular reviews of our data collection and storage practices.

However, no method of transmission over the Internet or electronic storage is 100% secure.

Disclosure of Personal Data

We do not share your personal data with third parties except in the following limited circumstances:

Service Providers: We may engage trusted third parties (e.g., hosting providers, analytics services) who process data on our behalf under strict confidentiality obligations.
Legal Requirements: If required by law, regulation, or a court order in Hong Kong, we may disclose your information to comply with legal process.
Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred, subject to the acquirer assuming the obligations of this Policy.

Your Rights (Under Hong Kong’s PDPO)

Under the Ordinance, you have the right to:

Request Access: Ask whether we hold your personal data and request a copy.
Request Correction: Request that we correct any inaccurate personal data.
Withdraw Consent: Withdraw your consent for processing where consent is the legal basis (subject to legal or contractual restrictions).
Request Human Review: If we use AI for automated decision‑making that affects you, you may request human review or contest the decision. (Note: We do not currently use AI for such purposes without separate notice and consent, but this right is noted for transparency.)

To exercise these rights, please contact us at info@npw.ltd. We will respond within the timeframe required by the Ordinance (generally 40 days). We may charge a reasonable fee for access requests.

Cross‑Border Data Transfers

If we transfer your personal data outside Hong Kong, we will ensure that such transfers comply with the Ordinance and that adequate protection measures are in place (e.g., contractual safeguards).

Third‑Party Links

The Site may contain links to third‑party websites. We are not responsible for the privacy practices or content of those sites. We encourage you to read their privacy policies.

Children’s Privacy

Our Site is not directed to individuals under the age of 13 (or the age of digital consent in Hong Kong, which is currently no specific age under the PDPO; we apply a practical threshold of 13). We do not knowingly collect personal data from children. If we learn we have inadvertently collected such data, we will delete it promptly.

If you have any questions about this Privacy Policy, our data practices, or wish to exercise your rights, please contact us at info@npw.ltd

Effective date: 1 March 2026