1. INTRODUCTION
DDX Group Limited (“DDX”, “we”, “us”, or “our”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, hold, process, and use personal data in connection with our corporate website, in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and the six Data Protection Principles (“DPPs”) contained therein.
Please read this policy carefully before using our website. By continuing to use the site, you acknowledge that you have read and understood this policy.
2. WHO WE ARE
DDX Group Limited is the data user responsible for personal data collected through this website.
We have not appointed a Data Protection Officer as this is not a mandatory requirement under the PDPO. For privacy-related enquiries, please contact us at the email address above.
3. PERSONAL DATA WE COLLECT
We collect personal data only to the extent necessary and for purposes directly related to the operation of our business and website. The table below sets out the categories of data we collect, the purposes, and the relevant DPPs.
| Type of Data | Purpose | DPP Basis |
|---|---|---|
| Name, email, phone, message | Responding to contact form enquiries | DPP 1 – collected for a lawful purpose directly related to our function as a consultancy |
| IP address, browser type, pages visited, session data | Website analytics and performance monitoring | DPP 1 – lawful, directly related purpose; DPP 4 – security |
| Name, CV, employment history, | Processing and evaluating job applications and recruitment | DPP 1 – lawful purpose; used only for recruitment (DPP 3) |
We do not collect sensitive personal data (as defined under the PDPO) without your explicit consent, and we do not use personal data for automated profiling or decision-making.
4. COOKIES AND ANALYTICS
4.1. What are cookies?
Cookies are small text files placed on your device when you visit a website. They allow the website to remember your preferences and analyse how visitors use the site.
4.2. Cookies we use
Necessary
Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.
| Cookie | Duration | Description |
|---|---|---|
| cookieyes-consent | 1 year | CookieYes sets this cookie to remember users’ consent preferences so that their preferences are respected on subsequent visits to this site. It does not collect or store any personal information about the site visitors. |
| __cf_bm | 1 hour | This cookie, set by Cloudflare, is used to support Cloudflare Bot Management. |
| _cfuvid | session | Cloudflare sets this cookie to track users across sessions to optimize user experience by maintaining session consistency and providing personalized services |
Analytics
Analytical cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
| Cookie | Duration | Description |
|---|---|---|
| _ga | 1 year 1 month 4 days 1 minute | Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors. |
| _ga_* | 1 year 1 month 4 days 1 minute | Google Analytics sets this cookie to store and count page views. |
Manage cookie preferences
You can modify your cookie settings anytime by clicking the ‘Consent Preferences’ button above. This will allow you to revisit the cookie consent banner and update your preferences or withdraw your consent immediately.
Additionally, different browsers offer various methods to block and delete cookies used by websites. You can adjust your browser settings to block or delete cookies. Below are links to support documents on how to manage and delete cookies in major web browsers.
Chrome: https://support.google.com/accounts/answer/32050
Safari: https://support.apple.com/en-in/guide/safari/sfri11471/mac
If you are using a different web browser, please refer to its official support documentation.
5. HOW WE USE YOUR PERSONAL DATA
We use personal data collected through this website for the following purposes:
- To respond to enquiries and requests submitted through our contact form.
- To process and evaluate job applications submitted via the website.
- To monitor and improve the performance, security, and user experience of our website through analytics.
- To comply with any applicable legal or regulatory obligations.
In accordance with DPP 3, we will not use your personal data for any new purpose without first obtaining your consent or having a lawful basis to do so.
6. RETENTION OF PERSONAL DATA
In accordance with DPP 2, we retain personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulation.
- Contact form enquiries: up to 2 years from the date of last interaction.
- Job application data: up to 12 months from the date of application if unsuccessful; longer if an offer of employment is made and accepted.
- Website analytics data: as configured in our analytics provider’s settings (typically up to 26 months).
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an individual.
7. SECURITY OF PERSONAL DATA
In accordance with DPP 4, we take all practicable steps to protect personal data held by us against unauthorised or accidental access, processing, erasure, loss, or use. Our security measures include secure server infrastructure, access controls, encryption in transit, and regular security reviews.
While we implement appropriate security safeguards, no method of data transmission or storage can be guaranteed as completely secure. You share personal data with us at your own risk and are encouraged to take appropriate precautions when submitting information online.
8. SHARING OF PERSONAL DATA
We do not sell, rent, or trade personal data. We may share personal data with third parties in the following limited circumstances, and only to the extent necessary:
- Service providers: third-party suppliers engaged to provide services on our behalf (e.g. website hosting, analytics), who are contractually bound to process data only on our instructions and in accordance with the PDPO.
- Legal or regulatory obligations: where disclosure is required by law, court order, or a competent regulatory authority in Hong Kong or another applicable jurisdiction.
- Business transfers: in connection with a merger, acquisition, or restructuring, personal data may be transferred as part of that transaction, subject to equivalent data protection obligations.
9. TRANSFER OF PERSONAL DATA OUTSIDE HONG KONG
Where we transfer personal data to a place outside Hong Kong, we take all practicable steps to ensure that the recipient provides a standard of protection at least comparable to that afforded under the PDPO. This may include contractual data protection clauses or reliance on adequacy assessments.
Transfers will only take place where we are satisfied that appropriate protections are in place and where the transfer is necessary for the purpose for which the data was collected.
10. YOUR RIGHTS UNDER THE PDPO
Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the following rights in relation to your personal data:
- Right of access (DPP 6): you may submit a Data Access Request to obtain a copy of any personal data we hold about you.
- Right to correction (DPP 6): you may submit a Data Correction Request if you believe any personal data we hold about you is inaccurate.
- Right to be informed: at or before the time of collection, you are entitled to be informed of the purposes for which your data is being collected and the classes of persons to whom it may be transferred (DPP 1).
To exercise any of the above rights, please contact us in writing at [email protected]. We will respond within 40 days of receiving your request, in accordance with the PDPO. We may charge a reasonable fee for handling Data Access Requests as permitted by law.
11. THIRD-PARTY WEBSITES
Our website may contain links to external websites operated by third parties. This Privacy Policy does not apply to those websites, and we are not responsible for their privacy practices or content. We encourage you to review the privacy policies of any third-party sites you visit.
12. CHILDREN
Our website is not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you become aware that a child has provided us with personal data without appropriate consent, please contact us and we will take steps to delete that data promptly.
13. CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time to reflect changes in law, our business practices, or the nature of our website. The most current version will be published on our website with an updated date. We encourage you to check this page periodically.
14. COMPLAINTS AND THE PRIVACY COMMISSIONER
If you have any concerns about how we handle your personal data, please contact us in the first instance at [email protected] so that we may seek to resolve the matter.
You also have the right to lodge a complaint with the Privacy Commissioner for Personal Data (PCPD):
DDX Group Limited | Reg. No. 79607025-000-01-26-2 | Body Corporate, HK 6/F Wyndham Place, 40-44 Wyndham Street, Central, Hong Kong