Privacy Policy

Effective Date: 1 February 2026

1. Introduction

Smart Tech Media ("we," "us," or "our") is a digital marketing and web development company incorporated and operating in the Hong Kong Special Administrative Region ("Hong Kong"). Our registered address is Unit 11/11F, Peninsula Centre, No. 67 Mody Road, Kowloon, Hong Kong.

We are committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, store, and disclose personal data when you visit our website at smarttechmedia.net (the "Website") or engage with our services. It also describes your rights in relation to your personal data and how you can exercise them.

By accessing or using our Website, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with the practices described herein, please refrain from using our Website or providing us with your personal data.

2. Information We Collect

2.1 Personal Information You Provide

We collect personal data that you voluntarily provide to us when you interact with our Website. This includes, but is not limited to:

  • Contact Form Submissions: When you use our contact form, we collect your name, email address, and any additional information you choose to include in your message.
  • Service Enquiries: When you enquire about our digital marketing or web development services, we may collect your name, company name, email address, phone number, and details about your project requirements.
  • Business Communications: Any information you provide to us through direct correspondence, including email exchanges and telephone conversations.

2.2 Information Collected Automatically

When you visit our Website, certain information is collected automatically through technical means:

  • Usage Data: Pages visited, time spent on pages, navigation paths, referring URLs, and exit pages.
  • Device Information: Browser type and version, operating system, screen resolution, and device type (desktop, tablet, or mobile).
  • Network Information: IP address, approximate geographic location (city or region level), and internet service provider.
  • Interaction Data: Click patterns, scroll depth, and form interaction data used to improve user experience.

2.3 Cookies and Similar Technologies

Our Website uses cookies and similar tracking technologies to enhance your browsing experience and collect analytical data. Cookies are small text files stored on your device that help us recognise your browser and capture certain information. For detailed information about the cookies we use, their purposes, and how to manage them, please refer to our Cookie Policy.

3. How We Use Your Information

We use the personal data we collect for the following purposes:

  • Responding to Enquiries: To process and respond to your contact form submissions, service enquiries, and other communications in a timely manner.
  • Service Delivery: To provide, manage, and improve the digital marketing and web development services you have requested.
  • Website Improvement: To analyse how visitors use our Website so we can improve its content, functionality, navigation, and overall user experience.
  • Analytics and Performance: To monitor and analyse Website traffic, usage trends, and performance metrics to ensure our Website operates effectively.
  • Marketing Communications: With your prior consent, to send you information about our services, industry insights, or promotional materials that may be of interest to you. You may opt out of marketing communications at any time.
  • Legal Compliance: To comply with applicable laws, regulations, legal processes, or enforceable governmental requests.
  • Security: To detect, prevent, and address fraud, security vulnerabilities, or other technical issues that may affect our Website or services.

4. Legal Basis for Processing

We process your personal data on the following legal grounds:

  • Consent: Where you have given us clear, informed, and voluntary consent to process your personal data for specific purposes, such as receiving marketing communications or submitting a contact form. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
  • Legitimate Interests: Where the processing is necessary for our legitimate business interests, provided those interests are not overridden by your rights and freedoms. This includes improving our Website, analysing usage patterns, and ensuring the security of our services.
  • Contract Performance: Where the processing is necessary to perform a contract we have entered into with you, or to take steps at your request before entering into a contract. This includes processing data to deliver our digital marketing and web development services.
  • Legal Obligation: Where the processing is necessary for compliance with a legal obligation to which we are subject under Hong Kong law or other applicable legislation.

5. Data Sharing and Third Parties

We do not sell, rent, trade, or otherwise commercially transfer your personal data to third parties. We value your trust and are committed to safeguarding the personal data you share with us.

However, we may share your personal data with the following categories of third parties where necessary:

  • Service Providers: We use third-party service providers to support the operation of our Website and the delivery of our services. For example, we use EmailJS to process contact form submissions. These providers are contractually obligated to use your data only for the purposes we specify and to protect it in accordance with this Privacy Policy.
  • Analytics Providers: We use analytics tools (such as Google Analytics) to understand Website usage patterns and improve our services. These providers may collect anonymised or aggregated data about your Website activity.
  • Professional Advisors: We may share data with our legal, accounting, or other professional advisors where necessary for the management of our business.
  • Legal Obligations: We may disclose your personal data if required to do so by law, regulation, court order, or other governmental or regulatory authority in Hong Kong or elsewhere. We may also disclose personal data where necessary to establish, exercise, or defend our legal rights.
  • Business Transfers: In the event of a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred to the successor entity, provided the successor agrees to handle your data in accordance with this Privacy Policy.

6. Hong Kong Personal Data (Privacy) Ordinance Compliance

As a Hong Kong-based company, we are committed to full compliance with the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") administered by the Office of the Privacy Commissioner for Personal Data, Hong Kong. Our data handling practices adhere to the six Data Protection Principles ("DPPs") set out in Schedule 1 of the PDPO:

DPP 1 — Purpose and Manner of Collection of Personal Data

We collect personal data for lawful purposes directly related to our business functions and activities. The data collected is adequate but not excessive in relation to those purposes. We take reasonable, practicable steps to inform you of the purposes for which your data will be used, whether it is obligatory or voluntary to provide the data, and the consequences of failing to provide obligatory data.

DPP 2 — Accuracy and Duration of Retention of Personal Data

We take all practicable steps to ensure that the personal data we hold is accurate and not misleading, having regard to the purposes for which it is used. We do not keep personal data longer than is necessary for the fulfilment of the purpose for which it was collected, unless retention is required by law.

DPP 3 — Use of Personal Data

Personal data is used only for the purposes for which it was collected, or for a directly related purpose, unless we have obtained your prescribed consent for a new use. We will not use your data for direct marketing purposes without first obtaining your consent.

DPP 4 — Security of Personal Data

We take all practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss, or use, having regard to the nature of the data, the potential harm that could result, the physical location where the data is stored, any security measures incorporated into equipment used, and measures taken to ensure the integrity and competence of persons having access to the data.

DPP 5 — Information to Be Generally Available

We take all practicable steps to ensure that any person can ascertain our policies and practices in relation to personal data, including the types of personal data we hold and the main purposes for which personal data is used. This Privacy Policy serves as a primary means of fulfilling this obligation.

DPP 6 — Access to Personal Data

You have the right to request access to and correction of your personal data held by us. We are committed to complying with data access and correction requests in accordance with the procedures and timeframes set out in the PDPO. Please see Section 9 (Your Rights) below for further details on how to exercise these rights.

7. International Data Transfers

As a company that uses international service providers and operates a globally accessible Website, your personal data may be transferred to, stored in, or processed in jurisdictions outside of Hong Kong. These jurisdictions may have data protection laws that differ from those in Hong Kong.

Where we transfer personal data outside of Hong Kong, we take reasonable steps to ensure that your data receives an adequate level of protection, in accordance with Section 33 of the PDPO (when in force) and applicable regulatory guidance. Such steps may include:

  • Using service providers that are bound by contractual obligations to protect your personal data to a standard consistent with the PDPO.
  • Ensuring that data is transferred to jurisdictions that provide an adequate level of data protection.
  • Implementing appropriate technical and organisational safeguards to secure data during transfer and storage.

8. Data Retention

We retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements. In determining the appropriate retention period, we consider:

  • The nature and sensitivity of the personal data.
  • The potential risk of harm from unauthorised use or disclosure.
  • The purposes for which we process the data and whether we can achieve those purposes through other means.
  • Applicable legal, regulatory, and contractual requirements.

As a general guide:

  • Contact form submissions are retained for up to 24 months from the date of your last interaction with us, unless a longer period is required for an ongoing business relationship or legal obligation.
  • Client project data is retained for the duration of the client relationship and for a reasonable period thereafter to fulfil contractual and legal obligations.
  • Analytics data is generally retained in anonymised or aggregated form and may be kept for longer periods for trend analysis and service improvement.
  • Cookie data is retained in accordance with the durations specified in our Cookie Policy.

When personal data is no longer required, we will securely delete or anonymise it in accordance with our data retention procedures.

9. Your Rights

Under the PDPO and applicable data protection laws, you have the following rights in relation to your personal data:

  • Right of Access: You have the right to request a copy of the personal data we hold about you. We will respond to data access requests within 40 days of receiving the request, in accordance with the PDPO. A reasonable fee may be charged to cover the cost of complying with the request.
  • Right of Correction: You have the right to request the correction of any personal data that is inaccurate, incomplete, or misleading. We will make the necessary corrections within 40 days of receiving a valid correction request.
  • Right to Deletion: You may request that we delete your personal data where it is no longer necessary for the purposes for which it was collected. We will assess such requests on a case-by-case basis, taking into account our legal obligations and legitimate business interests.
  • Right to Opt Out of Marketing: You have the right to opt out of receiving direct marketing communications from us at any time. You can do so by using the unsubscribe mechanism provided in our marketing emails or by contacting us through our Website.
  • Right to Withdraw Consent: Where we process your data based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

To exercise any of these rights, please contact us using the contact form on our Website. We may need to verify your identity before processing your request to ensure the security of your personal data.

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

10. Data Security

We take the security of your personal data seriously and implement appropriate technical and organisational measures to protect it against unauthorised access, alteration, disclosure, or destruction. Our security measures include:

  • Use of SSL/TLS encryption to secure data transmitted between your browser and our Website.
  • Regular review and updating of our security practices to address evolving threats.
  • Restricting access to personal data to authorised personnel on a need-to-know basis.
  • Use of reputable and secure third-party service providers with appropriate data protection commitments.
  • Periodic assessment of our data handling and storage practices.

While we strive to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee the absolute security of your data, but we are committed to taking all practicable steps to minimise risks.

11. Children's Privacy

Our Website and services are intended for individuals who are at least 18 years of age. We do not knowingly collect, solicit, or process personal data from anyone under the age of 18. If we become aware that we have inadvertently collected personal data from a person under 18, we will take immediate steps to delete that data from our records.

If you are a parent or guardian and believe that your child has provided us with personal data without your consent, please contact us through the contact form on our Website, and we will take prompt action to remove the information.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the "Effective Date" at the top of this page and, where appropriate, provide notice through our Website.

We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data. Your continued use of our Website after any changes to this Privacy Policy constitutes your acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, please reach out to us using the contact form on our Website:

  • Website: smarttechmedia.net
  • Address: Unit 11/11F, Peninsula Centre, No. 67 Mody Road, Kowloon, Hong Kong

We will endeavour to respond to all enquiries within a reasonable timeframe and are committed to resolving any data protection concerns you may have.

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