Privacy - Soverign 21 Consulting

Privacy Policy
Last updated: June 9, 2025

Welcome to Sovereign 21 Consulting. Sovereign 21 Consulting Limited (“Sovereign 21”, “we”, “us”, or “our”) owns and operates the website located at sov21.com (the “Website” and collectively with any connected software or other products, the “Site”).

This Privacy Policy describes our policies and procedures on the collection, use, and disclosure of your information when you use our Service, including consultations booked via phone or Zoom, and informs you about your privacy rights under Hong Kong law. This document is part of Sovereign 21’s Terms of Service. By accessing or using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Collecting and Using Your Personal Data
Types of Data Collected

Personal Data
When you contact us, book consultations, or engage our services, we may collect personally identifiable information to communicate with you or fulfill our services. This may include:

Email address
First name and last name
Phone number
Company name and position
Billing address (for invoicing)

Usage Data
Usage Data is collected automatically when you visit our Site. This may include:

Your device’s Internet Protocol (IP) address
Browser type and version
Pages visited, time, and date of visit
Time spent on pages
Unique device identifiers and diagnostic data

For mobile access, we may collect:

Mobile device type, unique ID, IP address
Mobile operating system and browser
Other diagnostic data

Tracking Technologies
We use cookies and similar technologies (e.g., web beacons, tags) to track Site activity and improve our Service. Technologies include:

Cookies: Small files stored on your device. You can refuse cookies via browser settings, but this may limit Site functionality. We use:
- Necessary Cookies (Session): Enable Site features, administered by us.
- Analytics Cookies (Persistent, Third-Party): Track traffic and usage trends, administered by service providers (e.g., Google Analytics).
Web Beacons: Small electronic files in emails or pages to count visits or track email opens.

We do not use cookies for user accounts or personalized features, as our Service does not offer login access.

Use of Your Personal Data
We do not sell or rent your Personal Data to third parties for marketing purposes. We may use Personal Data to:

Provide and maintain our Service, including consultations and invoicing.
Contact you via email or phone regarding bookings, services, or updates.
Process payments through invoices (in HKD).
Conduct internal analysis to improve our Service and understand client needs.
Manage client requests and communications.
Comply with legal obligations or evaluate business transfers (e.g., mergers).

We may share Personal Data:

With Service Providers: To analyze Site usage (e.g., Google Analytics) or process payments.
For Business Transfers: During mergers, acquisitions, or asset sales.
With Consent: For other purposes, with your explicit agreement.

Retention of Your Personal Data
We retain Personal Data only as long as necessary for the purposes outlined, or to comply with legal obligations (e.g., PDPO requirements). Usage Data is retained for shorter periods for internal analysis, unless needed for security or legal purposes.

Transfer of Your Personal Data
Your data is processed in Hong Kong and may be transferred to other jurisdictions (e.g., service provider servers). We ensure secure transfers compliant with PDPO, using adequate data protection measures. Your consent to this Privacy Policy agrees to such transfers.

Disclosure of Your Personal Data
We may disclose Personal Data:

Business Transactions: If involved in mergers or asset sales, with prior notice.
Law Enforcement: If required by law or valid public authority requests (e.g., Hong Kong courts).
Other Legal Requirements: To comply with legal obligations, protect our rights, prevent wrongdoing, or ensure safety.

Security of Your Personal Data
We use commercially acceptable measures to protect your Personal Data, but no internet transmission or storage is 100% secure. We cannot guarantee absolute security.

Analytics
We use third-party providers for Site analytics:

Google Analytics: Tracks traffic and usage. Data may be shared with Google services. Opt out via the Google Analytics opt-out browser add-on (https://tools.google.com/dlpage/gaoptout). See Google’s Privacy Policy: https://policies.google.com/privacy.

Your Rights under PDPO
Under Hong Kong’s Personal Data (Privacy) Ordinance (PDPO), you have the right to:

Request access to your Personal Data we hold.
Request correction of inaccurate or incomplete Personal Data.
Request details on how your data is used.

To exercise these rights, contact us (details below). We may verify your identity before responding. You may also complain to the Privacy Commissioner for Personal Data (PCPD) in Hong Kong: https://www.pcpd.org.hk.

Opting Out of Analytics
You can opt out of analytics tracking via:

Google Analytics opt-out add-on (above).
Browser settings to block cookies (may limit Site functionality).
Industry platforms: NAI (http://www.networkadvertising.org/choices/), EDAA (http://www.youronlinechoices.com), DAA (http://optout.aboutads.info/).

Links to Other Websites
Our Site may link to third-party websites (e.g., custody providers). We are not responsible for their content or privacy practices. Review their policies before sharing data.

Changes to This Privacy Policy
We may update this Privacy Policy, posting changes on this page with an updated “Last updated” date. Continued use after changes constitutes acceptance. We may notify you via email for significant updates.