Privacy Policy

Overview and Scope

This Privacy Policy applies to all visitors of this website, to every user of the services we provide, and to every person who contacts us through email, telephone, or any other channel. It covers the information we collect when you browse this site, when you send us a message through our contact page, when you telephone us, and when you engage us to provide advisory or solutions work.

We act as the controller for the personal information described in this Policy. A controller is the organisation that decides why and how personal information is collected and used. In this role we take responsibility for ensuring that your information is handled lawfully, fairly, and transparently at every stage of its journey through our organisation.

This Policy does not apply to websites operated by third parties, even when a link from our site takes you to them. You should read the privacy policies of those third-party sites because their practices are outside our control and outside the promises we make in this document.

Key Definitions

To avoid confusion, we set out below the meaning of the main terms used throughout this Policy. These definitions follow the common practice of privacy legislation around the world, including the legislation of Hong Kong and the regulations of the European Union.

Personal Information

Any information that relates to an identified or identifiable living person. This includes a name, an email address, a telephone number, and any other detail that could be used to identify you.

Special Category Data

Information about race, ethnicity, political opinions, religion, health, sexual orientation, or similar sensitive subjects. We generally do not collect this information and we ask you not to send it to us.

Processing

Any operation performed on personal information, including collecting, recording, storing, organising, retrieving, using, disclosing, and deleting that information.

Controller

The organisation that decides why and how personal information is processed. For the purposes of this Policy, the controller is Impetus Solutions Limited.

Cookies

Small text files that a website stores on your device to remember information about you between visits.

Where other technical terms are used, you may contact us and we will gladly explain them in everyday language. We prefer plain writing over legal jargon, because we want you to understand exactly what happens to your information.

Information We Collect

The amount of information we collect depends on how you interact with us. We collect only what we genuinely need, and we are transparent about each item. The categories of information we may collect include the following.

• Identity information. Your full name, job title, and the name of the company you represent.
• Contact information. Your email address, telephone number, and postal address.
• Enquiry details. The content of any message or question you send to us through our contact page or by email.
• Engagement information. Information you provide during a client project, including the details of the business problems we are asked to help solve.
• Payment and billing information. Where you enter into a paid engagement, the invoicing details needed to bill you correctly.
• Correspondence. Records of our conversations with you, whether by email, telephone, or in person.

We collect most of this information directly from you when you choose to provide it. We do not buy personal information from data brokers, and we do not compile secret profiles of visitors. The information we hold is information you shared with us or information we created in the course of serving you.

Sensitive Information

We have no need for your health records, your racial or ethnic origin, your political opinions, your religious beliefs, or any other category of sensitive personal information. Our services are built around business strategy, operational design, and market research, and none of these require us to process sensitive personal data about private individuals.

We ask that you do not send us sensitive personal information about yourself or anyone else. If you do share such information with us by accident, we will use reasonable efforts to delete it and will not rely on it for any purpose. Where the law requires us to obtain your explicit consent before handling such information, we will do so separately and never presume it.

Privacy for Children

Our website and services are directed at businesses and professionals, and they are not intended for use by children. We do not knowingly collect personal information from anyone under the age of sixteen. Our services help companies solve commercial problems; they are not games, apps, or content designed for young people.

If you believe that a child has provided personal information to us without the consent of a parent or guardian, please contact us immediately at service@anjinxin.mom. We will take swift steps to locate the information and delete it from our records, and we will adjust our internal controls to reduce the chance of any similar occurrence in the future.

Automatic and Technical Information

Like most websites, we automatically collect certain technical information when you visit this site. This includes the type of browser you use, the operating system of your device, your approximate internet protocol address, the pages you view, the time of your visit, and the website that referred you to us.

This technical information helps us understand how the site performs, which pages are useful, and where visitors struggle. We use it in aggregated form to improve the experience for everyone. We do not use this data to build a profile of you as an individual, and we do not sell it to advertisers.

Cookies and Similar Technologies

We use a small number of cookies and similar technologies to make our website work properly and to remember your preferences. A cookie is a small file stored on your device. Some cookies are essential, which means the site cannot function without them. Others are used for measuring how the site is used so that we can improve it.

You can control cookies through your browser settings. Most browsers allow you to block cookies, delete existing ones, or ask for permission before a new cookie is placed. If you choose to block essential cookies, parts of the website may not function correctly, and you may not be able to use certain features.

We do not use cookies to place advertising, and we do not allow advertising partners to track you across other websites from our pages. Our use of cookies is limited and purposeful, and we review our practices regularly to keep them that way.

How We Use Your Information

We use the personal information we collect only for legitimate and clearly explained purposes. The main purposes are listed below.

• To respond to enquiries you send to us and to provide the information or help you request.
• To prepare proposals, agreements, and invoices for advisory and solutions work.
• To deliver the services you have engaged us to provide, including research, analysis, and recommendations.
• To keep our records accurate and to manage our ongoing relationship with clients.
• To meet our legal, regulatory, and accounting obligations.
• To protect the security of our systems and to prevent fraud or misuse.
• To improve our website, our services, and our internal processes.

We do not use your information for purposes that are incompatible with the purposes described above. If we ever wish to use your information for a new and substantially different purpose, we will tell you about that purpose before relying on it.

Legal Basis for Processing

Where the data protection law of your region requires a legal basis for processing personal information, we rely on one or more of the following foundations.

• Legitimate interests. We process information to run our business efficiently, to answer enquiries, and to improve our services, and we do so in a way that respects your interests and rights.
• Performance of a contract. Where you engage us for advisory work, we process the information necessary to deliver the agreed services and to manage the contract between us.
• Legal obligation. Where we are required to process information to comply with a law, a tax rule, or a regulatory requirement, we will do so.
• Consent. Where consent is required before we can process your information, we will ask for it freely and give you an easy way to withdraw it.

Where we rely on legitimate interests as our basis, we have balanced those interests against your rights and have concluded that our processing does not outweigh or override your freedom and your interests. If you disagree with that assessment, you may raise an objection, and we will review it seriously.

How We Share Information

We do not sell, rent, or trade your personal information to anyone. We share information only in the limited circumstances described below, and always in line with the law.

• With our professional team. Our members who need your information to perform their work will have access to it on a need-to-know basis.
• With service providers. We may share limited information with trusted providers who help us run our business, such as hosting, email, accounting, and IT support providers, and only to the extent they need it.
• As required by law. We may share information if a law, court order, or regulatory authority requires us to do so, and we will comply with valid requests.
• In a business transfer. If our business is sold, merged, or reorganised, your information may be transferred as part of that transaction, and the new owner will be bound by a policy no less protective than this one.

In every case of sharing, we insist that the recipient uses the information only for the purpose we have agreed and that they keep it secure. We review our sharing arrangements regularly to confirm that these promises are kept.

Service Providers and Processors

We rely on a small number of service providers to help us deliver our services and operate our website. These providers process information on our behalf and may therefore be treated as processors. We choose them carefully and we require them to protect your information to standards that meet or exceed our own.

When we appoint a processor, we put in place a written agreement that sets out clear obligations. That agreement requires the processor to process information only on our documented instructions, to protect the information with appropriate technical and organisational measures, and to return or delete the information when the engagement ends. We remain responsible for the actions of our processors.

You can request the current list of our processors at any time by writing to service@anjinxin.mom. We will provide a summary of the categories of providers we use and the safeguards that apply to them.

Data Retention

We keep personal information only for as long as we genuinely need it. The length of time we keep information depends on why we collected it in the first place and on any legal requirement that obliges us to keep it longer.

As a general guide, enquiry correspondence is retained for a short period after it is closed. Records relating to a paid client engagement are kept for the period required by accounting and tax rules in Hong Kong. Where a legal dispute or regulatory matter is ongoing, we may need to keep relevant information until that matter is fully resolved.

When information is no longer needed, we delete it or anonymise it so that it can no longer be linked to you. Our deletion practices are reviewed regularly, and we aim to erase information promptly once its purpose has passed.

Data Security Measures

Protecting your information is a matter we take seriously. We have put in place technical and organisational measures designed to keep personal information safe from loss, misuse, unauthorised access, alteration, and disclosure.

On the technical side, our systems are protected by access controls, secure network connections, and up-to-date software. On the organisational side, we limit access to personal information to those who need it for their work, and we train our people in privacy principles. We review our security arrangements regularly and adjust them in response to new risks.

No method of transmission over the internet and no method of storage is completely secure. We cannot promise absolute security, but we work hard to reduce risk to a level appropriate to the information we hold and the harm that a breach might cause.

International Transfers

Because our clients and team members are located in more than one country, the personal information we process may be transferred to and stored in a country other than the one where you are located. This can include transfers to locations that may not have the same data protection rules as your home country.

Where we transfer personal information across borders, we take steps to ensure that your information continues to be protected to a high standard. We rely on recognised safeguards such as standard contractual clauses or equivalent lawful mechanisms, and we check those safeguards are in place before any transfer occurs.

If you wish to learn more about the countries to which your information may be transferred and the safeguards that apply, you may contact us and we will provide further details.

Your Rights

Depending on where you live, you may hold a number of rights over the personal information we process about you. We set out the main rights below, and we honour them wherever the law recognises them.

• Right of access. You may ask for a copy of the personal information we hold about you.
• Right to rectification. You may ask us to correct information that is inaccurate or incomplete.
• Right to erasure. You may ask us to delete your personal information, subject to any legal requirement to keep it.
• Right to restriction. You may ask us to limit how we process your information in certain circumstances.
• Right to data portability. In some cases you may ask to receive your information in a structured, machine-readable format.
• Right to object. You may object to processing that relies on legitimate interests or on marketing.
• Right to withdraw consent. Where we process with your consent, you may withdraw that consent at any time.

To exercise any of these rights, please contact us at service@anjinxin.mom. We will respond to your request without undue delay and within the period allowed by law. We may ask for proof of identity before acting on a request, to make sure we do not release your information to anyone else.

Your Choices and Controls

You are always welcome to deal with us in ways that limit the information you share. You may browse our website without contacting us, and you choose what to include in any message you send. Nothing on our site forces you to provide more information than you wish to give.

You may control cookies through your browser, manage marketing preferences as described below, and correct the contact details you have provided to us at any time. If you tell us that you no longer wish to hear from us, we will respect that wish promptly and we will not make it difficult for you to contact us for genuine service reasons.

Marketing Communications

We send marketing or news communications only to people who have asked to receive them. Typical messages include updates about our services, occasional insights on business topics, and invitations to relevant events. We will not add you to a marketing list without your clear consent.

Every marketing message we send includes a simple and working way to opt out. When you opt out, we will stop sending you marketing communications without delay, and we will keep your choice on record so that we do not add you back by mistake. Opting out of marketing does not stop required service messages that concern an ongoing engagement with us.

Links to Other Websites

Our website may contain links to other websites operated by third parties. These links are provided for your convenience and because they may be relevant to the services we offer. Once you leave our website, this Privacy Policy no longer applies.

We are not responsible for the content, the privacy practices, or the data handling of any third-party website. Before you provide personal information to any third-party site, we encourage you to read its own privacy policy carefully and to decide whether its practices are acceptable to you.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our services, in the law, or in our internal practices. When we make a material change, we will revise the effective date shown at the top of this page and, where practical, notify you through the website.

We encourage you to review this Policy periodically so that you stay informed about how we protect your information. Your continued use of our website or services after a change takes effect means that you accept the revised Policy, unless the law requires us to obtain a fresh consent from you for a particular change.

If a change is significant, we may provide a more prominent notice so that you have the opportunity to review it before it takes effect.

Contacting Us

If you have any questions about this Privacy Policy, about how we handle your information, or about the rights described above, we would be glad to hear from you. You may reach our team by email at the address below.

We will acknowledge your message and respond as quickly as we can, normally within two working days. If you are not satisfied with how we address your concern, you may also raise the matter with the relevant data protection authority in your region, and we will cooperate fully with any lawful request.