Privacy Policy

Koi Stream ("we", "our", "us") is committed to protecting the personal data of everyone who interacts with our services and website. This Privacy Policy explains how we collect, use, store, and protect personal data, and describes your rights under Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). Please read this document carefully.

1. Introduction and Scope

This Privacy Policy applies to personal data collected through our website at https://koistrem.digital, our contact forms, and in connection with our service engagements. It does not apply to third-party websites we may link to. By using our website or engaging our services, you acknowledge having read and understood this policy.

2. Data Controller

The data controller for personal data collected through this website and our services is:

• Koi Stream
• 9 Tai Po Road, Tai Po, New Territories, Hong Kong
• Email: [email protected]
• Phone: +852 5629 4871

3. What Personal Data We Collect

We collect the following categories of personal data:

• Contact information: Name, email address, phone number, when provided through our contact form or during service engagement setup.
• Organisation information: Business name, role, and operational context shared during enquiries or project scoping.
• Website usage data: IP address, browser type, pages visited, and session duration, collected through analytics cookies when consent is given.
• Correspondence records: Records of email or telephone exchanges with our team.

We do not collect sensitive personal data (such as health, financial, or biometric data) through this website.

4. How We Collect Personal Data

• Directly, when you complete our contact form or send us an email
• During telephone conversations with our team
• Through analytics cookies (when you have given consent)
• During service engagement scoping and implementation

5. Legal Basis for Processing

We process personal data on the following bases under the PDPO:

• Consent: For analytics cookies and marketing communications, where you have explicitly opted in.
• Contractual necessity: To deliver the services you have engaged us to provide.
• Legitimate interests: To respond to enquiries, maintain records, and improve our services, where these interests are not overridden by your data protection rights.
• Legal compliance: Where we are required to process data to comply with applicable law.

6. How We Use Personal Data

• To respond to your enquiries and provide the information you have requested
• To scope, deliver, and support our AI integration services
• To send you service-related communications (not marketing, unless consented)
• To maintain records of our engagements for accounting and legal purposes
• To analyse website usage and improve our digital presence (analytics cookies, when consented)

7. Data Retention

• Enquiry records: Retained for 24 months from last contact if no engagement follows.
• Client engagement records: Retained for 7 years from engagement close, in accordance with Hong Kong accounting and business record requirements.
• Analytics data: Retained for 14 months, consistent with standard analytics practice.
• Cookie consent records: Retained for 12 months.

Data is deleted or anonymised when the retention period expires.

8. Data Sharing with Third Parties

We do not sell or rent personal data to third parties. We may share data with:

• Service providers: Such as email hosting providers and website analytics services, who process data on our behalf under data processing agreements.
• Professional advisors: Such as accountants or legal advisors, where necessary.
• Regulatory authorities: Where required by law or court order.

We require all third-party processors to maintain appropriate data protection standards.

9. Data Protection Measures

• Data is transmitted via TLS-encrypted connections (HTTPS)
• Access to personal data is restricted to team members who require it for their work
• Passwords and credentials are managed using secure practices
• We review our data handling practices annually
• In the event of a data breach affecting your rights, we will notify you and the Office of the Privacy Commissioner for Personal Data (PCPD) as required under applicable law

10. Cookies

We use cookies on this website. Please see our Cookie Policy for full details of the cookies we use and how to manage your preferences. In summary:

• Essential cookies: Required for the website to function. Always active.
• Analytics cookies: Help us understand how the website is used. Require consent.
• Marketing cookies: Used for advertising purposes. Require consent.
• Preference cookies: Remember your settings. Require consent.

11. Your Rights Under the PDPO

Under Hong Kong's Personal Data (Privacy) Ordinance, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request that inaccurate or incomplete data be corrected.
• Erasure: Request deletion of your data where it is no longer needed for the purposes for which it was collected.
• Object to direct marketing: Opt out of any direct marketing communications at any time.
• Withdraw consent: Where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.
• Lodge a complaint: Complain to the Office of the Privacy Commissioner for Personal Data (PCPD) at www.pcpd.org.hk if you believe your rights have been infringed.

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days, as required by the PDPO.

12. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of those sites and encourage you to review their privacy policies before providing personal data.

13. Children's Privacy

Our services are directed at business organisations and professional decision-makers. We do not knowingly collect personal data from persons under the age of 18. If we become aware that we have collected data from a minor, we will delete it promptly.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, the "Last Updated" date at the top of this page will be revised. For material changes, we will take reasonable steps to notify affected individuals. Continued use of our website following an update constitutes acceptance of the revised policy.

15. Contact

For any questions about this Privacy Policy or to exercise your data rights, contact us at:

• Email: [email protected]
• Phone: +852 5629 4871
• Address: 9 Tai Po Road, Tai Po, New Territories, Hong Kong