Privacy Policy

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1. Introduction
HORIZON LINKTECH INTERNATIONAL LIMITED (trading as CLEAR PASS) collects and uses personal data when you visit our website, contact us, or buy our products. We respect your privacy. This policy explains how we collect, use and protect personal data under the Personal Data (Privacy) Ordinance (Cap. 486) (‘PDPO’).

2. Data Collection Overview
We process various categories of personal information to provide our services:
• Identity and Contact: Legal name, professional title, email, phone number, and company details.
• Technical and Usage: IP addresses, device signatures, browser specifications, and site navigation patterns.
• Transactional: purchase history and payment status (payments are processed by Stripe).
• This site uses cookies and similar technologies provided by our website host (Wix) to run and improve the site. We do not currently run advertising campaigns. The banner lets you accept, deny or choose your settings.

3. Methods of Acquisition
Data is gathered through:
• Direct Engagement: A Personal Information Collection Statement is displayed at the point of data collection on our contact form.
• Automated Systems: Tracking technologies like cookies as you interact with our digital platform.
• External Partners: Transaction-specific data received from payment processors.

4. Purpose of Use
We use your personal data to:
• Respond to your enquiry;
• Process and deliver your order and keep financial records;
• Meet legal requirements. and
• Send you information about our products, Send you information about our products, only if you have agreed (for example, by ticking the box on our contact form or at checkout). You can opt out at any time by replying “unsubscribe” or emailing info@clearpasshk.com.

5. Data Sharing Protocols
We do not trade or sell personal data. Information is shared with essential service providers for operational purposes:
• Professional advisers such as our auditors, accountants and solicitors.
• Stripe (Global):  payment processing.
• Wix (Global):  website hosting.
• Google Workspace (Global):  communication services.                                                                                                                                                                             

   These providers may process data outside Hong Kong.

6. Security Safeguards
To uphold data integrity, we employ:
• HTTPS encryption on our website.
• Card payments are handled by Stripe. We do not store your card details.     

• Access to personal data on our own systems is limited to those who need it for their work: the Director and, where required, our professional advisers. Our service providers (Section 5) process data on our behalf.

7. Retention Schedule
• Enquiries and emails: Kept for up to 2 years after our last contact, then deleted.
• Purchase and financial records: Kept for 7 years, as Hong Kong law requires.
• Marketing contacts: Kept until you opt out, or 2 years after our last contact. We keep your opt-out record so we do not contact you again.
• Website usage data: Kept according to our website provider’s settings (Wix).

8. Your Rights Under PDPO
Under the PDPO you may ask whether we hold your personal data and request a copy; ask us to correct inaccurate data; and opt out of product information at any time, free of charge, by replying ‘unsubscribe’ or emailing info@clearpasshk.com. We will respond to access and correction requests within 40 days. Some records, such as financial transaction records, must be kept for the period Hong Kong law requires, even if you ask us to delete them. To make a request, contact us at info@clearpasshk.com.
 

9. Contact Details
For enquiries regarding this Privacy Policy or to exercise your rights under the PDPO, please contact: HORIZON LINKTECH INTERNATIONAL LIMITED (trading as CLEAR PASS), The Director, by email at info@clearpasshk.com  or by post to: Suite 2311, 23/F, BEA Tower, Millennium City 5, 418 Kwun Tong Road, Kwun Tong.

10. Policy Amendments
We reserve the right to modify this policy. Significant updates will be communicated via our website or direct email. The most current version remains effective immediately upon posting.