1. Introduction
HORIZON LINKTECH INTERNATIONAL LIMITED (trading as CLEAR PASS) is dedicated to maintaining the trust of our visitors. We prioritize the security of your information across all interactions, from website visits to product purchases. This policy operates in strict adherence to the Personal Data (Privacy) Ordinance (PDPO) — Cap. 486 of the Laws of Hong Kong.

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: History of purchases and payment synchronization (facilitated via Stripe).

3. Methods of Acquisition
Data is gathered through:
• Direct Engagement: Information provided when completing forms, emailing our team, or placing orders.
• Automated Systems: Tracking technologies like cookies as you interact with our digital platform.
• External Partners: Transaction-specific data received from secure payment processors.

4. Purpose and Legal Grounds
We utilize your data based on defined legal frameworks:
• Inquiry Response: Managed under legitimate interest.
• Order Fulfillment: Necessary for contractual obligations.
• Product Communications: Conducted under legitimate interest.
• Regulatory Compliance: Required by law.

5. Data Sharing Protocols
We do not trade or sell personal data. Information is shared with essential service providers for operational purposes:
• Stripe (Global): Secure payment processing.
• Wix (Global): Reliable website hosting.
• Google Workspace (Global): Professional communication services.
• Hong Kong Solicitor: Legal counsel and review when necessary.

6. Security Safeguards
To uphold data integrity, we employ:
• Site-wide SSL (HTTPS) encryption.
• Restricted server environments.
• Comprehensive security assessments.
• Strict internal access controls.

7. Retention Schedule
• General Inquiries and Emails: Retained for 3 years.
• Financial Records: Retained for 7 years to meet statutory requirements.

8. Your Rights Under PDPO
In accordance with the Personal Data (Privacy) Ordinance, you are entitled to:
• Review and access your stored data.
• Request corrections to inaccuracies.
• Seek the deletion of your personal records.
• Revoke your consent for data processing at any time.

To exercise these rights, please reach out to us at info@clearpasshk.com.

9. Contact Details
For inquiries regarding these practices:
• Email: info@clearpasshk.com
• Location: Kwun Tong, Hong Kong

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.