Privacy Policy

1. Introduction

HK CoSec AI ("we", "our", or "us") is a company secretarial and compliance management platform that helps Hong Kong companies manage their statutory obligations, including annual returns, business registration renewals, and regulatory filings.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform and services. By accessing or using our services, you consent to the practices described in this policy.

2. Information We Collect

We collect the following types of information to provide and improve our services:

• Company Information: Company name, business registration number, Companies Registry number, incorporation date, registered and business addresses, nature of business, share capital, and financial year-end.
• Personal Information: Names, email addresses, phone numbers, HKID or passport numbers, nationalities, and residential addresses of directors, shareholders, and significant controllers.
• Documents: Statutory documents, government letters, certificates, and filings uploaded to or generated through the platform.
• Usage Data: IP address, browser type, pages visited, access times, and device information.
• Telegram Data: Telegram chat ID and username, collected only when you voluntarily link your Telegram account for reminder notifications.
• Authentication Data: Information received from Google Sign-In (name, email, profile picture) when you choose to authenticate with Google.

3. How We Use Your Information

We use the collected information for the following purposes:

• Managing statutory compliance, including annual returns (NAR1), business registration renewals, and Significant Controllers Register (SCR) maintenance.
• Preparing and filing documents with Hong Kong government departments on your behalf.
• Sending compliance reminders and notifications via email and Telegram.
• Providing AI-powered document analysis, letter review, and form-filling assistance.
• Managing team access, permissions, and multi-company workflows within your account.
• Processing subscription payments and managing your account and billing.
• Improving our platform, developing new features, and providing customer support.
• Complying with applicable legal and regulatory obligations.

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

• Government Departments: With the Companies Registry, Inland Revenue Department, Labour Department, and other relevant Hong Kong authorities when filing statutory documents on your behalf or as required by law.
• Service Providers: Third-party providers who assist us in operating the platform, such as cloud hosting, payment processing, and AI service providers, under appropriate data protection agreements.
• Team Members: With other members of your company's team who have been granted appropriate access permissions by an administrator.
• Legal Compliance: When required by law, court order, or government authority, or to protect our rights, property, or safety.
• Business Transfers: In connection with a merger, acquisition, or sale of all or a portion of our assets.

5. Data Security

We implement industry-standard technical and organizational security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include encryption of data in transit and at rest, role-based access controls, regular security reviews, and secure authentication protocols.

Despite these measures, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security, but we strive to use commercially acceptable means to protect your information.

6. Data Retention

We retain your information for as long as necessary to provide our services and fulfill the purposes described in this policy. When you close your account or request deletion, we will remove or anonymize your personal data, except where retention is required by Hong Kong law or for legitimate business purposes such as audit, compliance, or dispute resolution.

7. Your Rights

Under the Hong Kong Personal Data (Privacy) Ordinance (PDPO), you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request correction of inaccurate or incomplete personal data.
• Deletion: Request deletion of your personal data, subject to legal retention requirements.
• Consent Withdrawal: Withdraw consent to the processing of your data where processing is based on consent.
• Objection: Object to certain processing of your personal data.

To exercise any of these rights, please contact us through the platform's support channels.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to operate and improve our platform, remember your preferences, and analyze usage patterns. You can control cookies through your browser settings, but disabling them may affect platform functionality.

9. Third-Party Services

We integrate with third-party services including Google (for authentication), Telegram (for notifications), and payment processors. These services may collect and process information subject to their own privacy policies. We encourage you to review the privacy policies of these third-party services.

10. Children's Privacy

Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us so we can take appropriate action.

11. International Data Transfers

While our services are primarily designed for Hong Kong companies, some data may be processed or stored on servers located outside of Hong Kong by our service providers. We take reasonable steps to ensure that such transfers comply with applicable data protection laws.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by posting the updated policy on this page and updating the 'Last updated' date. We encourage you to review this policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us through the support channels available within the HK CoSec AI platform.