Privacy policy

Who we are

SparkEvo is a website design and digital marketing team based in Hong Kong. We are the data user for the personal data described on this page, which means we decide how it is collected, held and used, and we are accountable for it.

You can reach us about anything on this page by email. The address for privacy questions is hello@sparkevo.tech.

What personal data we collect

Personal data is any information that can identify you, directly or indirectly. We collect only what we need, and it falls into two groups.

• What you give us through the free audit form: your name, email address and business name, plus anything optional you choose to add, such as a website address or a note on what you need.
• What you give us through the contact form: your name, email address, the service you are interested in and your message.
• Your consent choices: whether you agreed to be contacted, and whether you opted in to marketing messages.
• Technical information your browser sends automatically when you visit, such as your IP address, browser type, device type and the pages you view. If you agree to measurement, this also covers how you move through a page, such as clicks, taps and scrolling, with anything you type into a form and other sensitive content masked before it is sent.

How we collect it

Almost all of it comes directly from you, the moment you complete a form or send us an email.

The rest is collected automatically as you browse, by our hosting provider and, only when you consent, by our measurement tools. We do not buy personal data and we do not build profiles from third-party lists.

Why we use it, and our basis under the PDPO

We use your personal data for a short, specific list of purposes.

• To answer your enquiry and arrange the free audit you asked for.
• To prepare a quote or proposal if you request one.
• To deliver a service after you become a client.
• To send marketing messages, but only if you ticked the marketing box.
• To keep the site secure, block spam and understand how the site is used.

Under the Personal Data (Privacy) Ordinance (PDPO), the Hong Kong data privacy law, we rely on the consent you give when you submit a form, and on the legitimate running of our business to answer a request you have made. We will not use your data for a new purpose without telling you first.

Cookies and measurement

The site uses a small number of cookies. Essential cookies keep the site working. Measurement cookies help us understand how the site is used, and they are set only after you agree.

Measurement covers both numbers and behaviour. We count visits and see which pages are read, and, where a tool can record a session, we see how a page was used so we can find and fix the parts that confuse people. Anything you type into a form, and other sensitive content, is masked before it is sent, so it never reaches us or the provider.

You can change or withdraw your choice at any time, and the full list of cookies and tools is in the cookie policy.

Read the cookie policy →

Who we share it with

We never sell your personal data, and we never share it so that another business can market to you. We share it only with the providers that run the site and our email, and only as much as each one needs.

• Our hosting provider, which serves the site and receives the form submissions.
• Our email provider, which delivers and stores our email.
• Analytics and behaviour-measurement providers, meaning Google for Analytics 4 and Microsoft for Clarity, and only if you have consented to measurement.

These providers act on our instructions. We do not let them use your data for their own purposes.

Where your data is held

Form submissions and email are stored by our providers, and their servers may be located outside Hong Kong. When your data leaves Hong Kong this way, we take reasonable steps to keep it protected, including choosing providers with recognised security and privacy commitments.

How long we keep it

We keep enquiry data only as long as we need it. If an enquiry does not become work, we remove it within 24 months.

Where you become a client, we keep records for as long as the law requires us to keep them after the work ends, and then delete them.

When data is no longer needed, we delete it or remove the parts that identify you.

How we protect it

Data is sent to us over an encrypted connection and stored with providers that protect it in transit and at rest. Access is limited to the people who need it to answer you.

No system is perfect. If a breach ever puts your data at real risk, we will tell you and the relevant parties promptly.

Your rights

Under the PDPO you have the right to the following.

• Ask whether we hold personal data about you, and request a copy of it.
• Ask us to correct anything that is inaccurate.
• Withdraw your marketing consent at any time.
• Ask us to stop using your data, or to delete it where we do not need to keep it.

To make a request or a complaint, email us. We answer access and correction requests within 40 days, as the PDPO requires, and we may ask you to confirm your identity first so that your data is not released to someone else. If you are not satisfied with our response, you can raise the matter with the Office of the Privacy Commissioner for Personal Data in Hong Kong.

Marketing, and how to stop it

We send marketing messages only to people who opted in. Every message includes a way to unsubscribe, and unsubscribing takes effect straight away.

Withdrawing marketing consent never stops us answering an enquiry you have already sent.

Children

This site is built for businesses. We do not knowingly collect personal data from children. If you believe a child has given us data, contact us and we will remove it.

Changes to this policy

If we change how we handle personal data, we update this page and the last updated date at the top of it. A short note of what changed appears at the bottom of the page.

If a change is significant, we will make it clear rather than bury it.