1. Introduction
This Privacy Policy explains how Bletchley Consulting Services Limited ("Bletchley", "we", "us", "our"), a company incorporated in Hong Kong, collects, uses, discloses and protects personal data in connection with the website at bletchley.cc and our related services (together, the "Services").
We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
2. Information we collect
Information you give us. Name, business name, email address, phone number, and any other details you provide when you contact us, request a demonstration, subscribe to updates or enter into an agreement with us.
Information collected automatically. IP address, browser and device type, pages viewed, referring page, and approximate location derived from IP address. This is collected through server logs and, where used, cookies and similar technologies.
Messaging data. Where you interact with us or with a service we operate through a messaging platform, we receive the content of your messages, your platform identifier (such as a phone number or profile name) and associated timestamps.
Client data. Where we provide services to a business client, we may process data on that client's behalf and under their instructions. In those cases the client is the data user and we act as a data processor.
We do not intentionally collect sensitive personal data, and we do not knowingly collect data from children.
3. How we use information
We use personal data to:
- provide, operate, maintain and improve the Services;
- respond to enquiries and provide customer and technical support;
- communicate about the Services, including service notices and, where you have opted in, marketing;
- monitor usage, diagnose faults, and protect against fraud, abuse and security incidents;
- comply with legal and regulatory obligations.
We use direct marketing only where you have consented, and you may withdraw consent at any time at no cost.
4. Legal basis and consent
We collect personal data on a voluntary basis. If you choose not to provide requested information, we may be unable to provide the Services or respond to your enquiry. Where required, we rely on your consent, and otherwise on our legitimate business interests and legal obligations.
5. How we share information
We do not sell personal data. We may disclose personal data to:
- Service providers who support the Services, such as hosting, database, analytics, email and messaging providers, acting on our instructions and under confidentiality obligations;
- Business clients, where the data was collected on their behalf;
- Professional advisers, such as legal and accounting advisers;
- Authorities, where disclosure is required by law, regulation or legal process, or to protect our rights, users or the public.
Our service providers may be located outside Hong Kong. Where personal data is transferred across borders, we take reasonable steps to ensure it is afforded protection comparable to that required under Hong Kong law.
6. Cookies
We may use cookies and similar technologies to operate the website, remember preferences and understand usage. Most browsers allow you to refuse or delete cookies. Disabling cookies may affect how parts of the website function.
7. Data retention
We retain personal data only for as long as necessary for the purposes described in this Policy, or for as long as required by law or by a client agreement. Data that is no longer needed is deleted or anonymised.
8. Security
We apply reasonable technical and organisational measures to protect personal data against unauthorised access, use, alteration or loss, including access controls, encryption in transit and restricted internal access. No system is completely secure, and we cannot guarantee absolute security.
9. Your rights
Subject to applicable law, you have the right to:
- request access to the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- withdraw consent to direct marketing;
- request deletion of your data where we are no longer required to retain it.
To exercise these rights, contact us through the contact channel published on our website. We may need to verify your identity before responding, and a reasonable fee may be charged for data access requests as permitted by law.
10. Third-party links and platforms
The Services may link to or operate on third-party websites and platforms, including messaging platforms. Those third parties have their own privacy policies, which govern their handling of your data. We are not responsible for their practices.
11. Changes to this Policy
We may update this Privacy Policy from time to time. The current version will always be posted on this page with its effective date. Material changes will be brought to your attention where appropriate.