Effective Date: 2nd May 2025
This Privacy Policy sets out the basis on which Bluesquare Strategy, a sole proprietorship registered in Hong Kong, with its registered office at 21st Floor, The Phoenix Building, No. 23 Luard Road, Wan Chai, Hong Kong S.A.R, and Business Registration No. 57445251-000-08-22-5 ("we," "us," or "Bluesquare Strategy") collects, uses, discloses, and processes personal data from you through our website www.bluesquarestrategy.com (our "Site"). By visiting our Site and providing personal data, you acknowledge the practices described below. For certain data processing, such as direct marketing or non-essential cookies, we will obtain your explicit consent through mechanisms like opt-in checkboxes or cookie banners.
Bluesquare Strategy is a Hong Kong-based consultancy providing business advisory services. We are committed to protecting your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and applicable laws.
1. Collection of Information
1.1 Types of Data We Collect
We may collect and process the following personal data about you for the purposes outlined in Clause 2:
(a) Information You Provide: Information such as your name, email address, phone number, and any details you include when submitting our contact form or corresponding with us (by email or phone). For example, we collect this data:
(b) Information We Collect Automatically: Information collected when you visit our Site, such as:
Technical information collected via Google Analytics, including your Internet Protocol (IP) address, browser type and version, operating system, and platform.
Information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through, and from our Site (including date and time), page response times, download errors, length of visits to certain pages, and page interaction data (e.g., scrolling, clicks, mouse-overs).
c) Information from Third Parties: We may receive data from third-party service providers, such as our website hosting provider or Google Analytics, for site performance analysis. We do not routinely receive personal data from other third parties, such as business partners, but if we do, we will notify you and specify the purposes for which we intend to use that data.
1.2 Data Retention
We retain personal data only for as long as necessary to fulfill the purposes outlined in Clause 2 or as required by law. For example:
Contact form data is retained for 12 months after your inquiry is resolved, unless required by law to retain longer.
We retain personal data only for as long as necessary to fulfill the purposes outlined in Clause 2 or as required by law. For example:
Data may be archived if the purpose for which it was collected still exists, after which it is securely deleted.
2. Uses of Your Information
2.1 Purposes of Data Use
We use your personal data for the following purposes:
Providing, improving, and developing our consulting services
Researching and enhancing our business advisory offerings.
Presenting content and information on our Site in the most effective manner for you and your device
Providing you with alerts, updates, or information about our services that you requested or signed up for.
Managing client relationships and responding to inquiries
Complying with applicable laws and regulations in Hong Kong and other jurisdictions where we operate
Responding to or participating in legal proceedings, including seeking professional advice.
Direct marketing, as detailed in Clause 2.2 below.
Communicating with you and addressing your questions or requests
Other purposes directly related or incidental to the above, such as maintaining records of client inquiries.
2.2 Direct Marketing
If we engage in direct marketing (e.g., offering or advertising our Business Consulting and Advisory services via email), we will require your explicit consent, obtained through an opt-in checkbox on our contact form or during correspondence. You may opt out at any time. For this purpose:
The personal data used are your name and email address provided under Clause 1.1(a).
The services offered are Business Consulting and Advisory services
Marketing information is sent via email.
You may opt out at any time by emailing contact@bluesquarestrategy.com or clicking the unsubscribe link in our emails. We will cease sending marketing communications at no charge.
3. Disclosure of Your Information
We keep your personal data confidential but may disclose it to:
Service providers, such as our website hosting provider or Google Analytics, who assist with our operations on a need-to-know basis.
Business partners or consultants, only with your consent or as necessary to provide our services (e.g., collaborating on a project).
Persons under a duty of confidentiality to us, such as legal or professional advisors
Persons to whom we are required to make disclosure under applicable laws and regulations in Hong Kong or other jurisdictions where we operate.
Actual or proposed transferees of our business operations in the event of a sale or merger.
We ensure all recipients are bound by confidentiality obligations or data protection agreements to safeguard your personal data. As a sole proprietorship, we have no subsidiaries or holding companies.
4. Cookies
4.1 Use of Cookies
Our Site uses cookies to distinguish you from other users, enhancing your browsing experience and improving our Site. We obtain your consent for non-essential cookies (e.g., analytical cookies) via a cookie banner displayed on your first visit.
4.2 What Are Cookies?
A cookie is a small file of letters and numbers stored on your browser or computer's hard drive if you agree. Cookies contain information transferred to your computer's hard drive.
4.3 Types of Cookies
We use persistent cookies, which remain in your browser for return visits, primarily for analytics. We use the following cookies:
(a) Analytical/Performance Cookies:
These allow us to recognize and count visitors and analyze how they navigate our Site, helping us improve functionality and ensure users find what they need easily (e.g., Google Analytics cookies).
4.4 Managing Cookies
You can block cookies by activating your browser's setting to refuse all or some cookies. However, this may prevent access to parts of our Site.
4.5 Third-Party Cookies
We use Google Analytics, which employs analytical/performance cookies, web server logs, and web beacons to analyze site usage. Google Analytics cookies track site usage anonymously, but IP addresses may be shared with Google, which may use it to personalize marketing materials for their network.
5. Third-Party Sites
Our Site may occasionally contain links to third-party websites over which we have no control. These websites have their own privacy policies, which we encourage you to review. We accept no responsibility or liability for the practices of third-party websites.
6. Security
6.1 Data Protection Measures
We use TLS/SSL encryption for data transmission and AES-256 encryption for stored data to protect your personal information. All data is stored on secure servers.
6.2 Access Restrictions
We restrict access to personal data to our service providers (e.g., hosting provider) on a need-to-know basis, with contractual confidentiality obligations.
6.3 Ongoing Review
We periodically review our information collection, storage, and processing practices to guard against unauthorized access, processing, or use.
6.4 Internet Transmission Risks
The transmission of information via the Internet is not completely secure. While we strive to protect your personal data, we cannot guarantee the security of data transmitted to our Site; any transmission is at your own risk.
7. Data Transfers
We do not routinely transfer personal data outside Hong Kong, but third-party services like Google Analytics may store or process data internationally (e.g., in the United States). If your data is transferred outside Hong Kong, we take all steps reasonably necessary, such as using data protection agreements or ensuring third-party processors comply with PDPO, to protect it in accordance with this Privacy Policy. By submitting your personal data, you acknowledge this potential transfer, storage, or processing.
8. Your Rights
8.1 Rights Under PDPO
You have the right to:
Check whether we hold personal data about you.
Access any personal data we hold about you.
Require us to correct any inaccuracy or error in your personal data.
Object to direct marketing, as outlined in Clause 2.2.
8.2 Exercising Your Rights
To exercise these rights, contact us at
contact@bluesquarestrategy.com with 'Data Request' in the subject line. We aim to respond within 40 days, as required by the PDPO. Data access and correction requests are processed free of charge.
8.3 Additional Rights (If Applicable)
If you are in other jurisdictions, additional data protection rights may apply. Contact us for details.
9. Changes to This Privacy Policy
We may amend this Privacy Policy from time to time by posting the updated version on our Site. Where required, we will notify you via email or a website notice. For significant changes affecting your data rights, we will seek your explicit consent where required by law. By continuing to use
www.bluesquarestrategy.com after the changes take effect, you acknowledge the revised policy.
10. Languages
A Chinese version of this Privacy Policy is available on our Site. In case of discrepancies between the English and Chinese versions, the English version prevails.
11. Contact Us
For questions, comments, or requests regarding your personal data, please contact:
Bluesquare Strategy 21st Floor, The Phoenix Building, No. 23 Luard Road, Wan Chai, Hong Kong S.A.R
For data requests, include 'Data Request' in the subject line to ensure prompt processing.
We aim to respond to your inquiries within 40 days, as required by the PDPO.
Last Updated: 2nd May 2025
