LEGAL
Privacy Policy
Last Updated: August 11, 2026 · Effective Date: August 11, 2026
HONG KONG PENGBO TECHNOLOGY CO., LIMITED (Company Registration No. 77233517) (hereinafter referred to as “the Company,” “we,” “us,” or “our”) respects and protects your personal privacy. This Privacy Policy explains how we collect, use, store, and protect your personal information when you visit our official website (hereinafter “this Website”), as well as the rights you enjoy in relation thereto.
Please read and fully understand this Policy before using this Website. By continuing to use this Website, you signify your consent to our processing of your relevant information in accordance with this Policy.
1. Information We Collect
When you visit this Website, the information we collect falls into the following two categories.
1.1 Information You Actively Provide
In certain circumstances, you may actively provide us with personal information, including:
- your name, email address, phone number, and the content of your inquiry submitted through the “Contact Us” form on this Website;
- sender information and email content contained in messages sent to our official email address;
- an email address provided when subscribing to our newsletters or updates; and
- personal information and attached documents submitted when applying for job opportunities.
1.2 Information Automatically Collected
While you browse this Website, our systems may automatically collect the following technical information:
- Device Information: device model, operating system and version, browser type and version, screen resolution, and device unique identifiers, such as OAID, IDFA, or IMEI, to the extent permitted by applicable law;
- Log Information: IP address, access time, duration of visit, browsed page paths, click behavior, and referring URL;
- Cookie Data: preference settings and session information collected through cookies and similar technologies; and
- Approximate Geographic Location: city- or region-level location information inferred from your IP address, not precise GPS data.
2. How We Use Your Information
We use the information collected for the following legitimate purposes:
| Purpose | Description | Legal Basis |
|---|---|---|
| Website Operation and Maintenance | Ensuring normal website functioning, content display, and security and stability | Legitimate Interests |
| Responding to Your Inquiries | Replying to questions submitted via forms or email | Contract Performance / Consent |
| Improving User Experience | Analyzing user behavior and improving website content and functionality | Legitimate Interests |
| Statistical Analysis | Understanding traffic volume, user preferences, and other macro-level data | Legitimate Interests |
| Security Protection | Detecting and preventing cyberattacks, fraud, and other security risks | Legal Obligation / Legitimate Interests |
| Marketing (only with your consent) | Sending company updates, product news, and other information | Consent |
| Recruitment Communication | Processing your job applications | Contract Performance / Consent |
3. Legal Basis for Data Processing
Under applicable data-protection laws, the legal bases for our processing of your personal information include:
- your consent, for example when you submit information via forms;
- performance of a contract or taking pre-contractual steps at your request, for example processing job applications;
- pursuit of our legitimate interests, for example enhancing website security and user experience, provided such interests do not override your fundamental rights and freedoms; and
- compliance with legal obligations, for example responding to lawful government requests.
4. Cookies and Similar Technologies
4.1 What Are Cookies
Cookies are small text files stored on your device’s browser by websites to record your preferences and session status.
4.2 Types of Cookies We Use
- Strictly Necessary Cookies: ensure the basic functionality of the Website; these cannot be disabled.
- Analytics Cookies: collect traffic data to help us optimize website performance.
- Functional Cookies: remember your preference settings to enhance usability.
4.3 Your Choices
You may manage or delete cookies through your browser settings. Please note that disabling certain cookies may affect the normal functioning of some features on this Website. We also display a cookie banner upon your first visit to this Website, allowing you to provide selective consent.
5. How We Share Your Information
We do not sell your personal information. We share your information only in the following limited and necessary circumstances.
5.1 Third-Party Service Providers
We may engage third-party service providers to assist us in operating the Website, processing data, sending emails, and other related services. These service providers act only under our instructions and are bound by confidentiality and security obligations. They are not permitted to use your information for any other purposes.
5.2 Legal Compliance
We may disclose your information if required by laws, regulations, court orders, or government authorities, or to protect the legitimate rights and interests of the Company, our users, and the public, for example by preventing fraud and maintaining cybersecurity.
5.3 Corporate Transactions
In the event of a merger, acquisition, asset transfer, or similar transaction, your information may be transferred to the successor entity as part of the Company’s assets. The successor entity will continue to be bound by this Privacy Policy.
6. Data Storage and Cross-Border Transfer
6.1 Storage Location
Your personal information is stored on servers located in [Hong Kong] (please adjust according to the actual server location).
6.2 Data Retention Period
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Policy:
- Inquiry Form Information: retained for [6 months] after the inquiry is concluded;
- Resume/CV Information: retained for [6 months] after the recruitment process concludes, and may be extended to a talent pool with your consent; and
- Website Access Logs: retained for no more than [12 months] for statistical-analysis purposes.
6.3 Cross-Border Transfers
If your information needs to be transferred to other countries or regions, we will ensure appropriate safeguards are in place and comply with applicable cross-border data-transfer regulations.
7. Data Security
We adopt industry-standard technical and organizational measures to protect your information against unauthorized access, disclosure, alteration, or destruction, including:
- Encryption in Transit: all website communications are encrypted using HTTPS/SSL protocols;
- Access Control: internal access to personal information is strictly limited on a minimum-necessary basis;
- Security Audits: regular system vulnerability scanning and security assessments; and
- Employee Training: data-protection awareness and skills training for our staff.
While we have implemented the above measures, no data-storage or transmission method is entirely secure. In the event of a data-security incident, we will notify you and relevant regulatory authorities in a timely manner as required by law.
8. Your Rights
Under applicable privacy laws, you have the following rights with respect to your personal information:
| Right | Description |
|---|---|
| Right to be Informed | To understand how we collect, use, and share your information |
| Right of Access | To request a copy of the personal data we hold about you |
| Right to Rectification | To correct inaccurate or incomplete personal information |
| Right to Erasure | To request deletion of your personal information where permitted by law |
| Right to Restriction of Processing | To request restriction of processing of your information under certain circumstances |
| Right to Data Portability | To receive your data in a structured, machine-readable format |
| Right to Withdraw Consent | To withdraw your consent to processing at any time, without affecting processing already carried out before withdrawal |
| Right to Lodge a Complaint | To lodge a complaint with the data-protection supervisory authority in your jurisdiction |
To exercise any of the above rights, please submit a written request to us via the contact details provided in Section 11. We will respond within [15–30 business days].
9. Children’s Privacy
This Website is not directed at children under 13 years of age, or such lower age as may be specified in your jurisdiction. We do not knowingly collect personal information from children. If you are a minor, please use this Website under the supervision of a legal guardian. If we discover that we have inadvertently collected information from a child, we will delete it immediately. If you are a guardian and believe your child has provided us with personal information, please contact us promptly.
10. Changes to This Policy
We may revise this Privacy Policy from time to time. In the event of material changes, such as changes in processing purposes or the scope of data-subject rights, we will notify you by one or more of the following methods:
- posting a notice on the homepage or a prominent location of this Website;
- updating the “Last Updated” date at the top of this page; or
- sending an email notification if you have provided us with your email address.
The revised Policy will take effect on the date of publication. Your continued use of this Website after any changes to this Policy constitutes your acceptance of the updated Policy.
11. Contact Us
If you have any questions, comments, or requests regarding this Privacy Policy or the processing of your personal information, please contact us through the following channels:
Company Address: Room D5, 5/F, King Yip Factory Building, 59 King Yip Street, Kwun Tong, Kowloon, Hong Kong SAR, China
Company Website: Pengbo Play
12. Supplemental Statement: Special Provisions under Hong Kong’s Personal Data (Privacy) Ordinance
Pursuant to the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, the Company hereby expressly states that:
- 12.1 the types of personal data we collect, the purposes of use, and the parties to whom such data may be transferred have been fully disclosed in this Policy;
- 12.2 you have the right to request access to and correction of your personal data held by us. To exercise this right, please submit a written request via the contact details set out in Section 11; and
- 12.3 we will process your request within a reasonable time, ordinarily not exceeding 30 days, upon receipt, and may charge a reasonable fee for repetitive or unreasonable requests.