Privacy Policy

 

Last updated: June 2026

HM Associates (“we”, “us”, “our”) is committed to protecting your personal data and handling it responsibly. This Privacy Policy explains how we collect, use, store, and disclose your personal data when you visit our website, download our toolkits, or sign up for our newsletter.

We comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (PDPO) and follow GDPR‑aligned principles of transparency, fairness, and purpose limitation where applicable.

1. What Personal Data We Collect

We collect personal data in two ways:

1.1 Data you provide to us directly

When you:

  • sign up for our newsletter

  • download a toolkit

  • contact us through a form

  • request information or support

You may provide:

  • your name

  • email address

  • company name (optional)

  • preferences or interests

  • any message you choose to send

We only collect the minimum data needed to provide the service you requested.

1.2 Data collected automatically

When you browse our website, we may collect:

  • basic analytics (page views, device type, browser type)

  • cookie data (see Section 6)

This information is anonymous and cannot identify you personally.

We do not collect sensitive personal data.

2. How We Use Your Personal Data

We use your personal data only for the purposes you would reasonably expect:

  • to send newsletters or updates you subscribed to

  • to deliver toolkits or resources you requested

  • to respond to enquiries

  • to improve our website and content

  • to understand what topics are most useful to SME leaders

We do not use your data for automated decision‑making or profiling.

3. Legal Basis

Although we operate in Hong Kong, we follow GDPR‑aligned principles:

  • Consent — when you sign up for newsletters or downloads

  • Legitimate interests — to improve our website and understand usage patterns

  • Legal obligation — if required to comply with Hong Kong law

You may withdraw consent at any time by clicking “unsubscribe” or contacting us.

4. How We Store and Protect Your Data

We take reasonable and practical steps to protect your personal data, including:

  • secure servers

  • encrypted transmission where appropriate

  • restricted access to authorised personnel only

However, no system is completely secure. We cannot guarantee absolute protection against unauthorised access, cyberattacks, or data breaches.

We retain personal data only for as long as necessary to fulfil the purpose for which it was collected, unless a longer retention period is required by law.

5. Sharing Your Personal Data

We do not sell, rent, or trade your personal data.

We may share your data only in the following situations:

  • Service providers (e.g., email delivery platforms such as Substack or similar)

  • Legal requirements (if required by Hong Kong authorities)

All service providers are required to handle your data securely and only for the purpose of providing their service.

We do not share your data with advertisers or unrelated third parties.

6. Cookies and Analytics

Our website uses cookies and basic analytics tools to:

  • understand how visitors use the site

  • improve content and user experience

  • remember your preferences

You can disable cookies in your browser settings. Some features may not function fully without cookies.

We do not use cookies for advertising or tracking across other websites.

7. Your Rights

You have the right to:

  • access the personal data we hold about you

  • correct inaccurate or outdated information

  • withdraw consent for newsletter or marketing communications

  • request deletion of your data where appropriate

  • ask about our data practices

Under PDPO, we will respond to access or correction requests within 40 days.

We may charge a reasonable fee for access requests as permitted by law.

To exercise your rights, contact us using the details below.

8. Cross‑Border Data Transfers

Our email and website services may store data on servers located outside Hong Kong.

We ensure that any overseas service providers follow reasonable data protection standards consistent with PDPO principles.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

  • changes in the law

  • updates to our services

  • improvements in our data practices

If changes are material, we will notify you via our website or email.

Your continued use of our website or newsletter after updates indicates your acceptance of the revised policy.

10. Contact Us

If you have any questions about this Privacy Policy or how we handle your personal data, you may contact us at:

Email:don@marketevolver.com
Address: HM Associates, 8/D Rialto Mansion, 183 King’s Road, Hong Kong