Privacy Policy

1. Data Controller

The data controller responsible for your personal information is:

Lambent
3 Lockhart Road, Wan Chai, Hong Kong
Email: [email protected]
Phone: +852 2436 8175

2. Information We Collect

Information you provide directly

• Name and contact details (email address, phone number) when you submit an enquiry form
• Organisation name and role, where provided
• Content of messages or questions you send to us

Information collected automatically

• IP address and browser type, for security and analytics
• Pages visited and time spent on each page
• Referring website or search terms
• Cookie identifiers (see our Cookie Policy)

Information from third parties

We may receive limited data from analytics providers (such as Google Analytics) to understand aggregate usage patterns. We do not purchase personal data from data brokers.

3. Legal Basis for Processing

We process personal data under the following legal grounds, consistent with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong:

• Consent — when you tick a consent box or voluntarily submit a form
• Legitimate interests — to respond to enquiries, improve our services, and maintain security
• Contract performance — when processing is necessary to deliver a service you have requested
• Legal obligation — when required by Hong Kong law or a regulatory authority

4. How We Use Your Information

• Responding to enquiries and scheduling consultations
• Delivering contracted AI services (semantic search infrastructure, model retraining, executive briefings)
• Sending service updates or relevant communications where you have opted in
• Analysing website usage to improve content and navigation
• Complying with legal or regulatory obligations
• Preventing fraud and maintaining the security of our systems

5. Data Retention

We keep personal data only for as long as necessary to fulfil the purpose for which it was collected:

• Enquiry records: up to 24 months from last contact
• Client project records: 7 years for accounting and legal purposes
• Website analytics data: 14 months (aggregated thereafter)
• Cookie data: as described in our Cookie Policy

After the applicable period, data is securely deleted or anonymised.

6. Data Sharing

We do not sell personal data. We may share data with:

• Service providers — cloud hosting, email delivery, and analytics vendors acting on our behalf under written data processing agreements
• Professional advisors — lawyers or accountants under confidentiality obligations
• Regulatory authorities — when required by Hong Kong law

Any third-party providers are required to handle data in accordance with applicable privacy law and our instructions.

7. International Data Transfers

Some of our service providers operate systems outside Hong Kong. Where data is transferred, we ensure appropriate safeguards are in place — including contractual clauses that meet the standards required by Hong Kong privacy law. We do not transfer data to jurisdictions without adequate protection unless such safeguards exist.

8. Data Security

• All data in transit is encrypted using TLS 1.2 or higher
• Data at rest is stored on access-controlled servers
• Internal access is limited to staff with a genuine need
• We conduct periodic security reviews of our infrastructure
• In the event of a data breach affecting your personal data, we will notify you and, where required, the Office of the Privacy Commissioner for Personal Data (PCPD) within 72 hours of becoming aware

9. Cookies

We use cookies and similar technologies to operate our website and understand usage patterns. You can manage your preferences at any time via our Cookie Policy page. Essential cookies cannot be disabled as they are required for basic site functionality.

10. Your Rights

Under the Personal Data (Privacy) Ordinance and, where applicable, the GDPR, you have the right to:

• Access — request a copy of the personal data we hold about you
• Correction — ask us to correct inaccurate or incomplete data
• Erasure — request deletion of your data where there is no lawful basis to retain it
• Data portability — receive your data in a structured, machine-readable format
• Object — object to processing based on legitimate interests
• Withdraw consent — at any time, without affecting the lawfulness of prior processing
• Lodge a complaint — with the Office of the Privacy Commissioner for Personal Data (Hong Kong)

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

11. Third-Party Links

Our website may contain links to external sites. We are not responsible for the privacy practices of those sites and encourage you to review their policies independently.

12. Children's Privacy

Our services are directed at organisations and professionals aged 18 and above. We do not knowingly collect personal data from individuals under 18. If we become aware that such data has been collected, it will be deleted promptly.

13. Changes to This Policy

We may update this policy periodically to reflect changes in our practices or applicable law. When we make material changes, we will post the updated policy on this page with a revised "Last Updated" date. Continued use of our services after such changes constitutes acceptance of the updated policy.

14. Contact for Privacy Enquiries

For questions or requests related to this policy or your personal data:

Lambent — Data Privacy
3 Lockhart Road, Wan Chai, Hong Kong
Email: [email protected]
Phone: +852 2436 8175