Privacy Policy

Introduction

LIVING BY CONCEPTS LIMITED, a company registered in Hong Kong with its registered office at Rm 928 TUNG LEE BLDG, 9 LAI YIP ST, Kwun Tong, Hong Kong, is committed to protecting the privacy of all individuals who interact with us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you visit our website at www.livingconcepts.surf or engage our services. The developer of this website and the owner of this organisation is Living Concepts.

Please read this policy carefully. By accessing our website or using our services, you acknowledge the practices described in this document. If you do not agree with any part of this policy, please refrain from using our website or providing us with your personal data.

Information We Collect

Personal Information You Provide

We may collect personal information that you voluntarily provide when you interact with us, including but not limited to:

• Full name and job title
• Email address and telephone number
• Company name and business address
• Details about your inquiry, project scope, or service requirements
• Correspondence and communication history
• Any other information you choose to share through contact forms, email, or telephone conversations

Information Collected Automatically

When you visit our website, certain information is collected automatically through standard web technologies. This may include:

• Internet Protocol (IP) address and device identifiers
• Browser type and version, operating system, and device type
• Referring website URLs, pages visited, time spent on pages, and navigation patterns
• Session duration and interaction data
• Geographic location derived from IP address at the city or regional level

Cookies and Similar Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience, analyse traffic, and understand how our site is used. Cookies are small text files stored on your device by your web browser. We may use the following types of cookies:

• Essential cookies: Required for the basic functionality of the website, such as navigation and access to secure areas.
• Analytics cookies: Help us understand how visitors interact with the website by collecting anonymised usage data.
• Preference cookies: Remember your settings and preferences to improve your experience on future visits.

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality and performance of the website.

How We Use Your Information

We use the personal information we collect for the following purposes:

• To respond to your inquiries, requests, or service needs
• To provide, maintain, and improve our computer systems design and technical services
• To communicate with you about project updates, service changes, or relevant technical information
• To send administrative messages, invoices, and account-related notifications
• To comply with legal and regulatory obligations applicable in Hong Kong and other jurisdictions where we operate
• To detect, prevent, and address security incidents, fraud, or misuse of our services
• To conduct internal analytics and improve the performance and content of our website
• To enforce our Terms of Service and other contractual agreements

Legal Basis for Processing (GDPR Compliance)

If you are located in the European Economic Area (EEA) or the United Kingdom, our processing of your personal data is based on the following lawful grounds under the General Data Protection Regulation (GDPR):

• Consent: Where you have explicitly consented to the processing of your data for specific purposes.
• Contractual necessity: Where processing is necessary to fulfil a contract with you or to take pre-contractual steps at your request.
• Legitimate interests: Where processing is necessary for our legitimate business interests, such as improving our services, network security, and direct communication with clients, provided your rights and interests do not override these interests.
• Legal obligation: Where processing is required to comply with applicable laws and regulations.

Data Sharing and Disclosure

We do not sell, rent, or trade your personal information to third parties. However, we may share your data in the following circumstances:

• With trusted service providers and business partners who assist us in delivering our services, including cloud infrastructure providers, communication platforms, and analytics tools, subject to strict contractual data processing agreements.
• Where required by law, court order, or governmental regulation, including compliance with Hong Kong laws and regulations.
• In connection with a corporate transaction such as a merger, acquisition, restructuring, or sale of assets, provided the receiving entity agrees to be bound by equivalent data protection obligations.
• With your explicit consent or at your direction.

International Data Transfers

As a Hong Kong-based company serving clients across the Asia-Pacific region, your personal data may be transferred to and processed in jurisdictions outside your country of residence. We ensure that any cross-border data transfer is protected by appropriate safeguards, including Standard Contractual Clauses (SCCs) where applicable, or other legally recognised transfer mechanisms.

Hong Kong is recognised by the European Commission as having adequate data protection standards for certain purposes. Where data is transferred to jurisdictions with different data protection laws, we take steps to ensure your data receives an equivalent level of protection.

Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes described in this policy, or as required by applicable law. Retention periods are determined based on the nature of the data and the legal, contractual, and business requirements associated with it.

When data is no longer needed, we securely delete or anonymise it in accordance with our data retention and disposal procedures. Records of business correspondence, project documentation, and financial transactions are typically retained for a period of seven years after the conclusion of the engagement, after which they are securely destroyed.

Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete data.
• Right to erasure: You may request deletion of your personal data, subject to certain legal exceptions.
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
• Right to data portability: You may request a structured, machine-readable copy of your data to transfer to another service provider.
• Right to object: You may object to the processing of your data for direct marketing purposes or on grounds relating to your particular situation.

To exercise any of these rights, please contact us using the details provided at the end of this policy. We will respond to your request within the timeframe required by applicable law, typically within 30 days.

California Consumer Privacy Act (CCPA) Rights

If you are a resident of California, the California Consumer Privacy Act (CCPA) provides you with additional rights regarding your personal information. Under the CCPA:

• You have the right to know what personal information we collect, use, disclose, and sell about you.
• You have the right to request deletion of personal information we have collected from you, subject to certain exceptions.
• You have the right to opt out of the sale of your personal information. We do not sell personal information as defined by the CCPA.
• You have the right to non-discrimination for exercising any of your CCPA rights.

Children's Privacy

Our website and services are not directed at individuals under the age of 16. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

Security Measures

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL protocols
• Secure server infrastructure with restricted access controls
• Regular security assessments and vulnerability testing
• Staff training on data protection and privacy best practices
• Strict access controls based on the principle of least privilege
• Incident response procedures for data breach scenarios

While we take reasonable steps to protect your data, no method of electronic storage or transmission is completely secure. We cannot guarantee absolute security.

Third-Party Links

Our website may contain links to third-party websites that are not owned or controlled by LIVING BY CONCEPTS LIMITED. We are not responsible for their privacy practices.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. When we make material changes, we will update the effective date at the top of this page.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us:

If you have an unresolved privacy concern, you have the right to lodge a complaint with the Privacy Commissioner for Personal Data in Hong Kong or the relevant authority in your jurisdiction.