Privacy Policy

Cloud Sea Media Group Limited, trading as CSMG Digital, respects your privacy and is committed to protecting your personal data.

This Privacy Policy explains how we collect, use, disclose, store, process and protect personal data when you visit our website, contact us, submit an enquiry, request information, book a call, engage our services, interact with our digital platforms, or otherwise communicate with us.

This Privacy Policy is intended to reflect the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, including the Data Protection Principles set out under the Ordinance. The Personal Data (Privacy) Ordinance applies to the collection, holding, processing and use of personal data in Hong Kong, and the Data Protection Principles outline how personal data should be handled.

This Privacy Policy is provided as a first-draft website privacy policy and does not constitute legal advice.

For the purposes of this Privacy Policy, “we”, “us” and “our” refers to:

Website: www.csmgdigital.com
Email: support@csmgdigital.com

Cloud Sea Media Group Limited may provide digital marketing, website, advertising, automation, lead generation, AI-enabled business support and related digital services under the CSMG Digital brand.

This Privacy Policy applies to personal data collected through our website, online forms, landing pages, booking tools, email communications, telephone calls, social media channels, advertising campaigns, client onboarding processes, business communications and related digital systems.

It applies to personal data collected from prospective clients, existing clients, website visitors, suppliers, business contacts, job applicants, contractors and other individuals who interact with us.

This Privacy Policy does not apply to third-party websites or platforms that we do not own or control.

In this Privacy Policy, “personal data” means information relating directly or indirectly to a living individual, from which it is practicable for that individual to be directly or indirectly identified, and which is in a form in which access to or processing of the data is practicable.

This may include personal information, business contact information and technical information that can identify an individual.

We may collect the following types of personal data:

We do not generally seek to collect sensitive personal data through our website.

You should not submit sensitive, confidential or highly personal information through our website forms, chatbots, live chat tools, AI tools or general enquiry channels unless we specifically request it and it is necessary for the relevant purpose.

If you provide sensitive information to us, we will handle it in accordance with applicable law and this Privacy Policy.

We may collect personal data directly from you when you:

• visit our website
• complete a contact form
• submit a lead form or landing page enquiry
• book a call or consultation
• request a quote, audit, proposal or information
• contact us by email, phone, social media, messaging app, chatbot or live chat
• subscribe to updates or marketing communications
• engage us to provide services
• provide onboarding information
• give us access to digital platforms or business systems
• attend a meeting, webinar, consultation or event
• respond to our advertising or marketing campaigns

We may also collect personal data from third-party sources, including:

• analytics platforms
• advertising platforms
• CRM systems
• booking tools
• email marketing systems
• social media platforms
• payment and accounting platforms
• public business directories
• referrals
• your authorised representatives

We may collect, hold, process and use personal data for the following purposes:

• responding to enquiries
• arranging calls, meetings, consultations and audits
• preparing proposals, quotes and service recommendations
• providing digital marketing, advertising, website, automation, AI, lead generation and related services
• managing client relationships
• delivering projects and campaigns
• providing reporting, support and account management
• issuing invoices and managing payments
• operating and improving our website
• measuring website and campaign performance
• analysing user behaviour and business engagement
• managing advertising, retargeting and remarketing campaigns
• maintaining internal business records
• sending administrative, service and account communications
• sending marketing communications where permitted by law
• improving our products, services, systems and customer experience
• protecting our website, systems, business and legal rights
• preventing fraud, misuse, unauthorised access or unlawful activity
• complying with legal, regulatory, tax, accounting and reporting obligations

We will only use personal data for the purpose for which it was collected, for a directly related purpose, with your consent, or as otherwise permitted or required by law.

We may use your personal data to send you marketing communications about our services, updates, insights, offers, events, resources or other business-related information that may be relevant to you.

The types of personal data we may use for direct marketing include your name, email address, phone number, business name, role, service interests, enquiry history and client relationship information.

Under Hong Kong privacy law, direct marketing using personal data is subject to specific requirements, including providing certain information and obtaining consent or an indication of no objection before using personal data for direct marketing.

You may opt out of marketing communications at any time by:

• using the unsubscribe link in our emails
• replying to our message with an opt-out request, where applicable
• contacting us at support@csmgdigital.com

We will not sell your personal data to third parties for their own direct marketing purposes.

Our website may use cookies, pixels, tags, scripts, web beacons and similar technologies.

These technologies may be used to:

• operate the website
• remember user preferences
• understand how visitors use our website
• measure website traffic and performance
• analyse form submissions and conversions
• support advertising and remarketing
• measure advertising campaign effectiveness
• improve website content, design and user experience

These technologies may be provided by third-party platforms such as Google services, Meta services, analytics providers, CRM tools, advertising networks, booking tools, chat tools and automation providers.

Hong Kong does not have a separate comprehensive cookie law in the same way as some other jurisdictions, but where cookies or tracking technologies collect personal data, the handling of that data should comply with the Personal Data (Privacy) Ordinance.

You can usually adjust your browser settings to block, delete or manage cookies. Some parts of our website may not function properly if cookies are disabled.

We may use analytics, advertising and reporting platforms to understand how users find and interact with our website and marketing campaigns.

These platforms may collect technical and usage information, including IP address, device details, browser details, pages visited, referral source, campaign source, approximate location and conversion activity.

We may use this information to:

• improve website performance
• measure advertising results
• understand audience behaviour
• manage campaign reporting
• optimise marketing activity
• show relevant advertisements to users who have interacted with our website or campaigns

Our website, campaigns or business operations may use AI-enabled tools, chatbots, voice tools, automated forms, CRM automations or similar systems to assist with enquiries, lead handling, customer communication, appointment booking, reporting, support or service delivery.

Information submitted through these tools may be collected, processed, stored, reviewed or actioned by us and by relevant technology providers.

You should not submit highly confidential, sensitive or unnecessary personal information through website forms, chatbots, AI assistants or automated tools.

Where AI or automation tools process personal data on our behalf, we take reasonable steps to ensure that the relevant service providers handle personal data appropriately and only for authorised purposes.

We may disclose personal data to:

• our directors, employees, contractors, consultants and authorised representatives
• related entities, associated offices or business partners involved in service delivery
• website hosting providers
• cloud storage providers
• CRM platforms
• email and SMS marketing platforms
• advertising platforms
• analytics providers
• booking and scheduling tools
• payment processors
• accounting and invoicing providers
• AI, chatbot, automation and workflow providers
• call tracking and communication providers
• IT support and cybersecurity providers
• professional advisers, including lawyers, accountants, auditors and insurers
• regulatory bodies, government authorities or law enforcement agencies where required by law
• another party in connection with a business sale, merger, restructure, acquisition, financing or transfer of assets

We take reasonable steps to ensure that third parties who process personal data on our behalf are required to protect that data and use it only for authorised purposes.

We may store, process or transfer personal data outside Hong Kong.

This may occur where we use cloud-based systems, international software providers, contractors, service providers, related teams or technology platforms located in other jurisdictions.

Possible overseas locations may include Australia, Malaysia, Singapore, the United States, the United Kingdom, the European Union and other countries where our service providers or technology platforms operate.

Where personal data is transferred or processed outside Hong Kong, we take reasonable steps to protect the data and to ensure that it is handled consistently with this Privacy Policy and applicable privacy obligations.

We take reasonable technical and organisational measures to protect personal data from unauthorised access, processing, loss, misuse, interference, disclosure, alteration or destruction.

These measures may include:

• access controls
• password protection
• secure cloud systems
• HTTPS encryption
• user permission controls
• internal confidentiality requirements
• secure file management
• administrative controls
• cybersecurity tools
• staff and contractor access restrictions

However, no method of internet transmission or electronic storage is completely secure. We cannot guarantee absolute security of personal data transmitted online.

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including:

• responding to enquiries
• providing services
• managing client relationships
• maintaining business records
• meeting legal, tax and accounting obligations
• resolving disputes
• enforcing agreements
• protecting our legal rights

When personal data is no longer required, we will take reasonable steps to delete, destroy, de-identify or securely archive it, unless we are required or permitted by law to retain it.

We take reasonable steps to ensure that personal data we hold is accurate, complete, up to date and not misleading, having regard to the purposes for which it is used.

You should contact us if your personal data changes or if you believe that any personal data we hold about you is inaccurate, incomplete or out of date.

You may request access to personal data that we hold about you. You may also request correction of personal data that is inaccurate, incomplete or out of date.

To make an access or correction request, please contact us using the details below:

Email: support@csmgdigital.com

We may need to verify your identity before responding to your request.

We will respond to access and correction requests within a reasonable time and in accordance with applicable law.

If you have a complaint or concern about how we have handled your personal data, please contact us first using the details below:

Email: support@csmgdigital.com

Please include your name, contact details and a clear description of your concern.

We will review your complaint and respond within a reasonable time.

If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner for Personal Data, Hong Kong. The PCPD is the privacy regulator responsible for Hong Kong’s Personal Data (Privacy) Ordinance.

Our website may contain links to third-party websites, social media pages, booking tools, payment systems, forms, advertising platforms or external resources.

We are not responsible for the privacy practices, security, content or policies of third-party websites or platforms.

You should review the privacy policies of third-party websites and platforms before providing personal data to them.

If Cloud Sea Media Group Limited is involved in a merger, acquisition, restructure, sale of business, transfer of assets, financing transaction or similar event, personal data may be disclosed or transferred as part of that transaction.

Where this occurs, we will take reasonable steps to ensure that personal data remains protected.

Our website and services are intended for business users and are not directed at children.

We do not knowingly collect personal data from children. If you believe that a child has provided personal data to us, please contact us so we can review the matter and take appropriate steps.

We may update this Privacy Policy from time to time.

The updated version will be published on this page with the latest “Last updated” date.

Your continued use of our website or services after an updated Privacy Policy is published indicates that you have read and understood the updated Privacy Policy.

For privacy-related questions, access requests, correction requests, complaints or marketing opt-out requests, please contact:

Email: support@csmgdigital.com
Website: www.csmgdigital.com