Privacy policy

Last updated: 29 October 2026

1. Who we are

This website is operated by upstrong inc limited 通上有限公司 (“we”, “us”), a company incorporated in Hong Kong. We are the “data user” for personal data collected through this website under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”).

Company registration no.

2416833

Business registration no. (HK)

66562397

Registered office

Rm 1007 Pakpolee Commercial Centre, 1A Sai Yeung Choi Street South, Mongkok, Kowloon, Hong Kong

Privacy contact

See the details on our Contact page

This policy covers this website only. Our services have their own websites and terms, which carry their own privacy notices.

2. What personal data we collect

• Messages you send us. If you email us we receive your name, email address and whatever you tell us.
• Technical data. Our hosting and content-delivery providers record standard server logs: IP address, browser and device type, pages requested, and date and time.

This website has no sign-up, no contact form, no advertising or analytics trackers, and we do not set cookies of our own. If that changes we will update this policy first.

3. Why we use it

• To read and reply to your enquiry.
• To keep the website secure and working, and to investigate abuse.
• To meet legal and regulatory obligations and to establish or defend legal claims.

We do not use your personal data for direct marketing and we do not sell it.

4. Who we share it with

Only as needed for the purposes above: our hosting and content-delivery provider (currently Cloudflare), our email provider (Microsoft 365), companies in our corporate group, and professional advisers. We disclose data to courts, regulators or law enforcement where the law requires it. These providers may process data outside Hong Kong; we require appropriate protection.

5. How long we keep it

Enquiry emails are kept for as long as needed to deal with your enquiry and any follow-up, then deleted or anonymised. Server logs are kept by the hosting provider for a short period, in line with its standard retention.

6. Security

We take practicable steps to protect personal data against unauthorised or accidental access, loss or misuse, including access controls and encrypted (HTTPS) connections.

7. Your rights

Under the PDPO you may ask us to confirm whether we hold personal data about you, to give you a copy, and to correct it if it is inaccurate. Send your request in writing using the details on our Contact page. We will respond within 40 days. We may charge a fee that is not excessive for a data access request.

8. Complaints

Please contact us first. You may also contact the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk).

9. Changes

We may update this policy. The date at the top shows the latest version.