Effective Date: 25 March 2025
Version: 1.2
Issued by: Nyxora Ltd
Website: https://nyxora.dev
1. Introduction
At Nyxora Ltd (“we”, “our”, or “us”), we are committed to protecting the privacy, confidentiality, and security of your personal data in accordance with Hong Kong’s Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”). This Privacy Notice explains how we collect, use, disclose, store, and safeguard your personal data when you visit our website (https://nyxora.dev/) (the “Website”).
This Privacy Notice applies solely to data collected through our Website. It does not apply to:
- Data collected offline or through direct contractual relationships;
- Personal data collected through third-party websites or platforms linked to or from our Website;
- Any data processing governed by a formal service agreement or client engagement terms.
By continuing to use our Website, you confirm that you have read and understood this Privacy Notice and agree to the terms described herein. If you do not agree with any part of this Notice, please discontinue your use of the Website.
2. What Personal Data We Collect
We may collect and process various types of personal data through your use of our Website, including but not limited to:
a. Personal Identifiers
- Full name
- Email address
- Contact number
- Company or organization name (if provided)
b. Technical and Usage Information
- IP address
- Browser type and version
- Device information and operating system
- Pages visited and browsing duration
- Referring URL (how you found our Website)
c. Cookies and Tracking Technologies
- Cookie identifiers
- Session preferences
- Website behavior analytics
(see Section 9 for our full Cookies Policy)
We do not collect sensitive personal data such as identity documents, biometric data, or financial account information via this Website.
3. Purpose of Data Collection
We collect and use personal data only for purposes that are necessary, lawful, and directly related to our business functions. These purposes may include:
- To respond to enquiries submitted via our contact forms;
- To deliver requested information about our services;
- To improve the functionality, usability, and performance of our Website;
- To analyze user behavior to optimize content and user experience;
- To detect and prevent fraudulent or unauthorized access;
- To comply with legal and regulatory obligations applicable in Hong Kong.
We will not use your data for purposes materially different from those described unless we obtain your express consent or are required by law.
4. Legal Basis for Processing
While Hong Kong law does not require a “legal basis” framework similar to the EU’s GDPR, we operate in accordance with the Data Protection Principles (DPPs) under the PDPO. In particular:
- DPP1 (Purpose and Manner of Collection): We collect data lawfully and fairly, and only for explicit purposes.
- DPP3 (Use of Personal Data): We use your data only for the purposes specified at the time of collection or directly related purposes.
- DPP4 (Security of Personal Data): We apply all reasonable security measures to protect your data from misuse, loss, and unauthorized access.
5. Cookies and Tracking Technologies
We use cookies and similar technologies to enhance your browsing experience. Cookies are small text files placed on your device to remember your preferences and help us analyze how users engage with the Website.
Types of Cookies We Use:
- Essential cookies – Necessary for website functionality;
- Performance cookies – Help us understand how users interact with our site;
- Functionality cookies – Remember user preferences for improved usability.
You can manage or disable cookies via your browser settings. Please note that certain features of our Website may not function properly if cookies are disabled.
A detailed breakdown of cookie usage is available in our Cookies Policy.
6. Disclosure of Your Data to Third Parties
We do not sell, trade, or rent your personal data to third parties.
However, we may disclose your data to third-party service providers for the limited purposes of:
- Website hosting and cloud storage;
- Website analytics;
- Email delivery or contact form routing.
We ensure that all third-party service providers comply with strict confidentiality obligations and data protection requirements consistent with Hong Kong standards.
7. Cross-Border Transfers of Data
Your personal data may be transferred, processed, or stored in jurisdictions outside Hong Kong when using third-party hosting or communication services. In such cases, we ensure that appropriate contractual and organizational safeguards are in place to ensure your data is adequately protected and that transfer restrictions under the PDPO are respected.
8. Data Security
We implement a combination of technical, administrative, and physical security measures to protect your personal data. These include:
- Secure data storage with restricted access;
- SSL encryption for data transmission;
- Regular security audits and updates;
- Role-based access control for staff handling personal data.
While no method of transmission over the Internet is 100% secure, we take all reasonable steps to minimize risk and protect your data from unauthorized access or misuse.
9. Retention of Data
We retain personal data only for as long as it is necessary to fulfill the purposes for which it was collected, or as required by applicable legal and regulatory requirements.
Data that is no longer needed is either securely deleted or anonymized in a way that it can no longer identify you.
Our internal Data Retention Policy outlines specific retention periods for each category of data processed.
10. Your Rights Under Hong Kong Law
You have the following rights under the PDPO:
- Access: You may request a copy of the personal data we hold about you.
- Correction: You may request that we correct any inaccuracies in your personal data.
- Withdrawal of Consent: Where applicable, you may withdraw previously given consent at any time by contacting us.
To make an access or correction request, please email us at [email protected]. We may request proof of identity before responding to such requests. A nominal fee may be charged for access requests as allowed by law.
11. Children’s Data
Our Website is intended for business use and is not directed at individuals under the age of 18. We do not knowingly collect or process data relating to minors. If you believe we have mistakenly collected data from a child, please notify us immediately and we will take appropriate action to delete the information.
12. Automated Decision-Making and Profiling
We do not use fully automated decision-making processes that significantly affect your rights. If such activities are introduced in the future, this Privacy Notice will be updated to reflect their nature and your associated rights.
13. Data Breach Notification
In the event of a data breach that presents a real risk of harm to individuals, we will:
- Notify affected data subjects promptly;
- Inform the Office of the Privacy Commissioner for Personal Data (PCPD) as required;
- Take immediate remedial measures to contain the breach and mitigate impact.
We maintain a robust incident response plan to handle potential data security incidents efficiently.
14. Privacy by Design and Impact Assessments
We incorporate Privacy by Design principles in all systems, services, and digital products. When undertaking new projects involving data processing that may pose high privacy risks, we conduct Data Protection Impact Assessments (DPIAs) to ensure adequate safeguards are in place.
15. Third-Party Links
Our Website may contain links to external websites or platforms operated by third parties. We are not responsible for the privacy practices or content of those websites. We encourage you to read the privacy policies of all third-party sites before providing your data to them.
16. Changes to this Privacy Notice
We may update this Privacy Notice from time to time to reflect changes in our practices or legal obligations. The “Last Updated” date at the top of this Notice indicates the latest revision. Continued use of our Website after updates means you accept the revised terms.
17. Contact Us
If you have questions, feedback, or concerns about this Privacy Notice or your personal data, please contact us:
Nyxora Ltd
Email: [email protected]
Address: Office A, 8/F., Kingswell Commercial Tower, 171 Lockhart Road, Wan Chai, Hong Kong
We encourage you to contact us directly with any concerns. If we are unable to resolve your issue, you have the right to contact the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong.