Privacy Policy

Introduction

Central Pacific Consultants Limited ("we", "us", "our") is a company registered in Hong Kong with its registered office at 2/F Beverly House, 93-107 Lockhart Road, Wan Chai, Hong Kong, Business Registration Number 53642392.

This Privacy Policy explains how we collect, use, and protect personal data when you visit our website at https://www.centralpacific.hk (the "Website"), submit an enquiry, or contact us directly.

We handle personal data in compliance with the Hong Kong Personal Data (Privacy) Ordinance (PDPO) and, where applicable, Regulation (EU) 2016/679 (the "GDPR").

This policy applies to the Central Pacific Consultants Limited corporate website only. It does not apply to our product Check-in Pax, which operates separately at https://www.checkinpax.com and https://app.checkinpax.com. Data processing within Check-in Pax is governed by the Check-in Pax Privacy Policy and Data Processing Agreement.

What Personal Data We Collect

We collect personal data only when you choose to provide it. This happens when you:

Fill out a contact or enquiry form on the Website
Subscribe to our newsletter
Contact us directly by email
Respond to a survey or marketing communication

The personal data we collect may include:

Your first and last name
The company you work for (if provided)
Your email address
Your phone number and job title (if provided)
Any other information you choose to include in your message

When you submit a form on our Website, we may also automatically collect:

IP address
Device identifiers
Date and time of submission
Approximate geolocation based on IP address

We collect this technical information solely to confirm that you gave us your consent to store your data and contact you as described in this policy.

How We Use Your Personal Data

We use the personal data you provide for the following purposes:

If you are a prospective or existing customer:

To respond to your enquiry
To provide information about our products and services, including Check-in Pax
To send periodic updates about our services, where you have consented or where we have a legitimate interest in doing so
To follow up after correspondence (email, chat, or phone)

If you are a supplier or partner:

To contact you when we require your services
To respond to your enquiries
To send periodic updates relevant to our business relationship

Legal basis. We collect and use your personal data only for the purposes stated in this policy or purposes directly related to them, and we obtain your consent where required under the Hong Kong Personal Data (Privacy) Ordinance (PDPO).

Where the GDPR applies, we process your personal data on the basis of:

Your consent, when you submit an enquiry or subscribe to communications
Our legitimate interests, in responding to business enquiries and maintaining professional relationships
Performance of a contract, where you are a customer or supplier

How We Protect Your Personal Data

We take reasonable technical and organizational measures to protect your personal data, including:

Encryption of data in transit using SSL/TLS
Access controls limiting personal data to authorized personnel only
Regular malware scanning
Selection of software systems that comply with the GDPR and maintain high security standards

We do not collect or store credit card information on this Website.
Data flow and storage. When you submit an enquiry through our Website, your information is transmitted directly to our customer relationship management system, Brevo (Europe), and a notification email is sent to our internal Google Workspace account. We do not store lead data on the Website's servers beyond the brief period required to transmit it to these systems.

Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes described in this policy, or as required by applicable law.

If you ask us to delete your data, we will do so unless we are required to retain it for legal, accounting, or auditing purposes.

Sharing of Personal Data

We do not sell, trade, or otherwise transfer your personal data to outside parties, except as described below.

Service providers. We share personal data with the following providers who assist us in operating our business:

Brevo (formerly Sendinblue) — customer relationship management and email communications
Google Workspace (Asia Pacific) — internal email and business productivity

These providers process personal data only on our instructions and are bound by data protection agreements.

Legal requirements. We may disclose personal data where required by law, to enforce our site policies, or to protect our rights, property, or safety, or those of others.

A list of the sub-processors used by our Check-in Pax product is available separately at https://www.checkinpax.com/subprocessors. That list does not apply to this Website.

Cookies and Tracking Technologies

Our Website uses cookies and similar technologies to improve your browsing experience. We use:

Google Analytics — to understand how visitors interact with the Website
Log files — to track actions on the Website, including IP address, browser type, internet service provider, referring/exit pages, and date/time stamps
Web beacons, tags, and pixels — to record information about how you browse the Website

For more details on the specific cookies we use and how to manage them, please refer to our Cookie Policy at https://www.centralpacific.hk/cookie-policy.

You can manage or disable cookies through your browser settings. Note that disabling all cookies may affect the functionality of the Website.

Your Rights

You have the following rights regarding your personal data:

Access — request a copy of the personal data we hold about you
Correction — request that we correct inaccurate or incomplete data
Deletion — request that we delete your personal data, subject to legal retention requirements
Withdrawal of consent — withdraw your consent to processing at any time
Objection — object to processing based on legitimate interests
Complaint — lodge a complaint with the relevant supervisory authority

To exercise any of these rights, please contact us at enquiry@centralpacific.hk. We will respond within one month. In exceptional circumstances, we may extend this period by up to two additional months and will notify you if we do.

Supervisory authority. You have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong. Contact details and complaint procedures are available at https://www.pcpd.org.hk/english/complaints/how_complaint/how_complaint.html.

If you are located in the European Economic Area, you also have the right to lodge a complaint with the supervisory authority in your country of residence, place of work, or the place of the alleged infringement.

Data Breach Notification

In the event of a data breach affecting your personal data, we will notify you without undue delay after becoming aware of the breach. Where the breach originates from a third-party service provider, we will notify you as soon as reasonably practicable after receiving notification from that provider.

Third-Party Links

Our Website may include links to third-party websites or services. These sites have their own privacy policies, and we have no responsibility or liability for their content or activities. We encourage you to review the privacy policy of any third-party site you visit.

Updates to This Policy

We may update this Privacy Policy from time to time. Any revisions will be published on this page with a revised effective date. We recommend checking this page periodically.

Contact Us

For any questions about this Privacy Policy or how we handle your personal data, please contact us:

Central Pacific Consultants Limited
2/F Beverly House, 93-107 Lockhart Road
Wan Chai, Hong Kong

Email: enquiry@centralpacific.hk