Privacy Policy

We handle Personal Data in accordance with applicable data protection laws, including but not limited to:

• The Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (PDPO)
• Any other applicable national or regional data protection laws

“Personal Data” means any information relating to an identified or identifiable living individual. This includes information that can directly or indirectly identify a person when combined with other data.

You may be required to consent to this Policy when making enquiries, registering for events, or interacting with our Products and Services. Where permitted by Applicable Laws, your continued use of our Products and Services constitutes your acceptance of this Policy.

If you do not agree with this Policy, please refrain from providing Personal Data and discontinue use of our Products and Services.

We process Personal Data only when at least one of the following legal bases applies:

• Consent – You have given explicit consent, which may be withdrawn at any time
• Contractual necessity – Processing is required to perform a contract with you
• Legitimate interests – Processing is necessary to protect our interests or those of third parties
• Legal obligation – Processing is required to comply with legal or regulatory requirements

Depending on your interaction with our Products and Services, we may collect the following categories of Personal Data:

We may also receive Personal Data from third parties who are legally authorised to provide such data.

We use Personal Data for the following purposes:

• To provide, operate, and maintain our Products and Services
• To customise, improve, and enhance user experience
• To provide customer and technical support
• To analyse usage trends and performance
• To manage security, fraud prevention, and abuse detection
• To comply with legal and regulatory obligations
• To conduct research and develop new services
• For any other purpose disclosed at the time of collection

With your explicit consent, we may also use Personal Data for direct marketing (see Section E).

We use cookies and similar technologies to improve functionality and user experience.

Cookies are small text files stored on your device. You may manage or disable cookies via your browser or device settings. However, disabling cookies may affect the availability or performance of certain features.

We use cookies to:

• Identify users
• Analyse usage behaviour
• Improve Products and Services
• Optimise marketing and advertising efforts

With your explicit consent, we may use your name, email address, and phone number to send marketing communications, including promotions, updates, and offers.

You may withdraw your consent at any time without charge by contacting us or using the unsubscribe mechanism provided in our communications.

Non-marketing service-related communications may still be sent where necessary.

We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected or as required by Applicable Laws (Retention Period).

Personal Data will be deleted or anonymised when:

• The Retention Period expires
• It is no longer required for service provision
• We receive a valid deletion request, subject to legal obligations

We may share Personal Data on a need-to-know basis with:

• Evona affiliates
• Cloud infrastructure and hosting providers
• Payment processors
• Customer support and CRM providers
• Professional advisers (legal, accounting)
• Government or regulatory authorities
• Successors or assignees

Some recipients may be located outside Hong Kong. We ensure that any cross-border transfers comply with Applicable Laws and are subject to appropriate safeguards.

We implement appropriate technical and organisational measures to protect Personal Data, including:

• Encryption at rest and in transit
• Access control and role-based permissions
• Confidentiality obligations for personnel
• Incident response and breach notification procedures

In the event of a data breach, we will notify affected parties and regulators as required by law.

Subject to Applicable Laws, you have the right to:

• Be informed about data processing
• Access your Personal Data
• Correct inaccurate or incomplete data
• Request deletion or restriction of processing
• Request data portability
• Object to processing, including direct marketing
• Be notified of data breaches

Requests may be made using the contact details below.

Our Products and Services are not intended for individuals under the age of 18. We do not knowingly collect Personal Data from children.

Where Evona acts as a data processor for Clients, we process Personal Data strictly in accordance with Client instructions and contractual obligations and do not use such data for our own purposes.

Our Products and Services may contain links to third-party websites. We are not responsible for their privacy practices and encourage you to review their policies before providing any Personal Data.

This Policy forms part of and is incorporated into our Terms of Use available on our website.

We may update this Policy from time to time. Material changes will be communicated via our Products and Services or by other appropriate means. Changes take effect 30 days after notification unless otherwise required by law.

If any provision of this Policy is found unenforceable, the remaining provisions shall remain in full force and effect.

This Policy is governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region. Any disputes shall be resolved by arbitration in Hong Kong in accordance with applicable arbitration rules.

If you have any questions, concerns, or requests regarding this Policy or your Personal Data, please contact:

Data Protection Officer

Evona Limited

Website: https://www.evona.ai/

Email: privacy@evona.ai