Privacy Policy
This Privacy Policy explains how E-SMART GROUP LIMITED collects, uses, and protects the personal information of users ("you", the "User") of the E-Smart Group website, accessible at https://e-smart-group.com.
We attach great importance to respecting your privacy and protecting your personal data. This Policy is drafted in accordance with the requirements of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and the six Data Protection Principles (DPPs) established thereunder.
1. Data Controller
The data controller responsible for the processing of personal data collected through the Website is:
E-SMART GROUP LIMITED
Rm 701, Unit 108, 7/F, Tower B, New Mandarin Plaza, 14 Science Museum Road, Tsim Sha Tsui, Hong Kong
Business Registration Certificate Number: 79681439-000-01-26-1
Contact: contact@e-smart-group.com
2. Personal Data We Collect
We collect the following categories of data :
2.1 Information Provided Directly by Users
When you use our contact form or communicate with us through the contact details displayed on the Website (email, WhatsApp, etc.), we may collect:
Your first and last name;
Your email address;
Your telephone number (where applicable);
The name of your company or project (where applicable);
The content of your message and any information you choose to include.
2.2 Information Collected Automatically
When you browse the Website, certain information may be collected automatically, including:
IP address, browser type and version, operating system, and language settings;
Pages viewed, date and time of access, visit duration, and traffic source;
Cookie identifiers and advertising tracking technologies (see Section 6).
3. Purposes of Processing and Legal Bases
We collect the following categories of data :
3.1 Responding to Contact Requests
Purpose: Processing requests for information, quotations, or commercial introductions and managing pre-contractual communications.
Legal Basis: Performance of pre-contractual measures requested by you and/or the legitimate interest of the publisher in responding to inquiries.
3.2 Website Analytics and Improvement
Purpose: Understanding how the Website is used, improving user experience, and enhancing content relevance.
Legal Basis: User consent obtained through the cookie banner and/or the legitimate interest of the publisher where anonymized and non-intrusive analytics tools are used.
3.3 Marketing, Retargeting and Advertising Performance Measurement
Purpose: Measuring advertising effectiveness, creating audiences for marketing campaigns, and displaying relevant advertisements on third-party platforms.
Legal Basis: User consent obtained through the cookie banner before the placement of advertising cookies and tracking technologies.
3.4 Compliance with Legal and Regulatory Obligations
Purpose: Complying with applicable legal obligations and protecting the legitimate rights and interests of E-SMART GROUP LIMITED in the event of disputes or legal proceedings.
Legal Basis: Legal obligation and legitimate interest of the publisher.
4. Recipients of Personal Data
Your personal data may be shared with:
Authorized personnel of E-SMART GROUP LIMITED;
Technical service providers acting on our behalf, including our hosting provider (Framer B.V.) and communication or CRM tools;
Meta Platforms Ireland Ltd., TikTok Technology Limited, and Snap Inc., exclusively in connection with the advertising cookies and tracking pixels described in Section 6;
Competent public authorities where required by law or judicial proceedings.
We never sell or rent your personal data to third parties for commercial purposes.
5. International Data Transfers
Given the international nature of our activities and the services used to operate the Website, your personal data may be transferred to and processed in jurisdictions outside Hong Kong, including countries where our service providers, partners, or technical infrastructure are located.
Where such transfers occur, we take reasonable measures to ensure that your personal data benefits from an adequate level of protection and is processed in accordance with applicable data protection requirements.
By using the Website and providing your personal data, you acknowledge and agree that such international transfers may occur.
6. Cookies and Advertising Trackers
The Website uses cookies and tracking technologies to ensure its proper functioning, measure audience performance, and deliver targeted advertising.
6.1 Categories of Cookies Used
Strictly Necessary Cookies
These cookies are essential for the operation of the Website, including security features and storage of your cookie preferences.
Their use does not require your consent.
Analytics Cookies
These cookies allow us to measure Website traffic and performance.
They are subject to your prior consent where required by applicable law.
Advertising Cookies and Tracking Pixels
Meta Pixel (Facebook / Instagram)
Operated by Meta Platforms Ireland Ltd.
Privacy Policy: https://www.facebook.com/policy.php
TikTok Pixel
Operated by TikTok Technology Limited.
Privacy Policy: https://www.tiktok.com/legal/page/eea/privacy-policy/en
Snap Pixel
Operated by Snap Inc.
Privacy Policy: https://snap.com/privacy/privacy-policy
These tracking technologies may collect your IP address, advertising identifiers, and browsing activity and may associate such information with accounts you hold on these platforms.
They are only activated after obtaining your prior consent.
6.2 Managing Your Consent
During your first visit, a cookie banner allows you to accept, reject, or customize the use of non-essential cookies.
You may change your preferences at any time through the Website's cookie management tool or by deleting cookies from your browser settings.
You may also opt out of personalized advertising directly through your Meta, TikTok, or Snapchat account privacy settings.
7. Data Retention Periods
Your personal data is retained only for periods proportionate to the purposes for which it was collected:
Contact form submissions and commercial communications: retained for the time necessary to process your request and subsequently archived for three (3) years from the last contact for commercial prospecting purposes;
Analytics data: retained for a maximum period of twenty-five (25) months;
Advertising cookies and tracking pixels: maximum lifespan of thirteen (13) months;
Data retained to comply with legal obligations: for the period prescribed by applicable law.
8. Your Rights Regarding Your Personal Data
In accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and the Data Protection Principles (DPPs), you have the following rights:
Right of Access (Data Access Request – DPP6 / Section 18): to obtain confirmation that personal data relating to you is held and to receive a copy thereof;
Right of Correction (Data Correction Request – Section 22): to request correction of inaccurate or incomplete data;
Right to Object to Direct Marketing (Sections 35A–35M): to opt out of direct marketing communications free of charge;
Right to Withdraw Consent: where processing is based on your consent.
To exercise these rights, please contact us at:
We may request proof of identity where necessary.
If you believe your personal data has been processed in breach of applicable regulations, you may lodge a complaint with the Privacy Commissioner for Personal Data (PCPD), Hong Kong's supervisory authority for personal data protection.
Website: https://www.pcpd.org.hk
9. Data Security
We implement reasonable technical and organizational measures, consistent with industry standards, to protect personal data against loss, alteration, unauthorized access, or disclosure.
These measures include:
HTTPS-secured communications;
Access controls for internal systems;
Staff awareness and training;
Careful selection of service providers and subcontractors.
However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.
10. Minors
The E-Smart Group Website is not intended for individuals under eighteen (18) years of age.
We do not knowingly collect personal data from minors. If you are under 18, please do not provide us with personal information.
If you believe that a minor has provided us with personal data, please contact us so that we can take appropriate deletion measures.
11. Changes to This Privacy Policy
This Privacy Policy may be amended at any time to reflect regulatory, technical, or organizational developments.
The latest version will always be available on the Website, and we encourage you to review it regularly.
12. Governing Law
This Privacy Policy shall be governed by the laws of the Hong Kong Special Administrative Region.
Any dispute relating to this Privacy Policy shall be submitted to the exclusive jurisdiction of the competent courts of Hong Kong.
13. Contact
For any questions regarding this Privacy Policy or the processing of your personal data, please contact us at: