WHEREAS Aplash(Hongkong)Limited (hereinafter referred to as the "Company," "we," "us," or "our"), duly incorporated under the laws of the Hong Kong Special Administrative Region, is engaged in the business of providing Merger & Acquisition ("M&A") advisory, tax consulting, business consulting, and immigration services (collectively, the "Services"), and WHEREAS the Company, in the course of offering its Services, may collect, process, use, disclose, or otherwise handle the personal data of its clients, prospective clients, and visitors to its website, and WHEREAS the Company is committed to protecting such personal data in accordance with the laws of Hong Kong, including without limitation the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"), NOW THEREFORE, the Company hereby adopts this Privacy Policy (the "Policy"), the terms and conditions of which shall govern the Company's handling of personal data. By accessing our website or otherwise availing yourself of our Services, you (hereinafter referred to as "you," "user," "client," or "visitor") acknowledge, accept, and agree to be bound by this Policy.
This Policy applies to all personal data collected, used, or disclosed by the Company in Hong Kong (or elsewhere, to the extent required by law), whether via our website, direct communications, or any other means in connection with our M&A advisory, tax consulting, business consulting, and immigration Services. The Company operates from offices in Hong Kong, Osaka (Japan), and Shenzhen (China); personal data may be processed across these locations, subject to the safeguards described in Section 8 (Cross-Border Transfers).
This Policy is governed by and shall be construed in accordance with the laws of the Hong Kong Special Administrative Region, including but not limited to the PDPO. Insofar as any provision contained herein conflicts with applicable law, such law shall prevail, and the conflicting provision shall be deemed amended or severed as necessary.
To the extent that the Company collects or processes personal data of individuals located in Japan, such processing shall be conducted in compliance with Japan's Act on the Protection of Personal Information (個人情報保護法 / APPI) and related guidelines issued by the Personal Information Protection Commission (PPC), in addition to the PDPO.
Subject to your express or implied consent, or as otherwise permitted or required by law, we may collect, record, and process the following types of personal data that you voluntarily provide to us:
In addition to the foregoing, we may automatically collect certain technical or aggregated data arising from your use of our website or digital platforms, such as:Log Files: IP address, browser type, operating system, and details of the pages you visit;
Cookies and Similar Technologies: Text files or other tracking tools that enable us to recognize your device, personalize your experience, and analyze site performance. You may adjust your browser settings to refuse cookies, although doing so may limit certain functionalities of our website.
We shall only collect, retain, and use personal data for one or more of the following lawful purposes:
To facilitate and perform the Services contemplated under any agreement we have with you, including but not limited to: M&A Advisory (conducting due diligence, structuring transactions, and negotiating deals); Tax Consulting (strategic tax structuring, compliance coordination, and cross-border tax advisory); Business Consulting (offering strategic advice, market analysis, or management solutions); and Immigration Services (preparing, filing, and following up on visa or permit applications).
To communicate with you regarding administrative matters, updates or Services, or to respond to any inquiries, complaints, or feedback you may have.
To ensure compliance with applicable laws, court orders, law enforcement or regulatory directives, and the requirements of the PDPO, which may include identity verification obligations under anti-money laundering ('AML') or counter-terrorism financing ('CTF') statutes.
To promote our Services, seminars, or events that may be of interest to you, provided you have not objected to such use or have given prior consent, where required by law.
To monitor, maintain, and improve our website's performance, security, and user experience by conducting data analysis, usage analysis, and related evaluations.
We may rely on your express or implied consent to process personal data for particular purposes, subject to the provisions of the PDPO and other applicable laws.
Processing is necessary for the performance of contractual obligations between you and the company.
Processing is mandated by applicable laws, court orders, or regulatory requirements, including obligations under Hong Kong law pertaining to AML/CTF.
Processing is necessary for the legitimate interests pursued by the Company or by a third party, except where such interests are overridden by your fundamental rights and freedoms.
We may share personal data internally among our staff, directors, or affiliates on a need-to-know basis in order to properly deliver the Services or otherwise manage the Company’s business operations.
Where necessary, we may engage trusted third parties to perform certain functions or services on our behalf, including but not limited to payment processing, legal or immigration counsel, auditors, cloud hosting providers, or IT maintenance. Any such third parties are contractually bound to handle personal data in accordance with the PDPO and comparable standards of confidentiality and security.
In the event the Company considers or undergoes a merger, acquisition, restructuring, or sale of all or a substantial portion of its assets, personal data may be disclosed to appropriate counterparties or their professional advisors, subject to customary confidentiality obligations.
We may disclose personal data where required to do so by law, court order, or regulatory directive, or if such disclosure is otherwise reasonably necessary to assert, protect, or defend the lawful rights, interests, or property of the Company or any other person.
The Company shall not retain personal data for any period longer than is necessary to fulfill the purposes for which it was collected, or as otherwise required or permitted by law. Upon the expiration of any applicable retention period, we shall securely destroy or anonymize personal data in accordance with established protocols.
The Company implements commercially reasonable measures and best practices to safeguard personal data from unauthorized or accidental access, processing, erasure, or other misuse. Such measures may include, without limitation, restricting system access to authorized personnel, employing encryption or secure socket layer (SSL) protocols, and maintaining physical, electronic, and procedural safeguards.
To the extent that it becomes necessary to transfer personal data outside Hong Kong for the performance of the Services or for any other lawful purpose described herein, we shall take such measures as may be required by law to ensure that any third-party recipient provides a standard of protection that is at least comparable to the PDPO and relevant data protection principles.
Subject to applicable law and the exemptions therein, you may be entitled to exercise the following rights with respect to your personal data:
Our Services and website are neither intended for nor directed at persons under the age of eighteen (18). We do not knowingly collect personal data from minors. In the event that you become aware that a minor has provided us with personal data, please notify us promptly so that we may take appropriate action to delete or anonymize such data.
Our website may contain links to third-party websites or resources over which we have no control. We are not responsible or liable for the content, privacy practices, or terms of use of any external sites. We encourage you to review the privacy policies of any websites you choose to visit.
If you have any questions or concerns regarding this Policy, or if you wish to exercise any legal rights under the PDPO or other applicable legislation, please direct your written request or inquiry to:
Address: Room 701, Unit 108 Tower B, 14 Science Museum Road, Tsim Sha Tsui, Kowloon, Hong Kong
Email: contact@aplash.io
We will endeavor to respond to your request or inquiry within a reasonable timeframe, in accordance with the applicable legal requirements.
The Company provides strategic consulting and advisory services. The Company does not hold a 税理士 licence under Japan's 税理士法 (Tax Accountant Act) and does not perform services reserved to licensed tax accountants, including the preparation and filing of tax returns. All tax filings, registrations, and statutory submissions in Japan are executed by independently licensed 税理士 engaged by or on behalf of the client. Nothing on the Company's website or in its materials constitutes tax, legal, or accounting advice. Clients should seek independent professional advice appropriate to their circumstances.
We reserve the right, at our sole discretion, to amend or update this Policy from time to time to reflect any changes in our legal or regulatory obligations, business operations, or otherwise. Any such amendments shall be effective upon posting the revised Policy on our website, and the “Effective Date” at the top of this Policy shall be updated accordingly. Your continued use of our website or Services after such posting shall constitute your acceptance of the revised Policy.
IN WITNESS WHEREOF, by accessing our website or using our Services, you hereby acknowledge that you have read, understood, and consented to the aforementioned terms. We remain dedicated to preserving the confidentiality, integrity, and security of your personal data in accordance with the PDPO and all applicable laws.