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Privacy Policy

Last Updated: March 2026

Introduction

Lacuna ("we," "us," or "our") is committed to protecting your privacy and ensuring you have a positive experience on our website and in our client relationships. This Privacy Policy explains our practices regarding the collection, use, and protection of your information.

1. Information We Collect

We collect information that you provide directly to us:

2. How We Use Your Information

We use collected information for the following purposes:

3. Legal Basis for Processing

We process personal data on the following legal bases:

4. Data Retention

We retain personal information for the following periods:

5. Data Protection and Security

We maintain reasonable security measures to protect your information from unauthorized access, alteration, or disclosure. These include:

6. Third-Party Services

We may share information with third parties in the following circumstances:

7. Your Rights

Under Hong Kong's Personal Data Privacy Ordinance, you have the following rights:

To exercise these rights, please contact us at the address below.

8. Cookies

Our website uses cookies to enhance your experience. These include:

You can manage your cookie preferences through your browser settings or our cookie policy page.

9. Complaints and Escalation

If you believe we have mishandled your personal data or violated your privacy rights, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong. You can also contact us directly to discuss your concerns.

10. Policy Changes

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of significant changes by posting the updated policy on our website and updating the "Last Updated" date.

11. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Email: [email protected]

Address: Room 2803, 28/F, Three Pacific Place, 1 Queen's Road East, Admiralty, Hong Kong

Phone: +852 2598 4371

12. Additional Information

Data Controller: Lacuna is the data controller for information collected through our website and services.

Jurisdiction: This Privacy Policy is governed by the laws of Hong Kong, including the Personal Data Privacy Ordinance.

International Data Transfers: Some of our service providers may be located outside Hong Kong. We ensure any such transfers comply with Hong Kong privacy law.