Privacy Policy

Introduction

Ayala Sultanova Consulting ("we," "us," or "our") is committed to protecting the personal data of visitors to www.ayalasultanova.com in accordance with the Personal Data (Privacy) Ordinance, Cap. 486, of Hong Kong. This policy explains what data we collect, how we use it, and the rights available to you.

What We Collect

· Contact form submissions: name, email address, and message content.

· Automatically collected data: IP address, browser type, and usage data via cookies and analytics tools (see Cookies section below).

Purpose of Collection and Use

We use your personal data to: respond to enquiries submitted via the contact form; provide the services you request; and, where you have opted in, send you marketing communications about our services. We do not use your data for any purpose materially different from those stated here without seeking your further consent.

Classes of Transferees

We may disclose your personal data to third-party service providers who help us operate this website and communicate with you, including our website hosting platform (Wix.com Ltd.), email service provider. These providers are only permitted to process your data for the purposes we specify and are bound by confidentiality obligations. We do not sell, rent, or trade your personal data to unrelated third parties.

Cross-Border Data Transfer

Some of our service providers listed above may store or process data outside Hong Kong (for example, on servers located in Ireland. While section 33 of the PDPO (restricting cross-border data transfers) is not yet in force, we take reasonable steps to ensure any overseas processor affords a standard of protection comparable to the PDPO.

Data Retention

We retain contact form submissions and associated correspondence for one year, or for as long as necessary to fulfil the purpose for which the data was collected, after which it is securely deleted or anonymised. Marketing list data is retained until you unsubscribe or withdraw consent.

Data Security

We implement reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction, appropriate to the sensitivity of the data collected.

Cookies

This website uses cookies to operate core functionality and, where applicable, to analyse site usage. You may control or disable cookies through your browser settings; doing so may affect site functionality.

Your Rights — Data Access and Correction Requests

Under sections 18 and 22 and Data Protection Principle 6 of the PDPO, you have the right to:

· Ascertain whether we hold your personal data and obtain a copy of it (a Data Access Request);

· Request correction of any personal data we hold about you that is inaccurate (a Data Correction Request).

To exercise these rights, please submit a written request to Ayala.sultanova84@gmail.com. We will respond within 40 days as required by the PDPO. We may charge a reasonable fee to cover the direct cost of complying with a Data Access Request.

Withdrawing Consent

Where you have opted in to marketing communications, you may withdraw consent at any time by using the "unsubscribe" link in any marketing email or by contacting us at Ayala.sultanova84@gmail.com.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal obligations. The "Last updated" date below indicates when this policy was last revised.

Contact Us

For privacy-related enquiries, please contact Ayala.sultanova84@gmail.com.

Last updated: 31 July, 2026.