Privacy Policy

1. Scope of this policy

This policy explains how HeCheng (Asia) Limited, its officers and its contracted specialists process personal information. It applies to every visitor of the studio website, to every person who writes to us by email, by post, by telephone or through the online enquiries form, and to the measures we take when we design, integrate and operate computer systems that may carry the personal information of the end users of a client operation.

The policy uses plain language wherever the law allows. Where a term carries a defined meaning under the Personal Data (Privacy) Ordinance of Hong Kong, or under any regulation that applies in the region where a client operates, the policy follows that meaning. Nothing in this policy reduces a right that you already hold under the law of your own residence.

We act as a controller for the information we gather about our own visitors and enquirers. Where we build systems for a client, that client commonly acts as the controller of the underlying operation and we act as a processor or as a designer under their instructions. The two roles are described separately below so that you are never confused about which promise applies where.

He Cheng personally reviews this policy at least once every twelve months, and the studio keeps the wording current with the tools it actually runs rather than with tools it once planned to run.

3. What we collect

We collect only the smallest set of information that lets us answer an enquiry, run the website, and deliver the services we are asked to deliver. For a source of this policy the categories are modest. When you write to the studio you supply your name, your email address, your telephone number if you choose to give it, the subject of your message and the message itself. When you browse the website we collect technical details of the visit.

We do not build shadow profiles of casual readers, we do not buy personal information from data brokers, and we do not assemble a dossier about you from fragments collected across other sites. If a file about you exists in our care, it exists because you chose to start a conversation with the studio or because a client lawfully asked us to handle data that concerns your relationship with that client.

We also collect information that identifies the devices and connections used to reach us, such as the internet protocol address of your access point, the type of device and browser you used, the pages you opened and the time you spent. This material is used at a low level and is kept no longer than the protection of the website reasonably demands.

Where you request work from us we may need further detail: the address and legal structure of your company, the names of the people authorised to make technical decisions, the records of your existing systems and the permissions we need to read them. These are collected for the performance of a commission and no more.

4. Categories of information

Broadly, the personal information we hold falls into a small set of categories. Identity data covers your name, your job title and the organisation you represent. Contact data covers the email address, the postal address and the telephone number you give us. Technical data covers device and network details gathered while you visit the website. Profile data covers the preferences you tell us about in relation to a prospective or active commission.

Transactional data records the conversations, the quotes, the scoping documents and the handover records of an engagement. Operational data covers information that passes through integrated systems when a client exercises our services, but that data belongs to the client and never belongs to us.

We deliberately do not collect special categories of information about our enquirers, because we have no reason to ask for details of your health, your beliefs, your ethnicity or your biometric measures in the normal course of selling systems design. If you volunteer such detail in a message, we treat it with the same confidentiality we apply to everything else and we delete it once it is no longer needed.

We do not intentionally hold information about criminal convictions of any person, and our work offers no occasion to do so.

5. How collection happens

Information reaches us in four ways, all of them open and none of them hidden. The most obvious is through the contact form on this site, where the fields ask only for a name, an address, a subject and the message you wish to send. The second is through direct correspondence: email, telephone, post, or a meeting held online or in person where notes are taken.

The third is through the visible logs that any website server keeps as a matter of course. When your browser asks a page for content, the server records the arrival, the address of your connection, the page you asked for and the moment of the request. This is standard practice across the entire web and is not chosen to spy on any one visitor.

The fourth is through the code of a planned or active commission. When HeCheng (Asia) Limited integrates a system for a client, information collected by that system arrives at the system boundaries in the ordinary course of business, and our handling of it follows the specific role assigned to us by that client.

We make no attempt to gather information through deceptive means, hidden software on your device, or the silent reading of your address book.

6. Purposes of processing

The studio uses personal information for purposes that a careful reader would expect. We use it to answer your enquiries and to hold the resulting conversation in an organised way. We use it to prepare quotes, scoping documents and contracts, and to issue invoices for work done and collect payment for that work. We use it to deliver the integrated systems we design, to provide support after handover, and to diagnose faults when something stops working.

We use it to satisfy legal and accounting obligations, such as the need to keep business records, to answer regulator queries and to prevent fraud against us or against the systems we tend. We also use it to protect the security of this website and of any system we run for a client, which includes the detection of unauthorised access, the blocking of hostile traffic and the recovery of data after an incident.

We use minimal internal records to understand how many genuine enquirers the studio attracts in a quarter, so that He Cheng can decide honestly whether the bench has room for more commissions.

None of these purposes amounts to selling your information to an advertiser, packaging you for a mailing list of strangers, or making automated decisions that materially shape your life based solely on the analysis of your data.

7. Lawful grounds we rely on

Where a data regulation requires us to name a lawful basis, we point to the grounds that fit the facts. For answering a pre-contract enquiry and preparing a quote, the ground is the taking of steps at your request before entering a contract. For delivering an active commission, the ground is the performance of the contract you have made with the studio.

For records we must keep to meet our duties under Hong Kong law and the rules of the accounting profession, the ground is the discharge of a legal obligation. For security controls on the website and on client systems, the ground is the legitimate interest of keeping a working estate intact and free from harm, weighed against the modest intrusion of technical logging.

Where we rely on a legitimate interest, we record the interest and the balancing that supports it, so that the judgement is never made silently inside a single mind.

Where we process material in the role of a processor for a client, we act only on the documented lawful basis chosen by that client, and we record those instructions in the commission documents.

8. Visitor and technical logs

The website server holds brief technical logs so that the studio can see when content is served, can investigate an outage and can block an abusive address. These logs record the Internet protocol address of the connection, the time and date of each request, the specific page or asset that was requested, the browser family and the referring site, where the browser shares that last detail.

The logs are read only by the small team that operates the site and by the hosting provider under a strict contract. Logs are held on a rolling window of a few weeks and are then overwritten or removed. We make no effort to enrich these records with marketing profiles and we do not sell the raw data to anyone.

If you prefer to avoid technical logs, you may read this site without JavaScript and without cookies, and the essential pages will still render their text and headings accurately, because nothing about an honest privacy notice should depend on being tracked.

9. Storage, cookies and site tools

This website is a mostly static notice covering the studio services. It does not depend on advertising networks, and it does not load third party scripts that follow a visitor across unrelated pages. Where a tool such as a form is used, the information you type is sent to our studio mailbox and not to a provider that profits from your words.

We keep a deliberately light approach to cookies. Any cookies placed are limited to the essentials of running the page, such as remembering whether your browser expanded the mobile navigation, and they carry no advertising value. No cookie set on this site is shared with a data broker.

Because the studio builds logging and monitoring into many of the systems it designs, some of those tools behave like cookies by keeping a record of a user session so that a fault can be replayed. Those tools run under the control of the client that owns the system and under that client policy, and the client decides how long each record remains.

10. Enquiries and project leads

When you write to support@hecheng.buzz or use the website contact form, the studio stores your message and your reply details so that the conversation can continue without your having to repeat yourself. This correspondence is treated as commercially confidential, which means we do not quote your name or your project to another enquirer, we do not announce your enquiry on social media, and we do not add your address to a list that we rent or sell.

If your enquiry matures into a commission, the correspondence becomes part of the project file and is kept in line with the retention periods in this policy. If your enquiry does not mature, we keep the message for a short period so that a follow up from you is not met with a blank stare, and we then delete it in the ordinary housekeeping round.

He Cheng reads every genuine enquiry eventually, which keeps the bench honest: no promise is made to a visitor that the studio cannot actually fulfil.

11. Information about your customers

A distinction that matters: when the studio integrates a system for a client, and that system holds personal information about that client customers, that information does not come under the studio roof to stay. The client remains the controller, the client remains answerable to its own customers, and the studio holds the material only to the extent needed on a given machine to test or to run the system at that moment.

Where the studio operates a system as part of a service, we act under a written agreement that names our role, restricts what we may do, obliges us to protect the data, and requires us to help the client respond to a request from one of its customers. This agreement is reviewed with each client so that the promises match the actual running estate.

If a customer of a client asks a question about their information, the correct first stop is the client of the operation they use. Where a request reaches us by mistake, we forward it to the client without delay and keep no copy unless the client asks us to help.

12. Aggregate and analytics data

The studio occasionally looks at plain totals: how many enquiries arrived, how many pages were read, how many minutes were spent on a commissioning page. This aggregate view helps He Cheng decide what to publish and where to spend studio effort. Aggregate figures are stripped of detail that could identify a single visitor and are kept for the studio own planning.

We do not treat aggregate analytics as a license to record every key a person presses. Dashboard readings sit at the level of a page and a number, never at the level of a keystroke diary of a named individual.

Where we run analytics on a client system, the client decides which definitions of a metric matter and controls who may view the resulting numbers. We implement those controls and then step back so that the client keeps the keys.

13. Sharing we do not practise

The list of things the studio will not do with your personal information is short and firm. We do not sell your personal information. We do not rent your personal information. We do not trade your personal information for free advertising. We do not hand your details to a data clearing house, a lead reseller or a mailing-list merchant so that they can sell you something unrelated to integrated systems.

We do not read the personal conversations of a client end user to one another. We do not sell the output of a system we build to a stranger. We do not transfer your details to any country merely because its laws are convenient for us; transfers happen only when the service genuinely needs them and are always protected by appropriate measures.

If a visitor lets the studio down by abusing the website, we may share the small technical details with the hosting provider or the authorities to stop the abuse, and that is the single responsible exception to an otherwise closed list.

14. Partners and processors

Like any small design studio, HeCheng (Asia) Limited leans on a few capable partners to keep its own lights on: a hosting company that runs the web server, a firm of accountants, a bank that clears invoices and a postal or courier service for documents. Each partner receives only the detail its job requires and is bound by contract not to use that detail for its own purposes.

We keep a register of the processors who touch personal information so that the chain of custody is never a mystery. The register names the processor, the task, the volume of data and the safeguards in place, and it is available for a client to inspect during an active commission.

We choose partners with a preference for those who operate under regulations with strong protections, and we keep the choice under review so that a partner does not quietly grow careless of your detail while our attention is on a commission.

15. Cross border transfers

HeCheng (Asia) Limited is registered in Hong Kong, and a client operation may run anywhere. When information belonging to an end user in one country is handled on a machine or by a person in another country, the transfer must be lawful and must carry the same level of protection the end user enjoyed before the move.

For transfers between Hong Kong and a region subject to the General Data Protection Regulation or an equivalent regime, we rely on the standard contractual measures that the law recognises, the adequacy findings that the law makes, or the explicit consent of the person concerned, whichever fits the case. For transfers among the territories that make up the wider operations a client serves, we follow the client written protocol for the movement of data.

The studio does not park your personal information in a jurisdiction with weak protections merely to reduce its own cost of care. If a partner is located outside Hong Kong, the written agreement with that partner spells out the same duties you read here, and the agreement is signed before a single record is handed over.

16. Retention and deletion

Personal information is kept only as long as the purpose for which it came remains real. Correspondence about an enquiry that never became a commission is deleted after a short holding period set by practice. Commission records are kept for as long as the law of accounting and taxation requires, which is typically several years, because a regulator may ask a question long after the last invoice was paid.

Technical logs have the shortest life and are rolled off after a few weeks. Records needed to defend the studio or a client against a claim are kept for the period that a claim could lawfully be brought. When every reason to hold a record has lapsed, the record is deleted from active systems and from backups on a schedule that the studio records.

Deletion is complete and quiet: we do not keep a secret copy for future profit, and we confirm deletion to a person who has asked for it. Where a record sits inside a system we built for a client, the client decides the retention and we follow the client instruction, because the client owns that pane of the window.

17. Security measures

The studio treats security as a craft rather than a slogan. Access to information is limited to the people who need it for their task, and each person signs a confidentiality agreement that He Cheng reviews. Accounts are protected by strong passwords and by a second factor wherever the tool allows, and sensitive material is encrypted while it travels and, where it makes sense, while it rests.

We patch the tools we run, we back up the data that must survive an accident, and we rehearse the recovery of a system so that a failure is a procedure rather than a panic. On a system we build and operate for a client, we apply the same discipline and add the alarm and monitoring measures described in the service pages of this site.

No studio can promise a world in which no one is ever attacked; what we promise is an honest estate where an attack is noticed, contained, reported and learned from. If a breach of the kind that must be told to you occurs, the studio notifies the affected controller without undue delay and helps that controller tell its own people plainly.

18. Your rights and choices

Depending on the law where you live, you may hold a number of rights over the personal information you share with the studio. You may ask to see a copy of the personal information we hold about you. You may ask us to correct a detail that is wrong or out of date. You may ask us to delete information when the reason for holding it has gone, or to restrict what we do with it, or to give it back to you in a readable form.

You may withdraw a consent you gave, where consent is the ground on which we act. Where we rely on a legitimate interest, you may object and we will weigh your objection honestly, stopping the processing where it does not properly outweigh your position.

To exercise a right, write to support@hecheng.buzz, describe the right you wish to use and give enough detail for the studio to find the record safely. We verify your identity before we honour a request that could lead another person astray, we answer within the legal period, and we never charge a fee for a first, honest look at the records we keep about you.

If our answer does not satisfy you, you may complain to the Privacy Commissioner for Personal Data of Hong Kong, or to the supervisory authority where you live, and we will treat that complaint with respect rather than defensiveness.

19. Children privacy

The studio services are directed at adults who make decisions about enterprise systems, and the website is not aimed at children. We do not knowingly collect personal information from a child, and the integration projects we design do not treat children as their audience unless the client tells us clearly that an end of their operation serves young people.

Where a client does serve children, the client carries the duty of parental consent and the responsibility for explaining its own practices to the families it serves. The studio supports that client with well-built permission tools and clear logs, but the client policy and the client consent are the client own business, not a decision taken silently inside our bench.

If a parent or guardian tells us that a child has sent us personal information by mistake, we delete it without further fuss, confirm the deletion, and thank the parent for raising the matter with us directly rather than through a third party.

21. Changes to this policy

The studio reviews this policy regularly and updates it whenever the tools, the services or the law change in a way that a fair reader would want to know about. Material changes are announced on this page with a fresh review date, and where the change touches a service you already use we tell you directly before the change takes effect on your estate.

Because He Cheng reviews the wording personally, the policy stays close to the reality of the bench. A statement in this document is a working promise made by the founder and the company together, and both are bound by it.

The responsibilities owned by a client for its own customers are described throughout this policy so that no reader mistakes a processing role for ownership. If a sentence leaves you unsure whether a given record sits with the client or with the studio, ask us and we will give you a straight answer naming the pane and its keeper.

This policy was reviewed and published on the date shown in the footer. Keep a copy if it matters to you, because the wording you rely on may be updated in a later quarter.