Privacy & Data Protection Policy

1. Introduction & Governance

Welcome to 512 CyberX Limited ("we," "our," or "us"). We are committed to safeguarding your privacy and ensuring that all personal information and proprietary data are treated with uncompromising confidentiality, rigorous technical security, and strict compliance with applicable data protection regulations.

This Privacy Policy outlines how we collect, handle, store, and protect information when you visit our website (www.512cyberx.com), interact with our mobile applications, or engage our interactive 3D software and enterprise IT services (collectively, the "Services"). This policy strictly complies with the statutory provisions of the Personal Data (Privacy) Ordinance (PDPO) of the Hong Kong Special Administrative Region.

2. Information We Collect

We collect only the information necessary to provide, optimize, and secure our software applications and commercial engineering services:

• Direct Contact Data: Name, business email, organization name, and inquiry details voluntarily submitted via our consultation request forms.
• Technical Telemetry: When utilizing our client mobile applications or 3D games, we may collect non-identifiable diagnostic data including device model, operating system version, performance metrics, frame latencies, and crash diagnostic logs.
• Application Usage Metrics: Aggregate information regarding feature utilization and user journeys to identify bottlenecks, optimize 3D asset streaming, and improve software stability.

3. Lawful Basis & Use of Data

We process personal and technical data strictly for legitimate commercial and engineering purposes:

• To evaluate client project scopes and fulfill contractual software engineering engagements.
• To maintain, patch, and enhance the responsiveness, security, and performance of our applications.
• To safeguard client systems, mitigate unauthorized access attempts, and enforce zero-trust security controls.
• To fulfill statutory accounting, corporate governance, and regulatory requirements in Hong Kong.

4. Third-Party Safeguards & Data Disclosure

We never sell, monetize, or commercialize your personal information or project data to third parties. Data may only be shared under the following strictly controlled scenarios:

• Infrastructure Partners: Secure cloud providers (e.g. AWS, GCP) operating under signed Data Processing Agreements and strict ISO 27001 / SOC-2 compliance frameworks.
• Legal & Regulatory Mandates: Where disclosure is strictly required by Hong Kong SAR law, judicial order, or governmental investigative authorities.

5. Enterprise Data Security & Retention

We apply defense-in-depth principles including cryptographic hashing, TLS 1.3 transit encryption, AES-256 storage encryption, and role-based access management (RBAC). Data is retained only for the duration required to achieve the stated business purpose or fulfill statutory audit cycles.

6. Your Data Protection Rights

Under the Hong Kong PDPO, data subjects possess enforceable rights regarding their personal records:

• The right to ascertain whether 512 CyberX Limited holds your personal data.
• The right to request a formal copy of your data records held by our organization.
• The right to request correction of inaccurate, obsolete, or incomplete personal data.
• The right to request data erasure or cessation of communication channels.

7. Privacy Contact & Inquiries

To exercise your statutory data rights or request clarification regarding our security standards, please contact our Data Governance Officer:

512 CyberX Limited
Attn: Data Protection Officer
No. 5, 17/F Strand 50, Bonham Strand, Sheung Wan, Hong Kong
Direct Email: info@512cyberx.com
Hotline: +852 6106 9900