Privacy Policy

How we handle personal data on this website and in the course of delivering our services.

Template — not yet legally reviewed. This document is a drafting starting point prepared alongside the website build. It must be reviewed and adapted by qualified legal counsel before publication, and the bracketed items completed.

Last updated: · Version 1.0 (draft)

1. Who we are

ViralFlux ("ViralFlux", "we", "us") provides B2B back-office operations and administrative outsourcing services. Our registered office is at Regus, China Hong Kong City Tower 3, Canton Road, Hong Kong.

For questions about this policy or about how your personal data is handled, contact us at contact@viralflux.info.

[Insert registered company number and, where a Data Protection Officer or EU/UK representative is appointed, their contact details.]

2. Two distinct roles

This policy covers personal data for which ViralFlux is the controller — principally website visitors, enquiries, and business contacts at prospective and current client organisations.

When we process personal data on behalf of a client while delivering back-office services — for example employee records handled under an HR operations engagement, or customer records handled under a CRM engagement — ViralFlux acts as a processor. That processing is governed by the Data Processing Agreement executed with the client, not by this policy. Individuals whose data is processed in that capacity should direct requests to the client organisation acting as controller. See our GDPR Statement for detail.

3. What we collect

3.1 Information you give us

  • Contact and enquiry details submitted through our forms: full name, work email address, company name, team size, services of interest and the content of your message.
  • Scheduling details if you book a call through our scheduling provider, including your name, email address and chosen time slot.
  • Correspondence you send us by email or telephone, and records of that correspondence.

3.2 Information collected automatically

  • Standard server log data, which may include IP address, browser type and version, operating system, referring page, pages viewed and timestamps.
  • [If analytics are deployed: specify the provider, the identifiers set, the retention period, and the legal basis relied upon. No analytics or advertising cookies are set by the site as currently built.]

Our website loads a web font from Google Fonts and, on the contact page, an embedded map. These third-party services necessarily receive your IP address in order to serve the resource. [Confirm the current provider list before publication and update this paragraph and section 7 accordingly.]

4. Why we process it, and on what basis

  • To respond to your enquiry — necessary for taking steps at your request prior to entering a contract, or our legitimate interest in responding to business enquiries.
  • To provide and administer our services — performance of a contract with your organisation.
  • To operate and secure our website — our legitimate interest in maintaining a functioning, secure service.
  • To meet legal, accounting and reporting obligations — compliance with a legal obligation.
  • To send service-related or marketing communications — your consent where required, or legitimate interest in communicating with existing business contacts. You may opt out at any time.

5. How long we keep it

  • Enquiries that do not lead to an engagement: [24] months from last contact.
  • Client relationship and contractual records: for the term of the engagement plus [7] years, to meet statutory retention requirements.
  • Server logs: [90] days.

Data processed on behalf of a client is retained and deleted according to that client's instructions and the applicable Data Processing Agreement.

6. Who we share it with

We do not sell personal data, and we do not share it with third parties for their own marketing purposes. We disclose personal data only to:

  • Service providers acting on our instructions (hosting, email, scheduling, and where applicable analytics), each bound by written contract;
  • Professional advisers such as auditors and legal counsel, where necessary;
  • Public authorities, where we are legally required to do so.

[Insert the current sub-processor list, or link to a maintained sub-processor page.]

7. International transfers

We are established in Hong Kong, which is not the subject of a European Commission adequacy decision. Where personal data reaches us from the EEA or the UK, we rely on the 2021 Standard Contractual Clauses — with the UK International Data Transfer Addendum where applicable — supported by a transfer impact assessment and appropriate supplementary measures. The same safeguards are applied to any service provider processing data outside the EEA.

8. Security

We maintain technical and organisational measures appropriate to the risk, including TLS in transit, AES-256 encryption at rest, enforced multi-factor authentication, role-based least-privilege access, managed endpoints and mandatory annual staff training. Further detail is set out on our Security & Compliance page. No system can be guaranteed absolutely secure, and we do not represent otherwise.

9. Your rights

Subject to applicable law, you may request access to your personal data; correction of inaccurate data; erasure; restriction of processing; portability; and you may object to processing based on legitimate interests. Where processing relies on consent, you may withdraw it at any time without affecting prior processing.

To exercise a right, email contact@viralflux.info. We respond within one month, and will tell you if we need longer. If you are dissatisfied you may complain to your local supervisory authority, or in Hong Kong to the Office of the Privacy Commissioner for Personal Data (PCPD).

10. Cookies

As currently built, this website sets no cookies of its own and uses no advertising or analytics trackers. [If a cookie is introduced — including through an embedded scheduling widget, map, or analytics — a compliant consent mechanism must be added before those resources load, and this section replaced with a full cookie table.]

11. Children

Our services are directed at businesses. We do not knowingly collect personal data from anyone under 16 through this website.

12. Changes

We may update this policy from time to time. The version and date at the top of this page indicate the current revision; material changes will be communicated to active clients directly.

13. Contact

ViralFlux
Regus, China Hong Kong City Tower 3, Canton Road
Hong Kong
contact@viralflux.info