Privacy Policy

Last updated: [Fill in date before launch] · Applies to Apply Job HK (the "Service", "we", "us")

⚠️ Template draft — must be reviewed by a lawyer before use. This document is drafted with reference to Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) and the guidance of the Office of the Privacy Commissioner for Personal Data, as a starting template only. It has not been reviewed by a legal professional and does not constitute legal advice. Before formal adoption, have it reviewed by a Hong Kong lawyer and fill in all the details in [ ]. This is an English translation provided for convenience; in the event of any discrepancy, the Traditional Chinese version prevails.

We value your personal data. This policy explains how we, as the "data user", collect, use, store and protect your personal data, and your rights under the Privacy Ordinance.

1. The personal data we collect

To provide the services you have purchased, we may collect:

2. Purpose and use of collection

We use your personal data only for the following directly related purposes:

We will not use your data for purposes beyond the above; any marketing use requires your prior express consent (opt-in), which you may withdraw at any time.

3. Categories of recipients to whom data is transferred

In the course of providing the service, your data may be transferred, on your instruction, to the following categories of recipients:

CategoryPurpose
The job platforms and employers you chooseSubmitting job applications you have confirmed
Contractors / cloud service providers who help us deliver the serviceDocument processing, data storage (bound by contract, see Section 5)

We will not sell, rent out or use your personal data for any third party unrelated to this Service.

4. Data security

We take all practicable steps to protect your personal data against unauthorized or accidental access, processing or loss, including encryption in transit and at rest, access controls, and staff confidentiality obligations.

On login data: we avoid storing your account passwords wherever possible; where genuinely necessary, we handle it with the highest sensitivity and delete it immediately once it is no longer needed. Please note that some platforms' terms of use (such as LinkedIn and JobsDB) may restrict third parties from operating accounts on your behalf; the related risks are detailed in our Terms of Service.

5. Data retention and contractors

We will not retain your personal data longer than necessary. After the service is completed, we will delete or anonymize your data within [suggested: e.g. 12 months]; login data is deleted immediately once it is no longer needed.

If we engage contractors or cloud services to process your data, we use contracts to ensure they comply with the same retention and security standards. Under Section 65 of the Privacy Ordinance, we remain legally responsible for the acts of our authorized agents; if any data is processed outside Hong Kong, we will use the recommended cross-border transfer contractual clauses.

6. Your rights: access and correction

You have the right to request access to and correction of the personal data we hold about you. We will respond within 40 days of receiving your request. To exercise these rights, please contact [privacy contact email].

7. Third-party data in your CV

If your CV contains other people's data (such as referees), you confirm that you have obtained those individuals' consent for us to use their data for the purpose of submitting applications. We will not proactively contact, or otherwise use, such third-party data.

8. Direct marketing

We will not use your personal data for direct marketing without your prior express consent. Even where you have consented, you may request that we stop at any time, free of charge, and we will comply immediately.

9. Policy updates and contact

We may update this policy from time to time, and the updated version will be published on this website. If you have any enquiry about this policy or your personal data, please contact:

[Company name] · Privacy Officer
Email: [fill in] · Address: [fill in] (Hong Kong)