Privacy Policy
This Privacy Policy explains how Phoenix Investment Development Limited collects, uses, stores and protects personal information. It applies to every visitor, client, prospective client, syndicate participant and correspondent who deals with our registry office. Phoenix Investy is the trading name used by the firm on this website and in its daily correspondence, and the developer of this website operates under that same name. We keep this notice plain because a person should be able to understand how their information is handled without legal training. This document should be read together with our Terms of Service, which govern the use of this website.
1. Scope of This Policy
This policy covers personal information that we gather through this website, through email and telephone contact, through forms and correspondence, and through the delivery of our advisory and systems services. It also covers information that we receive from clients, counterparties, agents and professional advisers in the ordinary course of a mandate. It does not cover the practices of third parties that we do not control, even where we refer to them or link to them.
Where a separate agreement or engagement letter contains privacy terms that differ from this policy, the terms of that agreement take precedence for the matter it governs. In all other respects this policy is the standing statement of how the firm treats personal information.
2. Who We Are
The data controller responsible for personal information described in this policy is Phoenix Investment Development Limited, whose registered office and registry desk are located at Room 1, G/F, 33 Bedford Road, Tai Kok Tsui, Hong Kong (HK). The firm carries on the business of investment development, advisory work and integrated systems design, and it maintains the records described here at that address.
References in this policy to we, us and our mean Phoenix Investment Development Limited. References to you mean any individual whose personal information we handle, including website visitors, enquirers, clients, representatives of corporate clients, and participants in a syndicated development.
3. Information We Collect
The categories of personal information that we may collect include the following. We collect only what is reasonably required for the purpose at hand, and we avoid gathering detail that serves no clear function.
- Identity details such as your name, title, organisation and role.
- Contact details such as email address, telephone number, postal address and messenger handle.
- Correspondence content, including the messages you send and the notes we make when replying.
- Professional details such as the nature of your business and your relationship to a matter.
- Financial and transactional details that are necessary for a mandate, such as payment references.
- Technical details such as browser type, device category, approximate region and pages viewed.
- Records of consent, preference and objection that you have expressed to us.
We do not seek to collect special category information such as health data, political opinions or religious belief, and we ask that you do not send such information to us through this website.
4. How We Collect Information
We collect information directly from you when you complete a form, send an email, telephone the desk or correspond with a member of our team. We also collect information automatically when you visit this website, through the small technical records described in the cookies section below.
In some matters we receive information from a third party, for example when a client introduces a representative, when a counterparty provides a contact for a syndicate, or when a professional adviser shares a document that names an individual. Where we receive information indirectly, we handle it under this policy and we expect the party that shared it to have a lawful basis for doing so.
5. Why We Use Information
We use personal information for the following purposes, each of which is connected to a legitimate and stated function of the firm.
- To acknowledge and answer enquiries sent to the registry desk.
- To assess whether we can assist with a proposed mandate and to scope the work.
- To deliver advisory, research, syndication, integration, market entry and reporting services.
- To maintain the register of mandates and the associated correspondence.
- To meet accounting, tax, audit and record keeping obligations.
- To protect the firm and its clients against fraud, misuse and security threats.
- To improve the clarity and usefulness of this website and its content.
- To send updates where you have asked to receive them and to honour any request to stop.
We do not sell personal information. We do not trade it for advertising. We do not use it to build profiles for unrelated commercial purposes.
6. Legal Bases for Processing
Depending on the circumstances, we rely on one or more of the following bases for processing personal information. The first is the performance of a contract or the steps leading to a contract, which applies when you engage us or ask us to prepare a proposal. The second is compliance with a legal obligation, which applies to accounting, tax and record keeping duties.
The third is our legitimate interest in operating a professional advisory firm, which covers answering enquiries, maintaining records, protecting the firm and improving our services. The fourth is consent, which applies where you have specifically agreed to receive marketing material or where a particular use requires it. Where we rely on consent you may withdraw it at any time by contacting the desk, and withdrawal does not affect processing that took place before the withdrawal.
8. Website Analytics
We may measure aggregate visits to understand which pages are read and how visitors move through the site. Where we do so, the measurement is limited to counts and broad categories such as region, device type and referring source. We prefer aggregate reporting, and we do not attempt to identify individual visitors from these figures.
If we ever introduce a tool that requires personal identification for analytics, we will update this policy and, where the law requires it, seek consent before that tool is activated.
10. Service Providers and Processors
We engage service providers for functions such as information technology, email hosting, document storage and accounting support. These providers act on our instructions and are permitted to handle personal information only for the purpose we have specified. We select providers with care and we seek contractual commitments that reflect our own standards of confidentiality and security.
If a provider has a security incident that affects information we have entrusted to it, we expect prompt notice and cooperation so that we can assess the impact and meet any notification duty that applies to us.
11. International Transfers
Our registry office is in Hong Kong, and the firm may work with advisers and service providers in other jurisdictions. Where personal information moves across a border, we take steps to ensure that it continues to receive protection consistent with this policy. Those steps may include contractual commitments, review of the provider, or reliance on an approved transfer mechanism.
If you would like more detail about how a specific transfer is protected, you may write to the desk and we will explain the arrangement that applies to your information.
12. How Long We Keep Information
We keep personal information only for as long as it is needed for the purpose for which it was collected, and for any additional period required by law. Enquiries that do not lead to a mandate are normally retained for a moderate period so that we can recognise a returning correspondent and meet record keeping duties, after which they are removed or anonymised.
Information connected to a completed mandate is retained for the period required for accounting, tax and professional records, and for a further period during which a claim or question could reasonably arise. When the retention period ends, the information is securely deleted or rendered unreadable.
13. How We Protect Information
We use a combination of organisational and technical measures to protect personal information. These include restricted access on a need to know basis, controlled credentials, secure storage for documents, and periodic review of the systems that carry client records. Our systems integration practice applies the same discipline to our own house as it does to the work we perform for clients.
No method of transmission or storage is entirely free of risk. We therefore work to reduce risk to a sensible level rather than claim that it has been eliminated, and we maintain procedures to respond quickly if an incident occurs.
14. Your Privacy Rights
Subject to the law that applies to you, you may have the right to request access to the personal information we hold about you, to ask us to correct information that is inaccurate, and to ask us to delete information that we no longer have a lawful reason to keep. You may also have the right to object to certain processing, to restrict it, or to ask for a portable copy of information you provided to us.
You may withdraw consent to marketing at any time. You may also ask us to stop sending material even where we rely on a different basis, and we will honour a reasonable request. We will explain any limitation that applies to a request so that you understand the position.
15. Making an Access Request
To make a request, write to marketing@phoenixinvest.mom or to the registry office at Room 1, G/F, 33 Bedford Road, Tai Kok Tsui, Hong Kong (HK). Please describe clearly what you are asking for so that we can locate the relevant information and respond usefully.
We may ask you to confirm your identity before we act, because we must not disclose personal information to someone who is not entitled to receive it. We aim to reply within a reasonable period, and we will tell you if the matter requires more time. Requests are handled at no charge in ordinary cases, though a reasonable fee may apply where a request is manifestly unfounded or excessive.
16. Privacy for Children
This website and our services are intended for adults and for representatives of organisations. We do not knowingly collect personal information from children. If you believe that a child has provided information to us, please contact the desk and we will take appropriate steps to remove it.
Where a matter lawfully involves a minor, we expect the information to be provided by a parent, guardian or authorised representative, and we handle it with heightened care.
17. Marketing Communications
We send occasional updates about syndication windows, research notes and registry news to people who have asked to receive them or with whom we have an existing professional relationship. Every message includes a simple way to opt out, and we act on opt out requests promptly.
If you prefer not to receive any marketing material, tell the desk and we will record your preference. We will continue to contact you where necessary to deliver a service you have engaged or to meet a legal duty.
18. Third Party Links
These pages may contain links to websites operated by others. We provide such links for convenience and reference. We do not control the privacy practices of those websites and we are not responsible for their content or their handling of personal information.
We encourage you to read the privacy notice of any website you visit, particularly before providing personal information to it.
19. Business Changes and Reorganisation
If the firm is reorganised, merged or transferred in whole or in part, personal information may be shared with the parties involved and with their advisers as part of that transaction. Where this occurs, we take steps to ensure that the information continues to be protected consistently with this policy, and we will update this notice where the law requires.
We do not otherwise transfer personal information to an unrelated party for that party to use for its own purposes without a lawful basis and appropriate notice.
20. Automated Decisions and Profiling
We do not use this website to make automated decisions that produce legal effects for you. Our advisory work is performed by people who consider the individual circumstances of each matter. Systems and dashboards that we build for clients present figures and flag exceptions, but a human being remains responsible for interpreting them and for deciding what to do.
If that position ever changes for a particular service, we will describe the change in this policy and explain the safeguards that apply.
21. Complaints and Disputes
If you are unhappy with how we have handled your personal information, please contact the desk first so that we have the opportunity to put the matter right. Provide as much detail as you can, including the serial of any related mandate, and we will investigate and reply.
If you remain dissatisfied, you may raise the matter with the privacy regulator that has jurisdiction over the firm. We cooperate with supervisory authorities and we will respond to a legitimate enquiry from one.
22. Changes to This Policy
We review this policy from time to time and we may update it to reflect changes in our practices, in our services or in the law. When we make a material change we will adjust the effective date at the top of this page and, where appropriate, provide additional notice.
The version published on this page is the current version. We encourage you to review it periodically so that you remain informed about how your information is protected.
23. How to Contact Us
Privacy questions and requests may be directed to the registry office. We welcome the opportunity to answer a question before it becomes a concern.
Registry Contact for Privacy Matters
Phoenix Investment Development Limited
Room 1, G/F, 33 Bedford Road, Tai Kok Tsui, Hong Kong (HK)
Email: marketing@phoenixinvest.mom
Telephone: +14325520593
Please mark privacy correspondence with the reference PRIV-2026-01 so that it reaches the correct file without delay.