1. Acceptance of Terms

By accessing or using the HKPC CRM System ("the Service"), operated by Hong Kong Professional Company Secretarial Services ("HKPC", "we", "us", or "our"), you agree to be bound by these Terms of Service ("Terms"). If you do not agree, you must not use the Service.

If you are using the Service on behalf of a company or other legal entity, you represent that you have the authority to bind that entity to these Terms.

These Terms are available in both English and Traditional Chinese. In the event of any inconsistency between the two versions, the English version shall prevail.

2. Description of Service

The Service is a web-based client relationship management platform designed for company secretarial service providers and their clients. Features include document storage and management, KYC (Know Your Customer) compliance document upload, company record keeping, deadline tracking, and related administrative tools.

HKPC reserves the right to modify, suspend, or discontinue any aspect of the Service. In the event of a permanent discontinuation of the Service, HKPC will provide at least thirty (30) days' prior written notice and will make User Content available for export during that period.

3. User Accounts & Security

3.1 Registration. You must provide accurate and complete information when creating an account. You are responsible for maintaining the confidentiality of your login credentials.

3.2 Account Security. You are solely responsible for all activities that occur under your account. You agree to notify us immediately of any unauthorized use of your account or any other breach of security. HKPC will not be liable for any loss or damage arising from your failure to protect your login credentials.

3.3 Unauthorized Access. We implement reasonable technical and organizational security measures to protect your account and data. However, no method of electronic storage or transmission over the Internet is 100% secure. We cannot guarantee absolute security.

4. Data & Document Uploads

4.1 User Content. You retain ownership of all documents, files, and data ("User Content") you upload to the Service. By uploading User Content, you grant HKPC a limited, non-exclusive license to store, process, and display your User Content solely for the purpose of providing the Service to you.

4.2 Sensitive Data. The Service is designed to handle sensitive personal data including but not limited to identity documents, passport copies, address proofs, and company incorporation documents. You represent that you have obtained all necessary consents from data subjects before uploading their personal data to the Service. This obligation does not relieve HKPC of its own independent obligations under the Personal Data (Privacy) Ordinance.

4.3 Prohibited Content. You may not upload any content that is illegal, infringes third-party rights, contains malware, or violates any applicable law.

4.4 Data Retention. We retain your User Content for as long as your account is active or as needed to provide the Service. Specific retention periods by data category, deletion and anonymisation procedures, and statutory retention exceptions are set out in our Data Retention Policy available at Privacy Policy. Upon account termination, User Content will be made available for export for thirty (30) days, after which it will be deleted or anonymised in accordance with the Data Retention Policy, except where retention is required or permitted by law.

5. Privacy & Data Protection

5.1 Personal Data (Privacy) Ordinance. HKPC is committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO"). Our collection, processing, and storage of personal data is governed by our Privacy Policy and Personal Information Collection Statement, which form part of these Terms by reference.

5.2 Data Protection Principles. In particular: (a) under DPP4 (Data Security), we take all practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use, having regard to the nature of the data, the potential harm from a breach, and the measures available; (b) under DPP2 (Retention), personal data is not kept longer than necessary for the fulfilment of the purpose for which it is used; (c) under DPP3 (Use), personal data is used only for the purposes for which it was collected, unless with the data subject's express and voluntary consent; and (d) under DPP1 (Collection), personal data is collected by lawful and fair means, for a lawful purpose directly related to our functions, and the data subject is informed of the purpose, transferee classes, and access/correction rights on or before collection.

5.3 Data Access & Correction. You have the right to request access to and correction of your personal data held by us. Such requests should be directed to our Data Protection Officer at the contact address provided in Section 15. A reasonable fee may be charged for processing access requests.

5.4 Third-Party Disclosure. We do not sell, trade, or otherwise transfer your personal data to third parties except: (a) as required by law or regulatory obligation; (b) to service providers who process data on our behalf (including IT, hosting, and email delivery providers), subject to contractual confidentiality and security obligations; or (c) with your explicit consent. Categories of such service providers and their roles are further described in our Privacy Policy.

5.5 Cross-Border Data Processing. Personal data is primarily stored on servers located in Hong Kong. Backup copies and certain processing operations may involve service providers located in other jurisdictions. Where HKPC engages a service provider outside Hong Kong to process personal data on its behalf, HKPC will take contractual or other practicable measures to ensure that the service provider processes the data only on HKPC's instructions, keeps it confidential, implements appropriate security measures, and does not retain it longer than necessary. Further details are set out in our Privacy Policy.

6. Limitation of Liability

6.1 General. This section sets out our entire liability to you under these Terms. Nothing in these Terms shall exclude or limit our liability: (a) for death or personal injury caused by our negligence; (b) for fraud or fraudulent misrepresentation; (c) for gross negligence or wilful misconduct; or (d) to the extent such exclusion or limitation is prohibited by applicable law, including the Control of Exemption Clauses Ordinance (Cap. 71) of Hong Kong.

6.2 Disclaimer of Warranties. THE SERVICE IS PROVIDED ON AN "AS IS" AND "AS AVAILABLE" BASIS WITHOUT WARRANTIES OF ANY KIND, EITHER EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT. We do not warrant that the Service will be uninterrupted, timely, secure, or error-free.

6.3 Limitation of Damages. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, AND SUBJECT TO SECTION 6.1 AND APPLICABLE REASONABLENESS REQUIREMENTS, HKPC SHALL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF PROFITS, DATA, USE, OR GOODWILL, RESULTING FROM: (a) YOUR USE OR INABILITY TO USE THE SERVICE; (b) ANY CONDUCT OR CONTENT OF ANY THIRD PARTY ON THE SERVICE; OR (c) ANY DATA BREACH OR SECURITY INCIDENT OCCURRING DESPITE HKPC'S COMPLIANCE WITH THE DATA SECURITY OBLIGATIONS UNDER THE PDPO. NOTHING IN THIS SECTION 6.3 EXCLUDES OR LIMITS LIABILITY FOR DIRECT DAMAGES CAUSED BY HKPC'S BREACH OF CONTRACT, NEGLIGENCE, OR BREACH OF STATUTORY DUTY.

6.4 Liability Cap. SUBJECT TO SECTION 6.1, HKPC'S TOTAL AGGREGATE LIABILITY TO YOU FOR ALL CLAIMS ARISING OUT OF OR RELATING TO THESE TERMS OR THE SERVICE (WHETHER IN CONTRACT, TORT, NEGLIGENCE, OR OTHERWISE) SHALL NOT EXCEED THE GREATER OF: (a) THE TOTAL FEES PAID BY YOU TO HKPC IN THE TWELVE (12) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM; OR (b) HKD 10,000. THE EXISTENCE OF MORE THAN ONE CLAIM SHALL NOT ENLARGE THIS LIMIT.

6.5 Data Breach & Security Incidents. HKPC undertakes to implement and maintain security measures appropriate to the sensitivity of the data processed, including access controls, encryption of data in transit, network firewalls, and regular security reviews. In the event of a data breach, HKPC will: (i) promptly notify affected users upon becoming aware of the breach; (ii) take immediate remedial action to contain and mitigate the breach; and (iii) cooperate with any investigation by the Privacy Commissioner for Personal Data. Where a data breach occurs due to: (a) a sophisticated cyberattack; (b) a security vulnerability in third-party infrastructure beyond our reasonable control; (c) an act of any government or regulatory authority; or (d) force majeure events, HKPC's liability shall be limited in accordance with Sections 6.3 and 6.4 above.

6.6 User's Duty to Mitigate. You agree to take reasonable steps to mitigate any loss or damage you may suffer arising out of your use of the Service, including maintaining independent backups of your User Content and promptly changing passwords upon suspicion of compromise. Nothing in this section reduces HKPC's obligations under applicable law or these Terms.

7. User Obligations & Acceptable Use

You agree not to: (a) use the Service for any unlawful purpose; (b) upload or transmit viruses, malware, or malicious code; (c) attempt to gain unauthorized access to any part of the Service, other accounts, or computer systems; (d) interfere with or disrupt the Service or servers; (e) reverse engineer, decompile, or disassemble any part of the Service; (f) use the Service to infringe the intellectual property or privacy rights of others; or (g) engage in any activity that imposes an unreasonable or disproportionately large load on our infrastructure.

8. Intellectual Property

The Service and its original content (excluding User Content), features, and functionality are and will remain the exclusive property of HKPC and its licensors. The Service is protected by copyright, trademark, and other laws.

9. Indemnification

You agree to indemnify, defend, and hold harmless HKPC, its directors, officers, employees, and agents from and against any third-party claims, losses, and reasonable legal costs arising directly from: (a) your material breach of these Terms; (b) your unlawful use of the Service; or (c) your User Content that infringes a third party's intellectual property or privacy rights. This indemnity does not apply to the extent that a claim arises from HKPC's negligence, wilful misconduct, breach of these Terms, or breach of applicable law.

10. Third-Party Services

The Service may integrate with or link to third-party services (including but not limited to email delivery services and hosting infrastructure). HKPC does not control and is not responsible for the content, privacy policies, or practices of any third-party services.

10.1 Hosting & Third-Party Infrastructure. The Service is hosted on third-party shared hosting infrastructure. Under DPP4 of the PDPO, HKPC is required to ensure, by contractual or other means, that any data processor (including hosting providers) implements appropriate security measures. HKPC has taken such contractual steps with its hosting provider. HKPC remains responsible for its selection, supervision, and contractual control of its data processors, and for its own incident response obligations.

11. Termination

11.1 Termination for Breach. HKPC may terminate or suspend your account immediately, without prior notice, if you materially breach these Terms. Where practicable, HKPC will provide notice and a reasonable opportunity to cure the breach before termination, except where immediate action is reasonably necessary to protect the Service, comply with law, or address a security risk.

11.2 Termination for Convenience. Either party may terminate for any reason upon thirty (30) days' written notice to the other party.

11.3 Data Export on Termination. Following termination, HKPC will make your User Content available for export for thirty (30) days. Thereafter, User Content will be deleted or anonymised in accordance with the Data Retention Policy, except where retention is required or permitted by law.

11.4 Survival. All provisions of these Terms which by their nature should survive termination shall survive, including ownership provisions, warranty disclaimers, indemnity, and limitations of liability.

12. Governing Law & Dispute Resolution

These Terms shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China ("Hong Kong"), without regard to its conflict of law provisions.

Any dispute arising out of or in connection with these Terms shall first be attempted to be resolved through good-faith negotiations between the parties. If the dispute cannot be resolved within thirty (30) days, either party may submit the dispute to the exclusive jurisdiction of the courts of Hong Kong.

13. Changes to Terms

HKPC may modify these Terms from time to time. For minor or administrative changes, updated Terms will be posted on the Service and your continued use constitutes acceptance. For material changes that adversely affect your rights or obligations, HKPC will provide at least thirty (30) days' prior notice by email and through the Service. If you do not agree to a material change, you may terminate the Service before the effective date without penalty.

14. Miscellaneous

14.1 Severability. If any provision of these Terms is held to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect. The invalid or unenforceable provision shall be deemed modified to the minimum extent necessary to make it valid and enforceable, or severed if modification is not possible.

14.2 Waiver. Our failure to enforce any right or provision of these Terms shall not be deemed a waiver of such right or provision.

14.3 Entire Agreement. These Terms, together with the Privacy Policy and any applicable service-specific terms, constitute the entire agreement between you and HKPC regarding the Service.

14.4 Assignment. You may not assign or transfer these Terms without our prior written consent. HKPC may assign or transfer these Terms in connection with a merger, acquisition, or sale of all or substantially all of its assets, provided that the assignee agrees to be bound by these Terms and to maintain equivalent data protection obligations. HKPC will notify you of any such assignment in accordance with our Privacy Policy.

15. Contact Information

For questions about these Terms, the Service, or to exercise your data access and correction rights, please contact us at: