Privacy Policy
FLIPS Digital Media Limited ("Flips", "we", "us") operates flipsdigital.com. This policy explains what personal data we collect through this website, why we collect it, who we share it with, and what you can do about it.
We are the data user responsible for the personal data collected through this site, and we handle it in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
The short version
We collect two things: what you type into our enquiry form, and — only if you agree — anonymous statistics about how the site is used. We do not sell your data, and if you never contact us and decline analytics, we keep nothing about you.
What we collect
When you send us an enquiry
Our enquiry form asks for:
- Name (required)
- Email address (required)
- Contact number (required)
- Company name (optional)
- Your message (required)
You choose everything in that list. We do not add anything to it — in particular we do not record the IP address a submission came from.
Providing this data is voluntary, but we cannot reply to an enquiry without at least a name and a way to contact you.
When you agree to analytics
If you accept analytics in the banner shown on your first visit, we load Google Tag Manager and Google Analytics, which collect information about how the site is used: pages viewed, approximate location derived from IP address, device and browser type, and how you arrived at the site.
Nothing is loaded and no measurement request is made until you accept. If you decline, or simply never answer, no analytics code runs at all.
You can change your mind at any time — see Your choices below.
When you use the enquiry form
To keep the form from being abused we use Google reCAPTCHA. It loads only once you start filling the form in — not on pages you are simply reading — and Google receives interaction and device data at that point in order to tell a person from a bot.
Automatically, to serve the site
Like any website, our servers and our content delivery provider process the technical information a browser must send to receive a page: IP address, the page requested, the time, and browser identification. This is used to deliver the site and keep it secure, and it is not combined with anything else or used to identify you.
We also apply a temporary rate limit to the enquiry form — no more than five submissions from the same network in ten minutes — to prevent automated abuse. This checks the IP address in memory at the moment of submission and does not store it.
Cookies and local storage
If you decline analytics, or never answer, no cookies are set at all.
If you accept, Google sets analytics cookies.
If you make a choice in the analytics banner, we record that choice in your browser's local storage under the name flips.consent, so we do not ask again on every page. It holds only whether you accepted and which version of the notice you answered. It stays on your device, is never sent to us, and clearing your browser data removes it — which will cause the banner to ask again.
Google's cookies are described in Google's own privacy policy, linked below.
Our website editors use a session cookie when signed in to our content management system. That never applies to visitors.
Who we share it with
We do not sell personal data, and we do not share it for anyone else's marketing.
We use these service providers, who process data on our behalf:
- Amazon Web Services — hosts the website, its database and its files. It holds everything you submit, and its request logs.
- Cloudflare — delivers and secures the site. It sees request data, including your IP address.
- Google (reCAPTCHA) — confirms the enquiry form is not being submitted by a bot. It sees interaction and device data, and is loaded only when you start filling in the form — not on pages you merely read.
- Google (Tag Manager and Analytics) — website statistics. Only if you accept analytics, and never otherwise.
- Amazon SES — delivers enquiry notifications to us, so it handles the contents of your enquiry.
We may also disclose personal data where we are required to by law, or to establish or defend a legal claim.
Where your data is held
Our website, database and file storage are hosted on Amazon Web Services in the United States, and Cloudflare serves the site from data centres worldwide. This means personal data you submit is transferred outside Hong Kong and stored in a jurisdiction whose data protection laws differ from Hong Kong's.
We use these providers under their standard data processing terms, which require them to protect the data and to process it only on our instructions.
How long we keep it
We keep enquiry submissions for 3 months after our last correspondence with you, after which they are deleted.
Analytics data is retained 14 months on our Google Analytics account.
What we use it for
- To answer your enquiry and to correspond with you about it
- To understand how the site is used, so we can improve it (only with consent)
- To keep the site available and to prevent abuse of the form
We do not use enquiry details for marketing, and we will not add you to a mailing list.
Your choices
Analytics. Decline in the banner and no analytics run at all. To change your mind later — in either direction — use the Cookie choices link in the footer of any page. Withdrawing stops collection immediately and deletes the analytics cookies already in your browser, so nothing links a later visit back to an earlier one.
Browser controls. Your browser can block or delete cookies and local storage, and most offer a "Do Not Track" setting.
Your rights
Under the Personal Data (Privacy) Ordinance you have the right to:
- ask whether we hold personal data about you, and to be given a copy of it
- ask us to correct personal data that is inaccurate
- ask us to stop using your data for direct marketing
Write to us using the details below. We will respond within 40 days, as the Ordinance requires. We may charge a reasonable fee for complying with a data access request, as the Ordinance permits.
If you are not satisfied with our response, you can complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong.
Security
We serve the whole site over an encrypted connection, restrict access to enquiry submissions to the Flips staff who need it, and hold our database on a private network that is not reachable from the internet. No system is perfectly secure, but we take these measures seriously.
Other sites we link to
Our portfolio links to websites we have built for clients. Those sites are operated by those clients under their own privacy policies, and this policy does not apply once you leave flipsdigital.com.
Children
This site is aimed at businesses and is not directed at children. We do not knowingly collect personal data from children.
Changes
We may update this policy. The date at the top shows when it last changed, and any material change to what we measure will cause the analytics banner to ask you again.
Contact us
FLIPS Digital Media Limited 1015 Seapower Tower, Concordia Plaza, Tsim Sha Tsui East, Hong Kong Email: info@flipsdigital.com Tel: +852 2311 3683 Fax: (852) 3157 1367