Privacy Policy

1. Introduction

Folio Bay Limited ("Folio Bay", "we", "us", or "our") is committed to handling personal data responsibly. This Privacy Policy explains how we collect, use, store, and protect personal information in connection with our document drafting software services, website, and related engagements.

This Policy applies to individuals who access our website at foliobay.live, submit enquiry forms, or engage with Folio Bay in connection with our Solo Drafter Plan, Team Workspace Plan, or Custom Clause Library Setup engagement.

Folio Bay is incorporated in Hong Kong and operates under the Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"). We comply with the six Data Protection Principles established under the PDPO.

Questions about this Policy can be directed to [email protected].

2. Data We Collect

We collect personal data directly from you when you:

• Submit an enquiry or contact form on our website
• Request a product trial or walkthrough
• Enter into a service agreement with Folio Bay
• Participate in onboarding sessions or content sessions (Clause Library Setup)
• Contact us by phone or email

The types of personal data we may collect include:

• Full name
• Email address
• Phone number (if provided)
• Job title and organisation name
• Correspondence and communication records
• Technical data (browser type, IP address, page visits) collected via cookies and analytics tools

We do not collect sensitive personal data as defined under the PDPO.

3. How We Use Your Data

Personal data collected is used for the following purposes:

• Responding to enquiries and providing information about our services
• Setting up and administering service accounts and workspace access
• Delivering onboarding sessions, walkthroughs, and clause library setup engagements
• Scheduling quarterly check-ins for Team Workspace Plan subscribers
• Sending service-related communications, including updates to terms or policies
• Improving the website and product experience through aggregated analytics
• Meeting legal or regulatory obligations applicable in Hong Kong

We do not sell personal data to third parties. We do not use personal data for automated decision-making or profiling.

4. Legal Basis for Processing

Under the PDPO, we process personal data on the following bases:

• Contract performance: To deliver services you have requested or entered into a service agreement for.
• Legitimate interests: To respond to enquiries, improve our services, and maintain our business operations.
• Consent: Where you have provided explicit consent, such as for optional communications.
• Legal obligation: Where processing is required to comply with applicable law in Hong Kong.

5. Data Retention

We retain personal data for as long as necessary for the purposes described in this Policy, or as required by applicable law. General retention periods:

• Enquiry and contact form submissions: up to 24 months from the date of submission
• Active service accounts: for the duration of the service agreement plus 12 months after termination
• Financial and contractual records: 7 years as required under Hong Kong law
• Website analytics data: aggregated and anonymised after 14 months

When data is no longer required, it is deleted or anonymised securely.

6. Data Security

Folio Bay implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption of data at rest and in transit (TLS)
• Role-based access controls limiting internal access to personal data
• Regular review of access permissions
• Breach detection and notification procedures

In the event of a data breach that poses a real risk of significant harm, we will notify affected individuals and the Office of the Privacy Commissioner for Personal Data (PCPD) in Hong Kong as required.

7. Cookies

Our website uses cookies to support basic site functionality and to understand how visitors navigate the site. We use:

• Essential cookies: Required for the site to function. Cannot be disabled.
• Analytics cookies: Collect aggregated, anonymised data on page visits and user navigation. Optional.

For full details on cookies we use and how to manage your preferences, see our Cookie Policy.

8. Third Parties

We may share personal data with third parties in limited circumstances:

• Service providers who assist with hosting, analytics, or communication tools — subject to data processing agreements
• Professional advisers (legal, accounting) where required
• Regulatory authorities where required by law

We do not share personal data with advertising networks or marketing platforms. Our website does not serve third-party advertising.

Where data is transferred outside Hong Kong, we apply appropriate safeguards in accordance with the PDPO.

9. Your Rights

Under the PDPO, you have the following rights in relation to your personal data:

• Right of access: To request a copy of the personal data we hold about you.
• Right of correction: To request correction of inaccurate or incomplete personal data.
• Right to object: To object to the use of your personal data for direct marketing purposes.
• Right to withdraw consent: Where processing is based on consent, to withdraw it at any time without affecting prior processing.

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days as required under the PDPO.

If you are not satisfied with our response, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong.

10. Third-Party Links

Our website may contain links to external websites or services. Folio Bay is not responsible for the privacy practices of those sites. We recommend reviewing the privacy policies of any third-party sites you visit.

11. Children's Privacy

Folio Bay's services are intended for professional use by individuals aged 18 and over. We do not knowingly collect personal data from minors. If we become aware that personal data has been collected from a person under 18, we will delete it promptly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated by posting the updated Policy on our website with a revised "Last Updated" date. Continued use of our services after any changes constitutes acceptance of the updated Policy.

13. Contact

For privacy-related enquiries, corrections, or access requests, contact: