PRIVACY POLICY

Last Updated: 15 October 2025
Issued by: Revolt Group Asia Limited

1. General Provisions
1.1. This Privacy Policy (“Policy”) is developed in accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (the “Ordinance”) and the Data Protection Principles (“DPP1–DPP6”) to ensure the protection of the rights and freedoms of individuals in the processing of their personal data, including the right to privacy and confidentiality.
1.2. This Policy applies to all personal data collected and processed by Revolt Group Asia Limited, its subsidiaries, affiliates, or other entities under common control (collectively, the “Company” or “Operator”).
1.3. The Policy governs all relationships related to personal data processing that have arisen both before and after its approval.
1.4. The Policy is publicly available on the Company’s official websites (including subdomains): https://revolt-group.com/, https://revolt-group.com/offer_eng, https://revolt-group.com/offer_ru, https://revolt-group.com/dolevie_eng, https://revolt-group.com/dolevie_ru.
1.5. Key Terms:

А. Personal Data means any data relating directly or indirectly to a living individual from which it is practicable to ascertain the identity of the individual, and which is in a form in which access or processing is practicable.
В. Data User (Operator) means a person who, either alone or jointly with others, controls the collection, holding, processing, or use of personal data.
С. Processing includes collection, recording, storage, adaptation, alteration, retrieval, consultation, use, disclosure, alignment, combination, erasure, or destruction of data.
D. Data Subject means any identified or identifiable individual whose personal data are collected or processed by the Company.

1.6. The Company ensures compliance with the Ordinance and is committed to lawful, fair, and transparent processing of personal data.

2. Purposes of Personal Data Processing
2.1. The Company processes personal data only for legitimate and clearly defined business purposes, including but not limited to:
entering into and performing contracts with clients, partners, and suppliers;
providing access to the Company’s professional services, information, and marketing materials;
fulfilling legal and regulatory obligations;
communicating with clients, partners, and contractors;
maintaining business operations, accounting, and audit compliance;
ensuring website functionality and improving user experience (through cookies, analytics tools, etc.);
providing information on new services, offers, and corporate updates (subject to the user’s consent).
2.2. The Company’s business activity consists of providing professional marketing, consultancy, and communication services for the real estate sector, including strategic marketing, branding, research, and transactional communications support.
2.3. Personal data are processed only to the extent necessary for the fulfilment of these purposes and retained no longer than required.

3. Legal Grounds for Processing
3.1. The legal grounds for personal data processing include:
the Personal Data (Privacy) Ordinance (Cap. 486);
contractual obligations between the Company and the data subject;
the legitimate interests of the Company, where such interests are not overridden by the rights of the data subject;
the consent of the data subject.
3.2. Consent may be withdrawn by the data subject at any time by contacting the Company’s Data Protection Officer (DPO).

4. Scope and Categories of Personal Data
4.1. The Company may collect and process the following categories of personal data:
full name, date and place of birth;
contact details (email, phone, postal address);
identification or passport details (where required for compliance or contracting);
taxpayer or business registration number (where applicable);
payment and banking details;
communication records and correspondence;
any other information voluntarily provided by the client in the course of cooperation.
4.2. The Company does not process special categories of personal data (e.g., health, political opinions, or religious beliefs) unless required by law.
4.3. The Company does not process biometric data.

5. Data Processing, Storage, and Protection
5.1. Personal data are processed by authorised Company personnel or approved contractors who act under strict confidentiality and data security obligations.
5.2. The Company implements appropriate technical and organisational measures to prevent unauthorised or accidental access, loss, alteration, or disclosure of personal data, including:
encryption and secure data transmission (SSL/TLS);
access control and role-based permissions;
data backup and secure storage;
regular review of third-party service providers’ compliance.
5.3. Personal data are stored only as long as necessary for the purposes outlined in this Policy or as required by law.
5.4. Personal data may be transferred to service providers, business partners, or advisers within or outside Hong Kong, subject to compliance with the Ordinance and the same level of protection.
5.5. The Company ensures that all third parties processing data on its behalf adhere to equivalent standards of privacy and security.

6. Rights of Data Subjects and Procedures
6.1. Data subjects have the right to:
request access to their personal data held by the Company;
request correction or deletion of inaccurate data;
withdraw consent for data processing;
object to processing for direct marketing purposes;
lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD).
6.2. Requests must be submitted in writing to the Company’s DPO, providing sufficient information to verify identity.
6.3. The Company will respond to data access or correction requests within 40 days as required under the Ordinance.
6.4. Any refusal to comply will be communicated in writing with a reasoned explanation.

7. Contact Details of Data Protection Officer

Data Protection Officer (DPO)
Revolt Group Asia Limited (Hong Kong SAR)
Registered Office: Room 10, Unit A, 7/F, Harbour Sky, 28 Sze Shan Street, Yau Tong, Hong Kong
Email: dpo@revolt-group.com
Website: https://revolt-group.com