Privacy Policy

This policy, sets out the basis on which Kossie Limited, a company incorporated under the laws of Hong Kong with its registered office address Room 708, 7/Floor, Stag Building, 148-150 Queen's Road Central, Hong Kong (Business Registration Number 70546347), collects, processes, stores, and protects personal data in compliance with the Hong Kong Personal Data (Privacy) Ordinance (“PDPO”) and the European Union General Data Protection Regulation (“GDPR”).

Any reference to “we”, “us”, “our” shall represent Kossie Limited together with any of its subsidiaries, its holding company, and fellow subsidiaries of its holding company (“Kossie”).

Any reference to “you” or “your” shall represent a “User” who visit our website(https://kossie.co.uk/ , https://www.kossie.com/, our “Site”) or using our website application (our “Web App”), which are collectively refers to our “Platform”. You accept and consent to the practices set out below.

  • 1. COLLECTION OF PERSONAL DATA

  • 1.1 Types of Data Collected

  • For the purposes outlined in Clause 2, we may collect and process the following personal data about you:

    • (a) Information you provide - personal data that you voluntarily submit, such as your name, address, email address, telephone number, credit card information or other personal details, when:

      • (i) registering or signing up via forms on our Platform or through third-party accounts (e.g., Facebook, Google);

      • (ii) contacting us via phone, mail, or other means in reporting issues, requesting support or completing any surveys or questionnaires.

    • (b) Information automatically collected - information automatically collected when you interact with our Platform, including:

      • (i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

      • (ii) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.

    • (c) Information we receive from third parties - We work with third parties and we may receive information about you from them, such as business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies.

  • 1.2 Data Retention

  • We retain personal data only for so long as necessary to fulfill the purposes for which it was collected, including legal or regulatory obligations. Data may be archived if the purpose for its use persists, in accordance with PDPO and GDPR requirements.

  • 2. PURPOSES OF DATA PROCESSING

  • We process your personal data for the following lawful purposes:

    • (a) providing, improving and developing our services;

    • (b) enhancing our AI models for model training and development (where permitted and anonymized where required);

    • (c) researching, designing and launching new features or products;

    • (d) optimizing content presentation on our Platform for your device;

    • (e) sending alerts, updates, or requested information about our services;

    • (f) managing payment collection and overdue amounts;

    • (g) complying with applicable laws and regulations in Hong Kong, the Eu, and other jurisdictions;

    • (h) participating in legal proceedings, or seeking professional advice;

    • (i) responding to your inquiries or requests; and

    • (j) other purposes directly related or incidental to the above.

  • Processing is based on lawful grounds under GDPR (e.g., consent, contractual necessity, legitimate interests, or legal obligations) and PDPO principles.

  • 3. DISCLOSURE OF PERSONAL DATA

  • 3.1 We treat your personal data as confidential but may disclose it to:

    • (a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries;

    • (b) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services), bound by confidentiality obligations;

    • (c) our overseas offices, affiliates, business partners and counterparts on a need-to-know basis, in compliance with PDPO and GDPR;

    • (d) parties under confidentiality agreements with us;

    • (e) entities as required by law or regulation in any jurisdiction; or

    • (f) actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world, subject to data protection safeguards.

  • 3.2 Corporate Program

    • The Corporations that contract with us to provide services to their Employees or others on our site or use our Web App are referred to as Employers. The Employees who use our services through invitations by their Employers are referred to as Employees.

    • The personal information of the Employees, including the guidance service, is kept confidential and encrypted in transit, and is not shared with their Employers. The Employers will only receive the following information:

    • (a) the numbers of Employees who have registered on our platform for the service;

    • (b) the numbers of guidance their Employees received from the Coaches;

    • (c) the area of the received guidance service; and

    • (d) the emails of Employees who have submitted the guidance requests.

    • Should the Employees express thoughts of self-harm, harm to others, or exhibit signs of psychosis, our Coaches will take these concerns seriously and not accept such requests, and report back to Kossie. The Employees are advised to CALL THE EMERGENCY SERVICE NUMBER AND NOTIFY THE RELEVANT AUTHORITIES, AND SEEK IMMEDIATE IN-PERSON ASSISTANCE. The platform is not designed for use in any of the aforementioned cases. The Employer will be immediately notified of any and all potentially harmful states their Employees in compliance with legal and ethical obligations.

  • 4. COOKIES AND TRACKING TECHNOLOGIES

  • 4.1 Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

  • 4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.

  • 4.3 We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

  • 4.4 We use the following cookies:

    • (a) Strictly necessary cookies - These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

    • (b) Analytical/performance cookies - They allow us to recognize and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

    • (c) Functionality cookies - These are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by your name and remember your preferences (for example, your choice of language or region).

    • (d) Targeting cookies - These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.

  • 4.5 You may refuse cookies via your browser but this may limit your access to parts of our Platform.

  • 4.6 We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network, subject to PDPO and GDPR compliance.

  • 5. THIRD-PARTY LINKS

  • Our Site, our Web App or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.

  • For translation services between English and both Traditional and Simplified Chinese, we implement Writesonic Inc. ('Writesonic'). To learn more about Writesonic's commitment to data security and privacy, please refer to their Privacy Policy https://writesonic.com/privacy-policy and Security Statement https://writesonic.com/legal/security.

  • 6. DATA SECURITY

  • 6.1 All text /live messages you provide to us are encrypted in transit.

  • 6.2 Any payment transactions will be encrypted using TLS/SSL technology.

  • 6.3 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

  • 6.4 We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.

  • 6.5 We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

  • 6.6 Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

  • 7. CROSS BORDER DATA TRANSFERS

  • 7.1 The personal data that we collect from you may be transferred to and stored in Singapore and the United States, outside Hong Kong, where our secure servers are located. All such transfers comply with PDPO and GDPR requirements including adequate safeguards and data processed securely and in accordance with this policy

  • 7.2 By submitting your personal data you agree to this transfer, storing or processing of data in Singapore and the United States, outside Hong Kong. subject to applicable protections.

  • 8. YOUR RIGHTS

  • 8.1 You have the right to:

    • (a) request confirmation whether we hold your personal data;

    • (b) access any personal data we hold about you;

    • (c) require us to rectify any inaccuracy or error in any personal data we hold about you;

    • (d) request deletion of your data and initiate the account closure (subject to legal exemptions);

    • (e) restrict processing in certain cases;

    • (f) obtain your data in a structured, machine-readable format;

    • (g) object to processing based on legitimate interests or for direct marketing; and

    • (h) withdraw consent where processing is consent-based.

  • 8.2 Any request under Clause 8.1 may contact us at info@kossie.co.uk and may incur an administrative fee to cover our processing cost, where permitted. We will respond within one month (GDPR) or as required by PDPO.

  • 9. CHANGES TO OUR PRIVACY POLICY

  • We may update this policy from time to time by posting the updated policy on our Platform. By continuing to use our Platform after the changes indicates your acceptance of the revised policy. We will notify you of significant changes required by law.

  • 10. GOVERNING LAW

  • These terms are governed by and shall be construed in accordance with the laws of the Hong Kong Special Administrative Region and complies with Hong Kong’s Personal Data Privacy Ordinance (“PDPO”) and the European Union General Data Protection Regulation (“GDPR”) requirements.

  • 11. CONTACT US

  • For questions, comments or requests regarding your personal data, please contact:

    • Email: info@kossie.co.uk
    • Address: Room 708, 7/Floor, Stag Building, 148-150 Queen’s Road Central, Hong Kong
    • Data Protection Officer: available for GDPR-related inquiries at jennifer@kossie.co.uk

Last updated: 7 October 2025

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