This Privacy Policy describes Our policies and procedures on the collection, use, and disclosure of Your information when You use the Service, and informs You of Your privacy rights under applicable data protection laws, including the European Union / United Kingdom General Data Protection Regulation (GDPR), the ePrivacy Directive, the California Consumer Privacy Act as amended by the California Privacy Rights Act (CCPA/CPRA), and the California Online Privacy Protection Act (CalOPPA).
1. Interpretation and Definitions
Interpretation
Words with initial capitalization have defined meanings under the following conditions. The following definitions apply regardless of whether they appear in singular or plural.
Definitions
· Account: A unique account created for You to access Our Service or parts of Our Service.
· Company (referred to as "the Company", "We", "Us", or "Our"): Refers to [Pacific Gateway Finance Ltd — full registered legal name], a company registered in [jurisdiction of incorporation] under company number [registration number], with its registered office at [full registered address].
· Cookies: Small files placed on Your computer or mobile device by a website containing details of Your browsing history.
· Data Controller: For the purpose of the GDPR, refers to the Company as the legal entity that determines the purposes and means of processing Personal Data.
· Device: Any device that can access the Service, such as a computer, cell phone, or tablet.
· Personal Data (or Personal Information): Any information that relates to an identified or identifiable individual.
· Service: Refers to the Website hosted on Google Sites.
· Service Provider: Any natural or legal person processing data on behalf of the Company (e.g., payment processors, analytics providers, hosting infrastructure).
· Usage Data: Data collected automatically through the use of the Service or its infrastructure.
· Website: Refers to Pacific Gateway Finance Ltd, accessible from www.pacificgateway.org.
2. Data Controller Details and Representatives
Data Controller
The data controller responsible for your Personal Data is:
· Legal name: [Pacific Gateway Finance Ltd]
· Contact address: [PO Box 1144, Yuen Long Delivery Office, Yuen Long, Hong Kong]
· Company registration number: [58881779]
· Contact email: info@pacificgateway.org
· Data Protection Officer: DPO can be connected at info@pacificgateway.org
Representatives in the European Union and United Kingdom
If Pacific Gateway Finance Ltd does not have an establishment in the European Economic Area (EEA) or the United Kingdom, but offers goods or services to, or monitors the behaviour of, individuals in the EEA or UK, Article 27 GDPR (and the equivalent UK GDPR provision) requires the appointment of a representative in those territories.
· EU & UK Representative: DPO can be connected at info@delightable.eu
You may contact our EU or UK Representative directly on all issues related to the processing of your Personal Data, in addition to contacting the Company. (If Pacific Gateway Finance Ltd qualifies for the Article 27(2) exemption — processing is occasional, does not involve large-scale special category data, and is unlikely to result in a risk to data subjects — this section should instead confirm the exemption applies and explain why.)
3. Website Infrastructure & Hosting
Our Website is created and hosted using Google Sites (provided by Google LLC). Certain technical data, server logs, and essential cookies are processed through Google's cloud infrastructure to deliver, secure, and maintain the functionality of our website.
4. Types of Data Collected
Personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information, including:
· First name and last name
· Email address
· Phone number
· Billing and delivery address (Address, State, Province, ZIP/Postal code, City)
· Payment details (e.g., credit card information, bank transfer details)
Usage Data
Usage Data is collected automatically when using the Service. This may include Your Device's IP address, browser type and version, pages visited, time spent on those pages, unique device identifiers, and diagnostic data.
5. Specific Technologies & Third-Party Services
Google Analytics
We use Google Analytics to monitor and analyze web traffic and user behavior. Google Analytics uses cookies to collect standard internet log information and visitor behavior in an anonymous form. IP anonymization is enabled on our Google Analytics setup to protect user privacy under EU guidelines. Google Analytics cookies are only activated after you provide consent through our cookie consent banner (see Section 8). You can opt out of Google Analytics tracking by installing the Google Analytics Opt-out Browser Add-on.
Google Invisible reCAPTCHA
We use Google Invisible reCAPTCHA on our forms to protect against spam and automated abuse. Invisible reCAPTCHA analyzes hardware and software information (such as IP address and user behavior) to distinguish humans from bots. Because reCAPTCHA cookies are not considered strictly necessary under current EU regulatory guidance, the reCAPTCHA script does not load, and no reCAPTCHA cookies are set, until you have consented to the "Security/Anti-Spam" cookie category in our cookie consent banner. Usage of reCAPTCHA is subject to the Google Privacy Policy and Terms of Service.
Google Places
We use Google Places API to provide location search and address auto-complete features. Google Places may collect device and location information for functional and security purposes. This is treated as a functional cookie/technology category under our cookie consent banner.
Online Advertising & Remarketing
We display advertisements and use remarketing services (such as Google Ads Remarketing and Meta Pixel) to advertise our business on third-party websites after you visit our Website. These third-party vendors use cookies, web beacons, and tracking technologies to serve ads based on your past visits. These technologies are only activated after you consent to the "Advertising" cookie category in our cookie consent banner. You can opt out of interest-based advertising by visiting the Network Advertising Initiative Opt-Out Page or the Digital Advertising Alliance Opt-Out Page.
Payment Processing
We offer paid products and/or services on our Website. We use third-party payment processors (e.g., Stripe, PayPal, or bank gateways) for payment handling. We do not store or collect your payment card details directly. That information is provided directly to our third-party payment processors, whose use of your personal information is governed by their Privacy Policy and PCI-DSS compliance standards.
Email Marketing & Communications
If you opt in to receive news, promotional offers, or updates from us, we will collect your email address and messaging preferences. You can withdraw your consent or opt out of marketing communications at any time by clicking the "Unsubscribe" link in any email we send.
6. Legal Basis for Processing Under GDPR
If You are located in the EEA or UK, the table below sets out, for each processing activity, the categories of data involved and the specific legal basis relied upon under Article 6 GDPR.
We do not use your Personal Data for any purpose incompatible with the purpose for which it was originally collected, in line with the purpose limitation principle (Art. 5(1)(b) GDPR).
7. Automated Decision-Making and Profiling
We use limited profiling for advertising and remarketing purposes (for example, showing you ads based on pages you previously visited on our Website). This profiling:
· Does not produce legal effects concerning you or similarly significantly affect you;
· Is only carried out on the basis of your prior consent (see Section 8, Cookies & ePrivacy Directive Compliance);
· Can be stopped at any time by withdrawing consent through our cookie preference centre or the relevant third-party opt-out tool.
We do not use fully automated decision-making, including profiling, that produces legal or similarly significant effects on you within the meaning of Article 22 GDPR.
8. Cookies & ePrivacy Directive Compliance
How consent works on this Website
Non-essential cookies and similar tracking technologies (analytics, advertising, remarketing, and reCAPTCHA cookies) are not set, and their associated scripts do not load or execute, until you provide explicit, informed, opt-in consent through our cookie consent banner. This means no data collection by these tools occurs before you make a choice.
Our cookie banner allows you to consent separately, by category, rather than through a single blanket "Accept All" action:
· Strictly necessary cookies — always active; required for core Website functionality (e.g., session management, security, load balancing on Google Sites infrastructure). No consent is required for these under Article 5(3) of the ePrivacy Directive.
· Functional cookies — support optional features such as address auto-complete (Google Places).
· Analytics cookies — Google Analytics, used to understand site usage.
· Advertising/remarketing cookies — Google Ads Remarketing, Meta Pixel, used to serve targeted ads on third-party sites.
· Security/anti-spam cookies — Google Invisible reCAPTCHA, only activated after you consent to this category.
Cookie table
This table reflects the categories of cookies in use. Exact cookie names and durations should be verified against a live scan of the Website before publication.
Managing your preferences
You can change or withdraw your cookie consent at any time via the cookie preference link in the Website footer, or through your browser settings. Withdrawing consent does not affect the lawfulness of processing carried out before withdrawal.
9. International Data Transfers (GDPR)
Your Personal Data may be transferred to, and processed in, countries outside the EEA and UK. The specific safeguard applied depends on the destination:
· Transfers to the United States (e.g., Google LLC infrastructure, Stripe, Meta): we rely on the European Commission's EU-US Data Privacy Framework adequacy decision where the recipient is a certified participant, or the European Commission's Standard Contractual Clauses (SCCs) as a fallback where certification does not apply.
· Transfers to Hong Kong (e.g., where Pacific Gateway Finance Ltd or its affiliates process data): Hong Kong does not benefit from an EU adequacy decision. We rely on the European Commission's Standard Contractual Clauses (SCCs), together with a documented Transfer Impact Assessment (TIA), as the legal basis for these transfers.
· Transfers to any other third country: we apply SCCs or another Article 46 GDPR safeguard, and will inform you of the safeguard used on request.
You may request a copy of the relevant safeguard documentation (e.g., the SCCs applicable to your data) by contacting us at info@pacificgateway.org.
10. Your Data Protection Rights Under GDPR
If You reside in the EEA or UK, You have the following rights:
· Right of Access: The right to request copies of Your Personal Data.
· Right to Rectification: The right to request correction of inaccurate or incomplete data.
· Right to Erasure ("Right to be Forgotten"): The right to request deletion of Your Personal Data under certain conditions.
· Right to Restrict Processing: The right to request that we restrict processing of your data.
· Right to Data Portability: The right to receive your data in a structured, machine-readable format.
· Right to Object: The right to object to our processing of your Personal Data (e.g., direct marketing or remarketing).
· Right to Withdraw Consent: The right to withdraw consent at any time without affecting lawful processing prior to withdrawal.
· Right to Lodge a Complaint: The right to lodge a complaint with an EU/UK Data Protection Authority about our collection and use of your data.
To exercise these rights, please contact us at info@pacificgateway.org.
11. Notice for California Residents (CCPA / CPRA & CalOPPA)
California Online Privacy Protection Act (CalOPPA) Compliance
· Do Not Track (DNT) Signals: Our website currently does not alter its behavior in response to web browser "Do Not Track" signals due to a lack of uniform industry standards.
· Third-Party Tracking: Third parties (such as Google Analytics and Google Ads) may collect personally identifiable information about your online activities over time and across different websites when you use our Service.
California Consumer Privacy Act (CCPA/CPRA) Disclosures
In the preceding 12 months, we have collected the following categories of personal information:
· Identifiers: Name, email address, phone number, IP address, device ID.
· Commercial Information: Purchased services, payment details, transaction histories.
· Internet/Network Activity: Browsing history, search interactions, traffic data.
· Geolocation Data: Approximate geographic location derived from IP address.
Sale and Sharing of Personal Information
We do not sell personal information for monetary payment. However, using third-party cookies for cross-context behavioral advertising (remarketing) may be considered "sharing" or "selling" under CPRA definitions.
You have the right to opt out of the sale or sharing of your personal information. To exercise this right, click the "Do Not Sell or Share My Personal Information" link in our website footer or adjust your cookie consent settings.
California Consumer Rights
· Right to Know & Access: Right to request information regarding categories and specific pieces of personal information collected.
· Right to Delete: Right to request deletion of personal information held by us.
· Right to Correct: Right to request correction of inaccurate personal information.
· Right to Limit Use of Sensitive Personal Information: Right to restrict the use of sensitive personal data to necessary operational purposes.
· Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.
To submit a California privacy request, contact us at info@pacificgateway.org.
12. Data Retention
We retain your Personal Data only for as long as necessary to fulfill the purposes set out in this policy, complete transaction contracts, fulfill legal or reporting obligations, and resolve disputes. Standard retention rules:
· Account & Service Data: Duration of account relationship plus up to 24 months.
· Customer Support & Email Inquiries: Up to 24 months from communication closure.
· Analytics & Usage Logs: Up to 24 months.
· Financial & Transaction Records: Retained for up to 7 years to meet tax and legal obligations.
13. Security of Your Personal Data
We employ appropriate administrative, technical, and physical security safeguards to protect your personal data. However, no method of transmission over the Internet or electronic storage is 100% secure.
14. Children's Privacy
Our Service is not intended for individuals under 16 years of age, and we do not knowingly collect personal data from children. Note that some EU member states set a lower age of consent for information society services (as low as 13, depending on the country), consistent with Article 8 GDPR. Where a lower national threshold applies to you, that threshold governs your ability to consent to our Service without parental authorisation. If we become aware that we have collected Personal Data from a child without appropriate consent, we will take steps to delete that information promptly.
15. Contact Us
If you have questions about this Privacy Policy or wish to exercise your legal rights, please contact us:
· Email: info@pacificgateway.org
· Data Controller: [Pacific Gateway Finance Ltd, PO Box 1144, Yune Long Delivery Office, Hong Kong]
· EU & UK Representative: info@delightable.eu
Last updated: September 13, 2026