Privacy Policy

1. Introduction

This Privacy Policy describes how LHT Media Limited ("LHT Media", "we", "us", or "our"), a private company limited by shares incorporated in the Hong Kong Special Administrative Region (Company Registration Number 79832989), collects, uses, discloses, and protects your personal data when you visit our website at lht-media.com (the "Site") or engage with our services.

This Policy applies to data we collect through the Site, in email or other correspondence, and in the course of providing our digital marketing services to clients and creators.

2. Data Controller

For the purposes of the EU General Data Protection Regulation (GDPR), the UK GDPR, and the Hong Kong Personal Data (Privacy) Ordinance (PDPO), the data controller is:

3. Personal Data We Collect

We collect the following categories of personal data:

3.1 Information You Provide Directly

• Contact details such as your name, business name, email address, and telephone number when you contact us through forms, email, or messaging channels.
• Business and project information you share when discussing potential or active engagements, such as marketing objectives, campaign budgets, brand assets, and target audiences.
• Creator profile information if you engage with us as a content-creator partner, including channel data, audience demographics, and verification information necessary to facilitate introductions and contracting with our clients.

3.2 Information Collected Automatically

• Technical data such as IP address, browser type and version, operating system, and device identifiers.
• Usage data such as pages visited, time spent on pages, referring URLs, and interaction events.
• Cookies and similar technologies — see our Cookie Policy for details.

3.3 Information from Third Parties

• Public information from platforms such as YouTube, Meta, and other social networks when assessing creator partnerships or campaign performance, in accordance with the terms of those platforms.
• Analytics providers (where used) such as Google Analytics, which provide aggregated usage data.

4. How We Use Personal Data

We process personal data for the following purposes:

• To respond to your inquiries and provide information about our services.
• To deliver, manage, and improve services contracted by our clients and partners.
• To process payments to our service providers and contractors and to comply with related tax and accounting obligations.
• To operate, secure, and improve the Site and our internal systems.
• To comply with legal, regulatory, and audit obligations, including anti-money-laundering (AML) and know-your-customer (KYC) requirements where applicable.
• To detect and prevent fraud, abuse, and unauthorized access.

5. Legal Bases for Processing (GDPR / UK GDPR)

Where the GDPR or UK GDPR applies, we rely on the following legal bases:

• Performance of a contract — to deliver services to clients and creators.
• Legitimate interests — to operate and grow our business, respond to inquiries, secure our systems, and prevent fraud, balanced against your rights and interests.
• Consent — for optional cookies, marketing communications, and any processing where consent is required.
• Legal obligation — to comply with applicable laws and regulatory requirements.

6. How We Share Personal Data

We do not sell your personal data. We may share it with:

• Service providers who process data on our behalf (e.g., cloud hosting, email, payment processing, accounting, analytics), under contractual data protection terms.
• Clients, creators, and partners as strictly necessary to fulfil contracted services (e.g., sharing campaign briefs with creators or reporting performance to clients).
• Professional advisors such as auditors, lawyers, and accountants, under confidentiality obligations.
• Authorities when required by law, court order, or regulatory request.
• Successors in interest in connection with a merger, acquisition, or transfer of business assets, subject to appropriate confidentiality protections.

7. International Data Transfers

Because we operate internationally, personal data may be transferred to, and processed in, countries other than the one in which you reside. Where such transfers involve data subject to the GDPR or UK GDPR, we implement appropriate safeguards, including Standard Contractual Clauses (SCCs) or equivalent mechanisms, and ensure that recipients maintain a level of protection comparable to the originating jurisdiction.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, accounting, or reporting requirements. When data is no longer required, we securely delete or anonymize it. Specific retention periods vary by data type:

• Contact inquiries: up to 24 months from last interaction.
• Client and creator engagement records: for the duration of the contractual relationship plus up to 7 years for tax, accounting, and audit purposes.
• Website analytics data: as governed by our analytics provider's standard retention settings (typically up to 26 months).

9. Data Security

We implement technical and organizational measures appropriate to the risks of processing personal data, including encrypted transmission (HTTPS/TLS), access controls, secure cloud infrastructure, and regular review of our security practices. No system is perfectly secure, but we strive to protect your data against unauthorized access, alteration, disclosure, or destruction.

10. Your Rights

Subject to applicable law, you may have the following rights regarding your personal data:

• Access — to obtain confirmation of and a copy of the personal data we hold about you.
• Rectification — to correct inaccurate or incomplete data.
• Erasure — to request deletion, subject to legal exceptions.
• Restriction — to limit how we process your data in certain circumstances.
• Portability — to receive your data in a structured, machine-readable format.
• Objection — to object to processing based on legitimate interests or for direct marketing.
• Withdraw consent — where processing is based on consent, without affecting prior lawful processing.
• Lodge a complaint — with a competent data protection authority, such as the Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD) or your local EU/EEA supervisory authority.

To exercise any of these rights, please contact us at info@lht-media.com. We may need to verify your identity before responding.

11. Children's Privacy

Our Site and services are not directed at children under the age of 16. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can take appropriate action.

12. Cookies and Tracking Technologies

We use cookies and similar technologies on our Site. For detailed information on the cookies we use, their purposes, and how to manage them, please refer to our Cookie Policy.

13. Third-Party Links

The Site may contain links to third-party websites or services. We are not responsible for the privacy practices of those third parties. We encourage you to review their privacy policies before sharing any personal data.

14. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in law, our practices, or our services. We will post the updated version on this page with a revised "Last Updated" date. Material changes will be communicated through prominent notice on the Site.

15. Contact Us

For questions, requests, or complaints about this Privacy Policy or our data practices, please contact us: