Privacy Policy

1. Introduction

Cobalt Quill ("we", "us", "our"), operated from 5/F, 88 Lockhart Road, Wan Chai, Hong Kong, is committed to protecting the personal data of its subscribers and website visitors. This Privacy Policy explains what information we collect, why we collect it, and how we use and protect it. Questions about this policy should be directed to [email protected].

2. Data Collection

We collect the following categories of personal data:

• Subscription data: Name, email address, and (where provided) phone number submitted through the contact form on our website.
• Correspondence data: Content of emails and other messages sent to our editorial address, used only to respond to enquiries.
• Technical data: Basic server logs, including IP address and browser type, retained for up to 30 days for security and troubleshooting purposes.
• Cookie data: Cookie preferences stored locally in your browser. See Section 5 for details.

We do not collect payment card data directly; subscription payments are handled through third-party processors who maintain their own privacy policies.

3. Legal Basis and Purpose

Under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, we process personal data on the following bases:

• Consent: For newsletter delivery and marketing communications, where you have subscribed.
• Contractual necessity: To fulfil subscription arrangements, including billing and account management.
• Legitimate interests: For basic security logging and fraud prevention, where these interests do not override your rights.

We retain subscription data for the duration of your subscription plus twelve months. Correspondence data is retained for twenty-four months. Server logs are deleted after thirty days.

4. Data Usage and Sharing

Your personal data is used only to deliver the newsletter, manage your subscription, and respond to your correspondence. We do not sell personal data to third parties. We do not use personal data for behavioural profiling or targeted advertising.

We may share data with service providers who assist in delivery (such as email delivery platforms), subject to data processing agreements that restrict their use to the purposes for which data is shared. We do not permit these providers to use your data for their own purposes.

We may disclose personal data where required by Hong Kong law or by a valid order of a court or regulatory authority.

5. Cookies

Our website uses a small number of cookies. Essential cookies support basic functionality. Optional analytics cookies help us understand aggregate readership patterns; you may decline these through the consent banner on the homepage. We do not use cookies for advertising or cross-site tracking. Full details are available in our Cookie Policy.

6. Data Security

We maintain appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include encrypted data transmission (TLS), access controls limiting data access to authorised staff, and regular reviews of our security practices. In the event of a data breach affecting your personal data, we will notify you and the relevant authority as required by applicable law.

7. Your Rights

Under the Personal Data (Privacy) Ordinance and, where applicable, the GDPR, you have the following rights regarding your personal data:

• The right to access a copy of personal data we hold about you
• The right to correct inaccurate data
• The right to request deletion of your data (subject to legal retention obligations)
• The right to withdraw consent for marketing communications at any time
• The right to data portability (where applicable)
• The right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (Hong Kong)

To exercise any of these rights, write to [email protected]. We will respond within thirty days.

8. Third-Party Links

Our newsletter and website may include links to external publications, organisations, and resources. We are not responsible for the privacy practices of third-party sites and recommend that you read their privacy policies before submitting personal data.

9. Children's Privacy

Cobalt Quill is directed at professional readers aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If you believe a minor has submitted data to us, please contact [email protected] and we will delete it promptly.

10. Policy Updates

We may update this policy from time to time. When we do, we will revise the "Last updated" date above and, where changes are material, notify active subscribers by email. Continued subscription following notification constitutes acceptance of the revised policy.

11. Contact

All data-related enquiries should be directed to: