Privacy Policy

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Privacy Policy Effective date: 1 September 2026 Last updated: 10 September 2026 Apex Alpha Solutions Limited ("the Company", "we", "us") develops and operates the Safety Cycle mobile application and its associated management system ("the System"). This Privacy Policy explains how we collect, use, store and protect personal data. 1. Information We Collect 1.1 Worker information entered by supervisors (foremen) For construction site safety management and statutory record-keeping, supervisors enter the following worker information into the System: • Name • Mobile phone number • Worker Registration Card expiry date • Construction Industry Safety Training Certificate (Green Card) expiry date • Photographs of work permits and related certificates • Handwritten signature 1.2 System user (supervisor) account information • Login name and password • Full name • Email address and mobile phone number 1.3 Safety form content Work information recorded in the daily safety cycle forms, which may include worker names and signatures of relevant personnel. 1.4 System operation records Administrator activity logs in the back office, used for security audit purposes. 2. Information We Do NOT Collect This application does not collect: • Location data (the application does not request any location permission) • Contacts • Audio or microphone data • Health or financial information • Advertising identifiers (the application contains no advertising) 3. Purpose and Use We collect the above information solely to: • Produce and retain statutorily required daily site safety forms • Verify workers' safety qualifications and certificate validity • Provide reminders when certificates are approaching expiry • Manage system accounts and authenticate users • Maintain security audit records We do not use personal data for marketing, nor do we sell it to third parties. 4. Camera and Photo Library Permissions The application requests camera and photo library access solely to capture or select photographs of workers' certificates. We do not access any images on your device unless you actively capture or select them. 5. Data Storage and Security • Data is stored on servers located in Hong Kong • All data transmission is encrypted using HTTPS • Sensitive files such as certificate photographs and signatures require authentication to access and cannot be downloaded via public links • Passwords are stored as salted hashes; our staff cannot view your original password 6. Data Retention Safety forms and related records are statutory documents for site safety management. We retain them for seven years after completion of the relevant works project, to meet statutory audit, insurance claim and dispute resolution needs. They are deleted or anonymised thereafter. Workers certificate photographs and expiry data are retained for one year after the worker ceases to participate in the relevant project, then deleted. System user account data is retained for one year after the account is deactivated, then deleted. 7. Data Sharing We do not disclose personal data to third parties except: • Where required by law, regulation or government authority • Where safety forms must be provided to relevant contractors or regulatory bodies in the course of site safety management 8. Rights of Workers (Data Subjects) Workers' personal data is entered into the System by their supervisors. Under the Hong Kong Personal Data (Privacy) Ordinance, data subjects have the right to access and correct their personal data. To request access or correction, please contact: Apex Alpha Solutions Limited Email: itdevedept@gmail.com Phone: 852 91386411 Address: ROOM 100, G/F, DD130, TO YUEN WAI, TUEN MUN, N.T. 9. Children's Privacy The System is intended for construction site use and is not directed at persons under 18. We do not knowingly collect data from children. 10. Changes to This Policy Any revisions to this Privacy Policy will be published on this page. 11. Contact Us Apex Alpha Solutions Limited Email: itdevedept@gmail.com Phone: 852 91386411 Address: ROOM 100, G/F, DD130, TO YUEN WAI, TUEN MUN, N.T.