This Privacy Policy explains how Aevora International Real Estate Limited ("Aevora", "we", "our", "us") collects, uses, discloses, and safeguards personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and, where applicable, the General Data Protection Regulation (EU) 2016/679.

This policy applies to all websites, digital platforms, systems, and services operated and marketed by Aevora International Real Estate Limited under the Aevora Collective brand, including its proprietary technology powered by ACE™, and any related applications, modules, or services (together, "the Platforms"), and all interactions across our services.

Aevora Collective is the trading brand under which Aevora International Real Estate Limited operates.

• Identity Data: Full name, title, ID or passport number (if required for service delivery)
• Contact Data: Email address, phone number, mailing address
• Usage Data: Interactions with the Platforms and other digital services
• Transaction Data: Service history, payment records, engagement logs, subscription status
• Location Data: For concierge and property-related services
• Content Data: Property listings, listing images, agent profile details, brand assets, and any content uploaded by users to the Platforms
• Sensitive Data: Only with explicit consent where relevant (for example, lifestyle preferences for concierge services)

We collect personal data:

• Directly from you through onboarding, service requests, forms, or communications
• Automatically through cookies, analytics tools, and platform usage
• From third-party sources (for example, partners, affiliates, or public databases) with a lawful basis
• From your use of the Platforms, including content you create, images you upload, and settings you configure

We use personal data to:

• Deliver, operate, and personalise services across the Aevora ecosystem
• Enhance user experience through the Platforms
• Generate marketing materials, property pages, brochures, social graphics, and email content for users
• Process subscription payments and manage billing
• Conduct internal analytics and improve operational efficiency
• Fulfil legal and regulatory obligations
• Communicate service updates, marketing, and strategic information (with opt-out options where required)

Under the PDPO, we process personal data for purposes directly related to our functions and activities. Under the GDPR, we rely on:

• Consent
• Contractual necessity (including the fulfilment of subscriptions and services)
• Legal obligation
• Legitimate interests (for example, service improvement and fraud prevention)

We may share personal data with:

• Service Providers and Affiliates: for operational and service delivery purposes
• Payment Processors: third-party payment processors handle card and payment data on our behalf. We do not store full card numbers on our servers.
• Cloud Infrastructure Providers: we use third-party cloud infrastructure for hosting, storage of content, and transactional email delivery
• Legal Authorities: where required by law or to protect our rights
• Technology Partners: for hosting, analytics, and platform functionality

Cross-Border Transfers: Data may be transferred outside Hong Kong with appropriate safeguards, including GDPR-compliant Standard Contractual Clauses where required.

Under the PDPO, you have the right to access and correct your personal data, withdraw consent where applicable, and be informed of the purpose of data collection and use.

Under the GDPR, you may also request erasure (the "right to be forgotten"), object to processing, request data portability, and lodge a complaint with a supervisory authority.

We retain personal data only for as long as necessary to fulfil the purposes outlined in this policy or as required by law.

Content uploaded to the Platforms is retained while your account is active and for a reasonable period after cancellation to allow data export, after which it is deleted or anonymised. Billing records are retained for at least 7 years to meet Hong Kong tax and accounting requirements.

We implement security measures including encryption across the Platforms, role-based access controls, secure cloud infrastructure, and regular audits and vulnerability assessments. Content stored on the Platforms is protected in transit and at rest.

Interactions with AI-powered features on the Platforms may involve automated processing or profiling. These systems are designed to enhance personalisation and operational efficiency. No decisions with legal or significant effects are made solely by automated means without human oversight.

If you upload content to the Platforms, you are the data controller for any personal data you include in that content (for example, client information, property owner details, or contact information). Aevora International Real Estate Limited acts as a data processor on your behalf, storing and displaying this content solely to deliver the service. A separate Data Processing Agreement is available for users who require one.

Subscriptions and paid services are billed through third-party payment processors. When you subscribe, you are redirected to a hosted payment page operated by the payment processor. We receive confirmation of payment and store subscription status, plan, and billing period. We do not receive or store your full card details. The payment processor acts as an independent data controller for the processing of your payment method and is subject to its own privacy policy.

We may update this Privacy Policy from time to time to reflect changes in technology, legal requirements, or our services. Updates will be posted on the Platforms with the revised effective date.

Email: info@aevoracollective.com
Mailing Address: Unit B, 3/F, Chun Wah Commercial Building, 30 Minden Ave, Tsim Sha Tsui, Kowloon, Hong Kong. (By appointment only)