Last updated: 3 May 2026

Privacy Policy

This policy explains how Suphy Direct Limited collects, uses, and safeguards personal data in connection with our network infrastructure and retail e-commerce services. We comply with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) and observe applicable international data protection frameworks where relevant.

1. Who we are

Suphy Direct Limited is a company incorporated in Hong Kong, Company Number 78550392, with registered office at Unit E01, 10/F, Wong King Industrial Building, 2-4 Tai Yau Street, San Po Kong, Hong Kong. We act as the data user (controller) for the personal data described in this policy.

2. Data we collect

2.1 Network infrastructure customers

Identification: company name, registration number, contact person name and role.
Contact: business email, phone, postal address.
Technical: AS numbers, prefix details, network usage information necessary to issue Letters of Authorisation, RPKI ROAs, and WHOIS objects.
Commercial: contracts, invoices, payment records.

2.2 Retail e-commerce customers

Order data: name, shipping and billing address, email, phone, items purchased.
Payment data: processed via third-party payment providers; we do not store full card numbers on our systems.
Communication: messages exchanged through our support channels or marketplace platforms.

2.3 Website visitors

Server access logs (IP address, user agent, timestamp) retained for security and abuse-prevention purposes.
No advertising trackers or third-party analytics cookies are installed without explicit consent.

3. How we use personal data

To deliver the services you have requested — provisioning IP space, fulfilling orders, providing support.
To meet legal, regulatory, and Regional Internet Registry (RIR) obligations, including WHOIS accuracy and abuse handling.
To process payments and maintain accounting records.
To investigate and respond to abuse reports, fraud, and security incidents.
To send transactional notices (e.g. lease renewals, order updates). We do not send marketing email without separate opt-in.

4. Disclosure to third parties

We share personal data only with parties who need it to deliver the service, including:

Regional Internet Registries (RIPE, ARIN, APNIC, LACNIC, AFRINIC) for WHOIS and resource-registration purposes.
Upstream network providers, where required to authorise route announcements.
Payment processors, shipping carriers, and online marketplace platforms (retail business).
Professional advisers (legal, accounting) bound by confidentiality.
Law-enforcement or regulatory authorities, where required by valid legal process.

We do not sell personal data and do not share it for third-party advertising.

5. International transfers

Some service providers and registries are located outside Hong Kong. Where data is transferred internationally, we rely on the recipient's own legal compliance and contractual safeguards to ensure an adequate level of protection.

6. Retention

We retain personal data only as long as necessary for the purposes set out above, and to comply with legal, accounting, and abuse-handling requirements. Network and order records are typically retained for seven years after the end of the customer relationship; server logs are retained for up to twelve months.

7. Your rights

Under the Hong Kong PDPO you have the right to request access to, and correction of, the personal data we hold about you. Submit requests in writing to support@suphydirectlimited.com. We will respond within forty days. We may charge a reasonable fee for fulfilling data-access requests.

8. Security

We apply reasonable technical and organisational measures to protect personal data against unauthorised access, loss, or alteration. No system is perfectly secure; in the event of a material data incident we will notify affected parties without undue delay.

9. Changes to this policy

We may update this policy from time to time. The "Last updated" date at the top reflects the most recent revision. Material changes will be highlighted on this page or notified to active customers by email.

10. Contact

For privacy questions, data-access requests, or complaints, contact:
Suphy Direct Limited
Unit E01, 10/F, Wong King Industrial Building, 2-4 Tai Yau Street, San Po Kong, Hong Kong
support@suphydirectlimited.com