Effective Date: 29 June 2026

Last Updated: 29 June 2026

 

1. Introduction

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The Baby Project HK ("we", "us", or "our") is a baby gear consultancy based in Hong Kong and operated by Out of the Box Holdings Limited. We are committed to protecting the privacy and personal data of our clients, website visitors, and contacts in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO") of Hong Kong.

This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit our website (www.thebabyprojecthk.com), contact us, or engage our services. By using our website or services, you agree to the practices described in this policy.

 

2. Data Controller

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The data user (controller) responsible for your personal data is:

The Baby Project HK

Contact: Out of the Box Holdings Limited

Email: hello@the-baby-project.com

WhatsApp / Phone: +852 5911 2086

Instagram: @thebabyprojectco

 

3. What Personal Data We Collect

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In accordance with Data Protection Principle 1 (DPP1) of the PDPO, we only collect personal data that is necessary for the purposes described in this policy. The personal data we may collect includes:

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3.1 Information You Provide Directly

• Name

• Email address

• Phone number / WhatsApp number

• Delivery address (for the Curated List & Item Purchasing and Shopping, Room Setup & Decor services)

• Baby due date or birth date

• Family preferences, budget range, and living space details (relevant to your consultation)

• Payment information (processed securely through our payment provider — we do not store card details)

 

3.2 Information Collected Automatically

• IP address and browser type

• Pages visited on our website and time of visit

• Device type and operating system

• Referring website or URL

This technical data is collected via Wix.com (our website platform) and may use cookies. Please refer to Section 9 (Cookies) for more detail.

 

3.3 Information from Third Parties

• If you contact us via Instagram (@thebabyprojecthk), we may collect your Instagram handle and the content of your messages.

• If you subscribe to our newsletter, we collect your email address.

 

4. How We Use Your Personal Data

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In accordance with DPP3 of the PDPO, we only use your personal data for the purpose for which it was collected, or a directly related purpose. We use your personal data to:

• Provide and administer the consultation services you have engaged

• Respond to enquiries and communicate with you about your service

• Process payments and maintain transaction records

• Prepare personalised baby shopping lists and recommendations

• Coordinate purchasing and delivery of baby products on your behalf (where applicable)

• Send you our newsletter (only if you have subscribed and given consent)

• Improve our website, services, and client experience

• Comply with applicable laws and regulations in Hong Kong

We will not use your personal data for direct marketing purposes without first obtaining your explicit consent, as required under Part VIA of the PDPO.

 

5. Direct Marketing

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If you have consented to receive marketing communications from us, we may use your name and email address to send you updates, tips, and information about our services. We will always:

• Obtain your consent before sending any marketing communication

• Clearly identify each marketing message as coming from The Baby Project HK

• Provide a simple, free method to opt out at any time

You may withdraw your consent to receive marketing at any time by emailing hello@thebabyprojecthk.com or clicking the unsubscribe link in any marketing email.

 

6. Data Accuracy and Retention

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In accordance with DPP2 of the PDPO:

• We take reasonable steps to ensure that the personal data we hold is accurate, complete, and up to date.

• We will retain your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by law.

• Client data related to completed consultations and purchases is typically retained for 7 years for accounting and legal compliance purposes, consistent with Hong Kong law.

• Newsletter subscriber data is retained until you unsubscribe.

• Website analytics data is retained in accordance with Wix.com's data retention policies.

Once personal data is no longer required, we will take reasonable steps to destroy or permanently anonymise it.

 

7. Data Security

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In accordance with DPP4 of the PDPO, we implement appropriate technical and organisational measures to protect your personal data against unauthorised or accidental access, processing, erasure, loss, or use. These measures include:

• Secure storage of client information

• Use of reputable third-party platforms (Wix, payment processors) with their own security standards

• Limited access to personal data — only Gloriana Bertarioni and any directly engaged service providers have access to client data

• Encrypted communication channels where possible

Please note that no method of transmission over the internet is 100% secure. While we strive to protect your personal data, we cannot guarantee absolute security.

 

8. Disclosure and Transfer of Personal Data

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In accordance with DPP3 and DPP5 of the PDPO, we do not sell, rent, or trade your personal data to third parties. We may share your personal data with:

• Service providers who assist us in delivering our services (e.g., delivery companies for product purchasing services, payment processors), strictly for those purposes

• Our website platform Wix.com, which hosts our website and processes technical data

• Professional advisors such as accountants or lawyers, where required

• Hong Kong government or regulatory authorities, where required by law

Where your personal data is transferred outside of Hong Kong (for example, to Wix servers), we take reasonable steps to ensure it receives an equivalent level of protection as required under the PDPO.

 

9. Cookies

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Our website is built on Wix.com, which uses cookies — small text files placed on your device — to enable website functionality, analyse traffic, and improve user experience. The types of cookies that may be placed include:

• Essential cookies: necessary for the website to function

• Analytics cookies: help us understand how visitors use the website (e.g., pages visited, time spent)

• Marketing cookies: used to deliver relevant content (only where you have consented)

You can control or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the website. For more information on how Wix uses cookies, please visit Wix's Privacy Policy at www.wix.com/about/privacy.

 

10. Your Rights Under the PDPO

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Under the PDPO (DPP6), you have the right to:

• Request access to the personal data we hold about you

• Request correction of any inaccurate personal data we hold about you

• Be informed of the type of personal data we hold about you and the main purposes for which it is used

• Withdraw consent to direct marketing at any time

To exercise any of these rights, please contact us in writing at:

Email: hello@thebabyprojecthk.com

WhatsApp / Phone: +852 5911 2086

We will respond to all data access or correction requests within 40 days, as required by the PDPO. We reserve the right to charge a reasonable fee for processing data access requests, in accordance with the PDPO.

 

11. Complaints

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If you are not satisfied with how we have handled your personal data, you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) of Hong Kong:

• Website: www.pcpd.org.hk

• Telephone: +852 2827 2827

• Address: 12/F, 248 Queen's Road East, Wan Chai, Hong Kong

We would always appreciate the opportunity to address your concerns directly before you contact the PCPD, so please reach out to us first.

 

12. Third-Party Links

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Our website may contain links to third-party websites (such as Instagram). We are not responsible for the privacy practices of those websites and encourage you to read their privacy policies before providing any personal data.

 

13. Children's Privacy

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Our services are directed at parents and expectant parents, not at children. We do not knowingly collect personal data directly from children under 18 years of age. If you believe we have inadvertently collected personal data from a child, please contact us so we can delete it.

 

14. Changes to This Privacy Policy

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We may update this Privacy Policy from time to time to reflect changes in our practices, services, or applicable law. The updated policy will be posted on our website with a revised "Last Updated" date. We encourage you to review this policy periodically.

Continued use of our website or services after any changes constitutes your acceptance of the updated policy.

 

15. Contact Us

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If you have any questions about this Privacy Policy or how we handle your personal data, please do not hesitate to contact us:

The Baby Project HK

Email: hello@the-baby-project.com

WhatsApp / Phone: +852 5911 2086

Instagram: @thebabyprojectco

Website: www.the-baby-project.com

 

© 2026 Out of the Box Holdings Limited trading as The Baby Project HK. All rights reserved.