Privacy Policy & Personal Information Collection Statement (PICS)

Effective Date: 22 August 2026

Company: Akquire Limited (hereinafter “the Company,” “we,” “us,” or “our”), operator of itstwelve.com (the “Website” or “Site”)

1. Introduction

Welcome to itstwelve.com (the “Website”), operated by Akquire Limited, a company registered in the Hong Kong Special Administrative Region (“HKSAR”). We respect your legal rights of privacy and are committed to complying with the Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and the Unsolicited Electronic Messages Ordinance (Cap. 593) (“UEMO”).

2. Collection of Personal Data (DPP1)

We collect personal data only when strictly necessary. As an informational restaurant directory, we do not require account registration for visitors, nor do we host user reviews or direct booking systems.

  • Email Address: collected solely on a voluntary basis when you choose to subscribe to our newsletter. If you do not provide your email address, we cannot send you the newsletter, but your access to the broader Website remains entirely unaffected.
  • Automated Data (Cookies & Analytics): our servers and third-party services (e.g., Google Ads) automatically collect standard visitor data via cookies, which may include IP addresses, browser type, language settings, operating system, referring site, and pages visited. Full detail on the categories of cookies used is set out in our separate Cookie Policy.

We do not collect sensitive personal data such as names, phone numbers, or financial details from visitors, and we do not host user reviews or booking systems on the Site.

Directory Content Sourcing: the restaurant listings displayed on the Site (name, address, cuisine, opening hours, lunch deal details) are compiled through the Company’s own manual research and from publicly available third-party sources, including other directory and booking platforms. This directory data concerns businesses, not individuals, and does not generally constitute “personal data” under the PDPO. In the limited instance that a listing includes an identifiable individual’s contact details (e.g., a sole proprietor), such data is collected fairly, from publicly available sources, and solely for the purpose of accurately presenting the business listing.

3. Purpose and Use of Data (DPP3)

Your email address will be used exclusively for:

  • Sending you our digital newsletter containing restaurant recommendations, lunch deals, and directory updates.
  • Administrative communications regarding your subscription status.

4. Direct Marketing (Part 6A of PDPO) & UEMO Compliance

We will only use your personal data for direct marketing (i.e., sending commercial electronic messages, such as newsletters featuring restaurant deals and promotions) if we have obtained your explicit, opt-in consent.

  • Opt-In Consent: when you subscribe, we provide a clear, unchecked opt-in checkbox or equivalent affirmative action. Silence, inactivity, or a failure to opt in does not constitute consent under Section 35C of the PDPO.
  • First-Time Use Notice: the first time we send you a direct marketing communication, we will remind you of your right to opt out, free of charge, as required by Section 35F of the PDPO.
  • Unsubscribe Facility: in strict compliance with the UEMO, every promotional email we send will contain an accurate sender profile and a clear, functional unsubscribe link.
  • Opt-Out: under Section 35G of the PDPO, you may withdraw your consent at any time, free of charge, by clicking the “unsubscribe” link in our emails or by contacting our Data Protection Officer.

5. Use of Cookies

The Website uses cookies to facilitate site functionality, track aggregate visitor statistics, and support advertising through Google Ads. By using the Site, you consent to our use of cookies as described in our Cookie Policy, available separately on the Website. You may disable cookies via your browser settings; this may affect certain features of the Site.

6. Affiliate Links and Third-Party Platforms

The Site contains affiliate links and outbound links that may direct you to third-party platforms (for example, a restaurant’s own website or a third-party booking platform such as Dining City) to complete a reservation or view further details. We do not control, and are not responsible for, the content, privacy practices, or data handling of these third-party platforms. Any personal data you provide on a third-party site is governed solely by that third party’s own privacy policy. Where such links form part of an affiliate marketing arrangement, further detail is set out in our separate Affiliate Disclosure.

7. Data Security and Processors (DPP4)

We take all practicable steps to protect your data from unauthorized access, processing, or erasure. We may transfer your email address to the following classes of third-party service providers (data processors), who are contractually bound to safeguard your data under standards equivalent to the PDPO:

  • Hosting & Infrastructure: our web hosting provider and content delivery/security network.
  • Email Service Providers: third-party platforms used to securely dispatch our newsletters.
  • Analytics & Advertising: Google Ads (Note: we do not pass your email address to Google; however, Google utilizes cookies to serve personalized ads based on your browsing behaviour).

Third-party directory or booking platforms referenced in our listings (e.g., Dining City) are independent data controllers in their own right and are not data processors acting on our behalf.

8. Data Retention (DPP2)

We will retain personal data only for as long as necessary for the purpose for which it was collected. Our retention periods are as follows:

  • Newsletter subscriber emails: retained for as long as you remain subscribed.
  • Unsubscribed contacts: immediately removed from active mailing lists upon unsubscribing, and retained only on a suppression list to ensure we do not re-contact you.
  • Website analytics data: retained for 26 months (in line with standard analytics platform defaults), after which it is automatically deleted or anonymised.
  • General enquiries: retained for 24 months from the date of your last communication with us.

9. Access and Correction Rights (DPP6)

Under the PDPO, you have the right to request access to and correction of your personal data held by us. In accordance with Section 19(1) of the PDPO, we will comply with a valid data access or correction request within 40 days of receipt. If we are unable to comply within that period, we will notify you in writing within the 40-day period and explain why, and will then comply as soon as reasonably practicable thereafter. In accordance with the PDPO, we may charge a reasonable fee to cover the direct cost of complying with a data access request.

If you wish to exercise these rights or have any questions, please contact our Data Protection Officer at:

Email: [email protected]

Address: Room 1108 Eton Solo, Hysan Avenue, Causeway Bay, Hong Kong

10. Data Breach Notification

Mandatory data breach notification is not yet a legal requirement in Hong Kong, although the PCPD is actively consulting on reforms that would introduce one. As a matter of good practice, in the event of a personal data breach that is likely to result in a real risk of significant harm to affected individuals, we will notify the PCPD and affected users as soon as reasonably practicable.

11. Changes to This Policy

As our services expand — for example, through business owner accounts, paid listings, or membership features — the categories of personal data we collect may change. This Privacy Policy will be updated accordingly, and material changes will be notified to users via a notice on the Website or, where appropriate, by email to newsletter subscribers.