Privacy Policy

1. Who We Are

New Digital Noise Limited ("NDN Group", "we", "us") is the data controller for personal information collected through GEOmeter (the "Service"), operated at nano.ndn.hk/geometer/.

We are a company incorporated in Hong Kong and are subject to the Personal Data (Privacy) Ordinance (Cap. 486) (PDPO) of the Hong Kong SAR.

Our Privacy Officer can be reached at: info@geoneo.ai

2. What Data We Collect

2.1 Data you provide directly

Data Type	When Collected	Why
Name	Enquiry form / subscription	To personalise communications
Email address	Enquiry / subscription / contact form	To deliver the Service and send onboarding emails
Company name	Enquiry / subscription	To identify your account
Phone number	Managed GEO enquiry form (optional)	For sales consultation
Brand names / queries	When running a GEO scan	To process your AI visibility scan
Payment details	Stripe checkout	To process subscription payments (handled by Stripe — we never store raw card data)

2.2 Data collected automatically

Data Type	Why
IP address	Security, fraud prevention, and geographic currency detection (via ipapi.co)
Browser/device type	To optimise the Service for your device
Pages visited and scan queries run	To improve the Service and detect abuse
Time and date of access	For security logs and usage analytics

2.3 Data we do NOT collect

• We do not collect sensitive personal data (health, financial, biometric, etc.)
• We do not track you across third-party websites
• We do not access your internal business systems

3. How We Use Your Data

• Providing the Service: Running GEO scans, delivering results, generating analysis
• Account management: Creating and maintaining your subscription account
• Onboarding communications: Sending the 5-email onboarding sequence to help you get value from the Service
• Customer support: Responding to your enquiries and resolving issues
• Service improvement: Using anonymised, aggregated usage data to improve GEOmeter's algorithms and features
• Billing and payments: Processing payments via Stripe
• Legal compliance: Meeting our obligations under applicable law
• Marketing (with consent): Sending product updates and relevant content — you can opt out at any time

4. Legal Basis for Processing

Under Hong Kong's PDPO, we collect and use personal data on the following bases:

• Contract performance: To deliver the subscription Service you have purchased
• Legitimate interests: To improve the Service, ensure security, and communicate with you about relevant updates
• Legal obligation: To comply with applicable laws and regulations
• Consent: For marketing communications (you can withdraw consent at any time)

5. Data Sharing & Third Parties

We share your data only as necessary to operate the Service. We do not sell your personal data.

Party	Purpose	Location
Stripe	Payment processing	USA (Standard Contractual Clauses)
Google (Gmail/Gemini)	Email delivery / AI engine queries	USA / Global
Anthropic (Claude)	AI engine queries and GEO analysis	USA
xAI (Grok)	AI engine queries	USA
Alibaba Cloud (Qwen)	AI engine queries (Asia region)	PRC/Singapore
Moonshot AI (Kimi)	AI engine queries (Asia region)	PRC
Brave Search	Web search queries for GEO analysis	USA
ipapi.co	IP geolocation for currency detection	USA/EU
Amazon Web Services	Server hosting (Singapore region)	Singapore

All third-party processors are required to handle your data securely and in compliance with applicable law. Brand names and queries you submit are transmitted to AI engines for processing — please do not submit confidential or sensitive information in scan queries.

6. Data Retention

• Account data: Retained for the duration of your subscription plus 12 months after cancellation
• Scan history and scores: Retained for up to 24 months to provide trend analysis
• Enquiry data: Retained for 24 months from the date of enquiry
• Payment records: Retained for 7 years as required by Hong Kong tax law
• Server logs: Retained for 90 days

You may request earlier deletion at any time — see Section 8.

7. Security

We take reasonable technical and organisational measures to protect your personal data, including:

• HTTPS/TLS encryption for all data in transit
• Server-side access controls and authentication
• Regular security reviews of our infrastructure
• API keys and credentials stored as environment variables, never in source code
• Payment data processed entirely by Stripe — we never store card details

No method of transmission over the internet is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security.

8. Your Rights (PDPO)

Under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of any inaccurate personal data
• Deletion: Request deletion of your personal data (subject to legal retention requirements)
• Opt-out of marketing: Unsubscribe from marketing emails at any time by clicking "Unsubscribe" in any email or contacting us
• Complaint: Lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD) at pcpd.org.hk

To exercise any of these rights, email us at info@geoneo.ai with the subject "Data Request". We will respond within 40 days as required by the PDPO.

9. Cookies

GEOmeter uses the following cookies and local storage:

Cookie / Storage	Purpose	Duration
geo_session	Identifies paid-tier subscribers for full-feature access	30 days
localStorage (dashboard)	Stores internal client metrics in browser (internal dashboard only)	Persistent until cleared

We do not use third-party tracking cookies or advertising cookies on GEOmeter. We do not use Google Analytics or similar tracking services.

10. Children's Privacy

GEOmeter is a business-to-business service intended for use by companies and professionals. We do not knowingly collect personal data from individuals under 18 years of age. If we become aware that we have collected data from a minor, we will delete it promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by email (for subscribers) and by updating the "Last updated" date at the top of this page. Continued use of the Service after changes constitutes acceptance of the updated Policy.

12. Contact & Data Access Requests

For any privacy questions, data access requests, or concerns:

Privacy Officer — New Digital Noise Limited (NDN Group)
Central, Hong Kong
Email: info@geoneo.ai
Subject line: "Privacy / Data Request"

You also have the right to contact the Office of the Privacy Commissioner for Personal Data (PCPD):
Website: pcpd.org.hk · Hotline: 2827 2827