Privacy Policy.

Effective Date: 09/February/2026

Last Updated: 09/February/2026

1. Introduction

Asia Strategic Growth Enterprises Limited ("we," "our," "us," or "the Company") is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://www.asiasge.com (the "Site").

Please read this Privacy Policy carefully. By accessing and using our Site, you acknowledge that you have read and understood the terms of this policy. We comply with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO") and the guidelines issued by the Privacy Commissioner for Personal Data (PCPD).

2. Data Collection and Use

We do not actively collect personal data from visitors unless it is voluntarily submitted through our contact form or email. The types of personal data we might collect if voluntarily submitted through our contact form and the purposes for which we use it are as follows:

Identity Data: Such as your name, title, company name. To respond to your inquiries submitted through our contact form, to provide you with information about our legitimate business services and to ensure that no personal data is used for proscribed or unlawful purposes, and to communicate with you.

Contact Data: Such as your email address, telephone number, address. To send you marketing communications (where you have consented), to deliver requested materials, and for client onboarding and management.

3. Hosting & Third‑Party Services

Please note that while we do not actively collect data, our website hosting provider or other third‑party services may automatically collect certain technical information (such as IP addresses, browser type, or usage statistics).

We are not responsible for the data collection practices of these providers, and we encourage you to review their privacy policies for more details.

4. Legal Basis for Processing

Under the PDPO, we process your personal data based on one or more of the following grounds:

· Your prescribed consent, which you may withdraw at any time.

· The processing is necessary for taking steps at your request to enter into a contract or for the performance of a contract.

· The processing is necessary for our legitimate interests, such as operating and improving our Site, and conducting our business, provided that such interests are not overridden by your data protection rights.

5. Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and whether we can achieve those purposes through other means.

6. Data Disclosure and Transfer

We do not sell, trade, or otherwise transfer your personal data to third parties without your consent, except in the following circumstances:

· Service Providers: We may share your data with trusted third-party service providers who assist us in operating our website, conducting our business, or servicing you (e.g., cloud hosting providers, analytics services), provided that they agree to keep this information confidential and comply with the PDPO.

· Legal Obligations: We may disclose your data where required to do so by law, subpoena, or other legal process, or if we believe that such action is necessary to comply with the law or to protect our rights, property, or safety, or that of others.

· Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your personal data may be transferred.

We do not transfer personal data to locations outside Hong Kong unless we have taken appropriate steps to ensure that your data will be protected to a standard comparable to the PDPO, such as by entering into a contract with the recipient incorporating the PCPD's recommended model clauses.

7. Data Security

We implement appropriate technical and organizational security measures designed to protect your personal data from accidental loss, unauthorized access, use, alteration, and disclosure. These measures include secure servers, encryption, and access controls. However, please note that no method of transmission over the Internet or electronic storage is 100% secure.

8. Your Rights under the PDPO

As a data subject under the PDPO, you have the right to:

· Access and Correction: Request access to and correction of any personal data we hold about you.

· Withdraw Consent: Withdraw your consent for the use of your personal data for marketing purposes at any time.

· Inquiry: Make inquiries about our privacy policies and practices.

To exercise any of these rights, please contact us using the details provided in Section 10 below. We will respond to your request within the time frame stipulated by the PDPO. We may need to verify your identity before processing your request.

9. Use of Cookies and Similar Technologies

Our Site may use cookies or similar technologies to improve user experience. In addition, our hosting provider may automatically collect technical information (such as IP addresses or browser type). We do not control these practices and encourage you to review their privacy policies.

10. Third-Party Links

Our Site may contain links to other websites that are not operated by us. This Privacy Policy does not apply to those third-party sites. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

11. Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or wish to make a complaint, please contact our Data Protection Officer at:

Asia Strategic Growth Enterprises Limited Email: contact@asiasge.com] Address: 15/F, The Chelsea, 69 Jervois Street, Sheung Wan, Hong Kong

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top. We encourage you to review this Privacy Policy periodically for any changes. Any updates will be effective upon posting. Continued use of our Site after changes indicates acceptance of the revised policy.