01

Purpose and Commitment

We are committed to processing personal data lawfully, fairly and transparently. We collect only the data reasonably necessary to respond to you, keep it secure, respect your rights and explain our practices in clear terms. This Policy should be read with our Cookie Policy.

02

Scope of This Policy

This Policy applies to personal data we process about website visitors, business contacts, prospective partners and investors, suppliers, job applicants and other people who contact us through the Services.

It does not apply to third-party websites or services that are linked from our Services but operated independently of us.

03

Legal Bases for Processing

Where a legal basis is required, we process personal data only when it is necessary to respond to your request or take steps you ask for; to comply with a legal obligation; to pursue our legitimate interest in operating and securing our business; or where you have given consent. You may withdraw consent at any time; this does not affect processing carried out before withdrawal.

04

Information We Collect

Information you give us

• Contact form: your name, email address, company name (optional), the topic you select and your message.
• Correspondence: anything you choose to include when you email us, such as your job title, telephone number or business documents.

Information collected automatically

Our hosting provider’s servers automatically record basic technical data for each request, such as IP address, browser type, the page requested and the time of the request. We do not use cookies, analytics tools, advertising pixels or other tracking technologies.

Sensitive data

We do not request sensitive or special-category data. Please do not send it to us unless it is clearly necessary.

05

How We Use Personal Data

• To read, route and reply to your enquiry, including passing it to APEX Energy, APEX Commerce or APEX Development where it concerns them.
• To manage a business relationship that follows from your enquiry.
• To keep the website secure, prevent misuse and fix technical problems.
• To meet legal, accounting and regulatory obligations and to establish or defend legal claims.

We do not send marketing messages unless you ask us to, and we do not make decisions about you based solely on automated processing.

06

Cookies and Online Tracking

This website does not use cookies or tracking technologies for visitors. Our Cookie Policy explains the only related technologies involved: the delivery of fonts by Google Fonts, and login cookies used only by our own staff when they manage the website.

07

Data Sharing and Access Controls

• Internal access: only authorised staff of our group who need the information for their role, under confidentiality obligations.
• Service providers: our website hosting and email providers, which process data only to provide their services to us.
• Authorities and advisers: regulators, courts, law-enforcement bodies or professional advisers where required by law or necessary to protect rights or safety.
• Corporate transactions: a buyer, investor or successor in connection with a merger, financing, reorganisation or sale of assets.

We do not sell personal data.

08

International Data Transfers

Our hosting, email and font-delivery providers may process data on servers located outside Cambodia. Where applicable law requires safeguards for such transfers, we use appropriate measures. Contact info@apex-group-holdings.com for more information.

09

Security Measures

• Encrypted connections (HTTPS) for the whole website.
• Access controls and role-based permissions for our inboxes and systems.
• Spam and abuse protection on the contact form.
• Confidentiality obligations for staff and oversight of service providers.

No method of transmission or storage is completely secure, but we maintain measures designed to protect against unauthorised access, loss, misuse and disclosure.

10

Data Retention and Deletion

We keep enquiries and correspondence only as long as reasonably necessary to deal with them and any business relationship that follows, and to meet legal and record-keeping requirements. Server logs are kept by our hosting provider for a limited period for security. When data is no longer needed, we delete or anonymise it.

11

Your Privacy Rights

Depending on applicable law, you may ask us to give you access to your personal data, correct it, delete it, restrict or object to its processing, provide it in a portable format, or withdraw your consent.

To make a request, email info@apex-group-holdings.com. We may ask for information to verify your identity. We aim to respond within 24 hours.

12

Children

Our Services are intended for businesses and adults and are not directed to children under 18. If you believe a child has sent us personal data, contact info@apex-group-holdings.com and we will delete it.

13

Incident Response

We maintain procedures to identify, contain, investigate and remedy suspected security incidents. If a personal-data breach occurs, we will assess the risk and notify affected individuals or authorities where required by law.

14

Third-Party Services

Our website loads fonts from Google Fonts and may link to other websites. Those services operate under their own privacy notices, which we encourage you to read.

15

Changes to This Policy

We may update this Policy to reflect changes in law, our Services or our practices. The current version is always posted here with its effective date.

16

Contact and Privacy Requests

APEX Group Holdings Co., Ltd., Phnom Penh, Kingdom of Cambodia. Email: info@apex-group-holdings.com. Phone: +855 15 688 668