AXIS Easy Prosper Limited: Data Protection Policy & Governance Framework
Effective Date: August 28, 2025
Policy Version: 1.0
Part 1: Foundational Principles & Governance
1.1. Policy Statement & Commitment
This Data Protection Policy & Governance Framework (the "Policy") outlines the principles and practices of AXIS Easy Prosper Limited (易發技有限公司) (Business Registration Number: 78669113), a private limited company registered in Hong Kong.1
This Policy defines the commitment of AXIS Easy Prosper Limited ("the Company") to the lawful, fair, and secure processing of Personal Data. It is designed to ensure full compliance with Hong Kong's Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO") 2 and to implement best practices in alignment with other applicable international data protection laws relevant to the Company's global Business-to-Business (B2B) Software-as-a-Service (SaaS) operations.1
This Policy governs all data processing activities undertaken by the Company, establishes clear roles and responsibilities, and serves as the foundational document for the AXIS Easy Prosper Limited Privacy Management Programme (PMP), as recommended by the Office of the Privacy Commissioner for Personal Data (PCPD).4
1.2. Definitions and Key Terms
This Policy relies on the following key definitions, which establish the legal boundaries of the Company's responsibilities:
· Data User: As defined in the PDPO, a person who, either alone or jointly or in common with other persons, controls the collection, holding, processing, or use of Personal Data.6 This role is equivalent to that of a "Data Controller" under regulations such as the EU's General Data Protection Regulation (GDPR).7
o Policy Application: In the context of the AXIS Easy Prosper Limited SaaS Platform, the Client (i.e., the global operator subscribing to AXIS Easy Prosper Limited services) is the Data User.
· Data Processor: As defined in the PDPO, a person who processes Personal Data on behalf of another person (the Data User) and does not process the data for any of their own purposes.9
o Policy Application: In the context of the AXIS Easy Prosper Limited SaaS Platform, AXIS Easy Prosper Limited is the Data Processor.11
· Personal Data: Any data relating directly or indirectly to a living individual from which it is practicable for the individual to be directly or indirectly identified, and which is in a form in which access to or processing of the data is practicable.6 This definition excludes data about legal entities but includes data pertaining to their individual employees.6
· PDPO: The Personal Data (Privacy) Ordinance (Cap. 486) of the Hong Kong Special Administrative Region, the primary legislation governing this Policy.2
· PCPD: The Office of the Privacy Commissioner for Personal Data, the statutory body in Hong Kong responsible for overseeing the enforcement of the PDPO.7
· Client Personal Data: Any Personal Data that AXIS Easy Prosper Limited processes on behalf of a Client (Data User) in the course of providing its B2B SaaS services.
· Company Personal Data: Any Personal Data for which AXIS Easy Prosper Limited acts as the Data User, such as data relating to its employees or its B2B Client contacts.
1.3. Application of Hong Kong’s 6 Data Protection Principles (DPPs)
This Policy is structured to ensure and demonstrate compliance with the six Data Protection Principles (DPPs) mandated by the PDPO.2
1. DPP 1 (Purpose and Manner of Collection): Data is collected lawfully and fairly for a purpose directly related to the Data User's functions.
2. DPP 2 (Accuracy and Duration of Retention): Data is kept accurate and for no longer than is necessary to fulfill the purpose of its use.
3. DPP 3 (Use of Personal Data): Data is not used for any purpose other than its original purpose, unless with consent.
4. DPP 4 (Security of Personal Data): All practicable steps are taken to ensure data security.
5. DPP 5 (Information to be Generally Available): Openness about data policies and practices is maintained.
6. DPP 6 (Access to Personal Data): Data subjects have the right to access and correct their data.
The PDPO's regulatory framework for Data Processors is primarily indirect. It places a legal obligation on the Data User (the Client) to adopt "contractual or other means" to bind its Data Processor (AXIS Easy Prosper Limited) to comply with DPP 2 (Retention) and DPP 4 (Security).9
This Policy is specifically structured to address these obligations. Part 4 (Data Security) and Part 5 (Data Retention) of this document are designed to serve as the contractual assurance and evidence that AXIS Easy Prosper Limited provides to its Clients, thereby enabling Clients to satisfy their own legal due diligence requirements under the PDPO. This proactive framework is intended to build Client trust and accelerate procurement by demonstrating verifiable compliance.16
Part 2: Data Protection Roles & Responsibilities
2.1. AXIS Easy Prosper Limited as a Data Processor (Primary Role)
This section governs all activities related to the AXIS Easy Prosper Limited AI-First Slots & Games Aggregator platform.1 In this primary role, AXIS Easy Prosper Limited:
· Processes Client Personal Data only on the basis of, and in accordance with, the documented instructions of the Client (Data User).17
· Clarifies that the processing of Client Personal Data is limited to pseudonymous identifiers (e.g., player_id) and associated transactional data (e.g., bet amounts). This data is processed solely on behalf of the Client (Data User), and AXIS Easy Prosper Limited does not process directly identifying information (such as names or addresses) of end-users.
· Does not control the purposes or means of processing; these are determined entirely by the Client.8
· Confirms that it operates as a B2B SaaS provider and has no direct relationship with the end-users (i.e., the players).1
· Contractually commits to fulfilling all Processor-specific obligations outlined in this Policy, including those related to security (Part 4), retention (Part 5), sub-processing (Part 7), and assistance (Part 8).
· Is prohibited from using Client Personal Data for any purpose other than providing and maintaining the contracted SaaS services, as detailed in the Master Services Agreement (MSA) and Data Processing Agreement (DPA).20
2.2. AXIS Easy Prosper Limited as a Data User (Secondary Role)
AXIS Easy Prosper Limited acts as a Data User (Controller) only in the following limited and specific circumstances 8:
1. Employee & Contractor Data: Processing the Personal Data of its 20 dedicated staff members and any associated contractors for human resources, payroll, and administrative purposes.1
2. B2B Client & Partner Contact Data: Processing the business contact information (e.g., names, business emails, business phone numbers, titles) of individuals at its Operator Clients and Game Provider Partners.1 This processing is for the limited purposes of contract management, billing, platform support, and managing the B2B commercial relationship.
For this Company Personal Data only, AXIS Easy Prosper Limited assumes all legal responsibilities of a Data User under the six DPPs of the PDPO.
2.3. Appointment and Responsibilities of the Data Protection Officer (DPO)
While the PDPO does not currently include a mandatory requirement to appoint a Data Protection Officer (DPO) 4, the PCPD strongly encourages the appointment of a responsible person to oversee compliance as part of a best-practice Privacy Management Programme (PMP).4
Furthermore, the business model of AXIS Easy Prosper Limited is "exclusively for export to international markets" 1, including key regions such as LATAM.1 The data protection laws of these target markets, such as Brazil's Lei Geral de Proteção de Dados (LGPD), have extraterritorial scope and do mandate the appointment of a DPO.23
Therefore, as a strategic compliance measure to satisfy the due diligence requirements of its international Clients and remove a significant procurement obstacle 16, AXIS Easy Prosper Limited has appointed a Data Protection Officer.
The DPO's responsibilities include:
· Acting as the primary point of contact for the PCPD 25 and other international data protection authorities (e.g., Brazil's ANPD).
· Monitoring the Company's compliance with this Policy and all relevant data protection laws.
· Advising on Data Protection Impact Assessments (DPIAs) for new platform features, particularly those involving new AI processing functions.
· Managing and overseeing the procedures for Data Subject Access Request (DSAR) Assistance (Part 8.1) and the Incident Response Protocol (Part 8.2).
· Coordinating and overseeing data protection training for all employees.
Part 3: Data Processing Operations (Processor Capacity)
3.1. Processing Solely on Data User (Client) Instructions
As a Data Processor, AXIS Easy Prosper Limited shall process Client Personal Data only in accordance with the documented instructions of the Client (Data User). These instructions are primarily set forth in the Master Services Agreement (MSA) and its associated Data Processing Agreement (DPA).17
The subject matter, duration, nature, and purpose of processing are determined by the Client. AXIS Easy Prosper Limited's role is to provide the cloud-based platform and technical capabilities (including AI functions) to execute these instructions.1 If AXIS Easy Prosper Limited is ever required by Hong Kong law to process data in a manner that deviates from the Client's instructions, AXIS Easy Prosper Limited will notify the Client in writing prior to processing, unless such notification is prohibited by law.
3.2. Categories of Personal Data Processed on Behalf of Clients
The AXIS Easy Prosper Limited platform is designed to process the following categories of Personal Data. The specific data processed at any time is determined and controlled by the Client (Data User).27 In line with the Company's AML/CTF policy, AXIS Easy Prosper Limited does not conduct KYC on end-users; this obligation remains with the Client (Data User).73 The data processed by AXIS Easy Prosper Limited is limited to:
· 3.2.1. Client-Managed Player Data: Data provided by the Client (Data User) from their end-users and processed by the AXIS Easy Prosper Limited AI platform.1 This is limited to:
o Pseudonymous Identifier: A unique player_id provided by the Client.
o Transactional & Gameplay Data: Data related to end-user activity, such as bet amounts, game telemetry, gameplay patterns, and in-game options selected.46 This data is processed to generate analytics and predict user preferences as instructed by the Client.1
· 3.2.2. Categories of Data Subjects: The Data Subjects are determined and controlled by the Client, and consist entirely of the Client's end-users (i.e., players).
3.3. Limitation of Purpose and Use (Fulfilling DPP 3)
In accordance with PDPO DPP 3, AXIS Easy Prosper Limited is contractually and legally bound to use Client Personal Data only for the purposes defined by the Client.2
· Permitted Purposes (as Processor):
1. Providing the SaaS game aggregation service and related technical support.1
2. Executing Client-directed AI functions, described as "automate integrations," "predict user preferences," "generate custom thumbnails," and "streamline backend operations".1
3. Storing, securing, encrypting, and backing up data per the Client's instructions.
· Prohibited Purposes:
o Client Personal Data will not be sold, leased, or rented.
o Client Personal Data will not be used for AXIS Easy Prosper Limited's own independent commercial purposes, such as product improvement or analytics, unless it has first been fully and irreversibly anonymized (see Part 5.3).20
Part 4: Data Security Framework (Fulfilling DPP 4)
4.1. The "Practicable Steps" Mandate
In accordance with PDPO DPP 4, AXIS Easy Prosper Limited commits to taking "all practicable steps" to protect Client Personal Data against unauthorized or accidental access, processing, erasure, loss, or use.15
As a Data Processor, AXIS Easy Prosper Limited acknowledges its contractual obligation to the Client (Data User) to implement and maintain a robust, comprehensive security program.9 The "practicable steps" implemented are proportionate to the sensitivity of the data (e.g., pseudonymous player_id data) and the potential harm that could result from a breach.29
4.2. Annex A: Schedule of Technical and Organizational Measures (TOMs)
AXIS Easy Prosper Limited maintains a detailed, non-exhaustive schedule of Technical and Organizational Measures (TOMs) which is provided to Clients as part of the DPA. This schedule serves as the auditable evidence of DPP 4 compliance. The TOMs include, but are not limited to:
· 4.2.1. Physical and Environmental Security: 31
o Securing all office premises for AXIS Easy Prosper Limited staff.
o Ensuring that all cloud sub-processors provide certified, secure data center environments with measures to prevent uncontrolled physical access.
· 4.2.2. System Access and Authentication Controls: 31
o Role-Based Access Control (RBAC): Access to Client Personal Data is strictly limited to authorized AXIS Easy Prosper Limited personnel on a "need-to-know" basis.
o Multi-Factor Authentication (MFA): Mandatory MFA is enforced for all personnel (including all 20 staff members 1) accessing production environments or sensitive data stores.20
o Access Logging: All access to production systems and databases is logged and monitored for unauthorized activity.31
· 4.2.3. Data Encryption: 31
o Data at Rest: All production databases and file storage are encrypted using robust, industry-standard algorithms (e.g., AES-256).20
o Data in Transit: All data transmitted over public networks (e.g., API calls, client dashboard access) is encrypted using industry-standard protocols (e.g., TLS 1.3 or higher).20
· 4.2.4. Network Security and Vulnerability Management:
o Implementation of firewalls, intrusion detection/prevention systems (IDS/IPS), and anti-malware protections.33
o Regular, automated vulnerability scanning of all internal and external-facing systems.33
o Periodic third-party penetration testing.
o A formal patch management process with defined timelines (e.g., 72 hours for critical) for remediating identified vulnerabilities.20
· 4.2.5. Human Resources Security: 34
o Mandatory data protection and security awareness training for all employees upon hiring and at least annually.
o All employees and contractors are bound by comprehensive confidentiality agreements.
· 4.2.6. Secure Development & Operations:
o Implementation of "Privacy by Design" principles within the Company's agile development methodology.1
o Strict segregation of development, testing, and production environments.
o Centralized security logging with a minimum 12-month retention for audit and forensic purposes.20
4.3. Cloud Platform and SaaS Architecture Security
As a "cloud-based platform" 1, AXIS Easy Prosper Limited implements security controls specific to its SaaS architecture:
· Data Isolation: The platform is built on a robust multi-tenant architecture that ensures each Client's data is logically and securely isolated from all other Clients, preventing co-mingling or unauthorized access.16
· Cloud Provider Compliance: AXIS Easy Prosper Limited, as detailed in Part 7, ensures its cloud infrastructure sub-processors (e.g., AWS, Google Cloud, Azure) maintain their own independent, third-party compliance certifications (e.g., SOC 2 Type II, ISO 27001).20
· PCPD Cloud Guidance: AXIS Easy Prosper Limited's security controls, particularly its mandatory patch management and staff training programs, are designed to prevent the types of failures identified in recent PCPD enforcement actions, such as the use of "outdated software" or a "lack of understanding" of platform security functions.36
This detailed TOMs schedule is not only a legal requirement but a commercial asset. It is designed to act as a pre-prepared "Vendor Security Questionnaire" to satisfy the rigorous due diligence 16 that Clients (as Data Users) are required to perform under PDPO DPP 4.9 This transparency accelerates the Client's procurement process by transforming a compliance bottleneck into a demonstration of AXIS Easy Prosper Limited's maturity.
Part 5: Data Retention, Erasure, and Anonymization (Fulfilling DPP 2)
5.1. Processor Retention Obligations (Deletion/Return of Client Data)
In accordance with PDPO DPP 2, AXIS Easy Prosper Limited must take all practicable steps to ensure that Personal Data is "not kept longer than is necessary" for the fulfillment of the purpose for which it is used.10
As a Data Processor, the "purpose" and "necessity" of retention are defined by the Client (Data User). Therefore, AXIS Easy Prosper Limited shall:
· Retain Client Personal Data only for the duration specified by the Client in the DPA or as configured by the Client within the SaaS platform.
· Upon termination of the service contract, and at the Client's choice, securely delete or return all Client Personal Data (including all copies) within a defined period (e.g., 90 days), unless retention is required by Hong Kong law.8
· Provide Clients with the technical capability (e.g., platform tools and APIs) to enforce their own retention policies.40
5.2. Retention Schedules for Company-Held Data
This section addresses data for which AXIS Easy Prosper Limited is the Data User (see Section 2.2). To comply with DPP 2 (Retention) 37 and DPP 5 (Openness) 14, AXIS Easy Prosper Limited has established the following purpose-based retention schedule.41
Data Category
Purpose of Processing
Retention Period
Legal Basis (PDPO)
Employee & HR Records
Employment contract, payroll, legal obligations
5 years after termination of employment
Contractual Necessity / Legal Obligation
Unsuccessful Job Applications
Recruitment processing
12 months after application date
Consent / Legitimate Interest
B2B Client/Partner Contacts
Contract mgt, billing, B2B marketing
5 years after termination of business relationship
Legitimate Interest / Legal Obligation
Financial/Invoice Records
Tax and corporate record-keeping
7 years (as required by HK law)
Legal Obligation
System/Security Logs
Security, auditing, threat detection
12 months (rolling)
Legitimate Interest / DPP 4
5.3. Anonymization Protocols for AI and Analytics Data
This clause is essential for AXIS Easy Prosper Limited's "AI-First" business model.1 To comply with data minimization and retention limitation principles (DPP 2) 37 while simultaneously improving its AI models 45, AXIS Easy Prosper Limited adheres to the following protocol:
1. Client Personal Data (such as player behavior and gameplay patterns 46) is processed by the AI only for the benefit of the specific Client who is the Data User for that data.
2. AXIS Easy Prosper Limited may anonymize Client Personal Data, removing all identifiers and data points that could link the data to a living individual, in accordance with PCPD guidance.10
3. This resulting anonymized, aggregated data 48 is, by definition, no longer "Personal Data" under the PDPO.6
4. AXIS Easy Prosper Limited retains the right to use this anonymized and aggregated data indefinitely for the sole purposes of platform improvement, training its predictive AI models, and generating aggregate industry analytics. This anonymized data is the "fuel" that allows AXIS Easy Prosper Limited to maintain its innovative edge and is a core part of the service's value.
Part 6: International Data Transfers & Global Compliance
6.1. Hong Kong Cross-Border Transfer Framework
AXIS Easy Prosper Limited operates "exclusively for export to international markets".1 This entire section is fundamental to its business model.
· PDPO Section 33 Status: AXIS Easy Prosper Limited acknowledges that Section 33 of the PDPO, which contains provisions to restrict cross-border data transfers, is not yet in force. As of the date of this policy, no timetable for its implementation has been announced.49
· PCPD Best Practice: Notwithstanding that Section 33 is not in force, the PCPD recommends that data users exercise due diligence and adopt safeguards when transferring data internationally.50
· AXIS Easy Prosper Limited Commitment: To demonstrate "due diligence" 52 and, more importantly, to enable its international clients to use its services, AXIS Easy Prosper Limited voluntarily adopts the principles of the PCPD's Recommended Model Contractual Clauses (RMCs).49 These clauses will be incorporated into its DPAs with Clients (for data inflows) and its contracts with Sub-Processors (for data outflows) to ensure a "substantially similar" 54 level of protection is maintained.
6.2. Data Processing and Transfers in Target Markets (CIS, LATAM, SEA, Africa)
The AXIS Easy Prosper Limited platform is designed to serve clients in the CIS, LATAM, and SEA regions.1 This requires a sophisticated approach to extraterritorial compliance.
· CIS (Commonwealth of Independent States): This region does not have a single overarching data protection law.55 Compliance is managed based on national laws (e.g., in Russia, Belarus, Kazakhstan 56) and governed by the contractual DPA.
· LATAM (Latin America): The key jurisdiction is Brazil, which is governed by the Lei Geral de Proteção de Dados (LGPD).58
· SEA (Southeast Asia): Key jurisdictions include Thailand (governed by the PDPA) 61 and Thailand (governed by its PDPA).62
6.3. Compliance Protocols for Extraterritorial Laws (Processor's Role)
The primary compliance challenge for AXIS Easy Prosper Limited's export-only model 1 is not Hong Kong's S33 (which is not in force 51), but the Client-side laws. A Client in Brazil, for example, is governed by the LGPD 59 and requires a lawful basis to transfer its user data to AXIS Easy Prosper Limited in Hong Kong.
AXIS Easy Prosper Limited's policy is designed to proactively provide the legal mechanisms to enable its Clients to make these transfers lawfully under their own home-country regulations. AXIS Easy Prosper Limited, as a Data Processor, contractually commits to the following safeguards:
Jurisdiction
Key Law
Extraterritorial Trigger
AXIS Easy Prosper Limited Commitment (as Processor) to Enable Lawful Transfer
Brazil (LATAM)
LGPD 58
Offering services to individuals in Brazil 23
AXIS Easy Prosper Limited provides "sufficient guarantees" 64 by:
1. Appointing a DPO (a requirement under LGPD Art. 41) 23 (see Sec 2.3).
2. Entering into Contractual Clauses that provide adequate protection, per LGPD (Art. 33).65
3. Committing to assist the Client with DSARs (LGPD Art. 18) 60 and incident notification.65
Thailand (SEA)
PDPA 62
Offering services to individuals in Thailand (extraterritorial).62
AXIS Easy Prosper Limited provides "adequate protection" by:
1. Entering into a DPA with contractual clauses ensuring data protection.
2. Committing to assist the Client with its obligations regarding data subject rights (e.g., access, erasure).63
3. Committing to robust security and breach notification.63
Part 7: Sub-Processor Management
7.1. Due Diligence and Selection of Sub-Processors
AXIS Easy Prosper Limited, as a Data Processor, may engage third-party sub-processors (e.g., cloud infrastructure providers 35, data analytics services 30) to support the delivery of its SaaS platform.
AXIS Easy Prosper Limited commits to conducting robust due diligence on all potential sub-processors to ensure they provide "sufficient guarantees to implement appropriate technical and organisational measures" 64 at a standard at least as protective as those outlined in this Policy.
7.2. Contractual Requirements and Client Authorization
AXIS Easy Prosper Limited shall not engage any sub-processor to process Client Personal Data without the "prior specific or general written authorisation" of the Client (Data User).64
· As part of the DPA, AXIS Easy Prosper Limited will provide Clients with a list of its current sub-processors.
· AXIS Easy Prosper Limited will provide Clients with prior written notice of any intended changes or additions to this list, giving the Client a reasonable opportunity to object.
· AXIS Easy Prosper Limited will enter into a written DPA with each sub-processor, imposing data protection obligations that are "substantially similar" 49 to those contained in the Client-AXIS Easy Prosper Limited DPA.
· AXIS Easy Prosper Limited remains fully liable to the Client for any act or omission of its sub-processors as if they were the acts or omissions of AXIS Easy Prosper Limited itself.17
Part 8: Data Subject Rights & Incident Management
8.1. Procedure for Assisting Data Users (Clients) with Data Subject Access Requests (DSARs)
· Processor's Role: AXIS Easy Prosper Limited, as a Data Processor, does not have a direct relationship with the end-users (players). Therefore, AXIS Easy Prosper Limited will not respond directly to any DSARs (e.g., requests for access, correction, deletion under PDPO DPP 6 28 or other laws) received from end-users.71
· Referral Procedure: If AXIS Easy Prosper Limited receives a DSAR from an end-user, it will "not respond... except on the documented instructions of Controller".71 AXIS Easy Prosper Limited will promptly forward the request to the relevant Client (Data User) for their action.
· Duty of Assistance: AXIS Easy Prosper Limited has a legal and contractual duty to assist the Client (Data User) in fulfilling its obligation to respond to DSARs.8 This assistance includes:
o Providing technical tools within the platform (e.g., search, extraction, and deletion APIs) to help the Client locate, manage, and erase their end-users' data as required.72
o Providing reasonable support to the Client upon their documented request.
8.2. Data Breach Response Protocol (Processor's Duty to Notify Data User)
· HK Law vs. Contractual Duty: While the PDPO currently has no mandatory data breach notification regime 21, AXIS Easy Prosper Limited has a contractual duty to its Client (Data User). This duty is also a legal requirement in the Client's own jurisdiction (e.g., under GDPR or LGPD 65).
· Notification to Client: Upon becoming aware of a security incident affecting Client Personal Data, AXIS Easy Prosper Limited will notify the Client (Data User) "without undue delay".8
· Content of Notification: The notification will, at a minimum, describe 20:
1. The nature of the breach.
2. The categories and approximate number of Data Subjects and data records affected.
3. The likely consequences of the breach.
4. The remediation measures taken or planned by AXIS Easy Prosper Limited.
· Duty of Assistance: AXIS Easy Prosper Limited will provide the Client with all necessary information and cooperation to enable the Client to meet their own breach notification obligations to regulators (e.g., PCPD, ANPD 65) and Data Subjects.8
Part 9: Policy Review and Contact Information
9.1. Policy Review, Training, and Auditing
· Review: This Policy shall be reviewed at least annually, or upon any significant change to the PDPO, other relevant laws, or AXIS Easy Prosper Limited's business operations.
· Training: All AXIS Easy Prosper Limited employees and contractors will receive mandatory training on this Policy and their specific data protection responsibilities upon hiring and at least annually thereafter.34
· Auditing: AXIS Easy Prosper Limited will conduct regular internal audits of its data protection practices. AXIS Easy Prosper Limited will also make available to the Client (under an NDA) all information necessary to demonstrate compliance with its DPA obligations, including cooperating with reasonable audits as required by law.8
9.2. Contact Details for the Data Protection Officer
For any inquiries, concerns, or requests from Clients, partners, or regulators related to this Policy or the processing of Personal Data, please contact our Data Protection Officer (DPO).4 This provides a clear point of contact as recommended by the PCPD.25
· By Email:
privacy@axiseasyprosper.com
· By Post:
Data Protection Officer
AXIS Easy Prosper Limited (易發技有限公司)
Company Information
Business Registration Number: 78669113
Company Name: AXIS Easy Prosper Limited (易發技有限公司)
Company Address: Unit S-V, R18, 6/F, Valiant Industrial Centre, Nos 2-12 Au Pui Wan Street, Fo Tan, Hong Kong
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