Privacy Notice

Cloudtrader Limited, trading as CloudTrader, is incorporated in Hong Kong. This notice explains how we handle personal data when you visit our website, contact us by email or communicate with us about our technology, advisory and programme services.

We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and its Data Protection Principles. If a particular engagement involves additional data collection or processing, we will provide the relevant information separately. This notice does not replace an engagement-specific collection statement or govern data handled independently by a third party.

Depending on how you interact with us, we may collect:

• Your name, business email address, company, role and any telephone number or other contact details you choose to provide.
• The content of your enquiries, correspondence and attachments, including information about a proposed or existing business engagement.
• Business contact information provided by your organisation or a person referring you to us, where they are authorised to share it.
• Technical information generated when you access the website, such as your IP address, browser and device information, pages requested, access times and security or error logs. Our hosting and delivery providers may process this information to operate and protect the website.

The website has no enquiry form or account-registration facility. You can contact us by email. Please do not send identity documents, payment-card details, passwords, health information or other sensitive personal data in an initial enquiry. Only provide another person's personal data if you are authorised to do so and have informed them of the relevant purpose.

We collect and use personal data only for purposes connected with our business communications and services, including:

• Responding to enquiries and arranging discussions.
• Assessing potential engagements and communicating about agreed services.
• Maintaining business correspondence and records needed to manage our relationships.
• Operating, maintaining and securing the website and our communications systems.
• Meeting applicable legal obligations, handling complaints and establishing, exercising or defending legal rights.

Providing information in an enquiry is voluntary. If you do not provide sufficient contact details or information about your request, we may be unable to respond or assess it. If information is required for a particular engagement, we will explain the requirement and the consequences of not providing it at the relevant time.

We will not use personal data for a new purpose unrelated to the original purpose of collection without your prescribed consent, unless otherwise permitted or required by law.

Access is limited to people and organisations who need the information for the purposes described in this notice. Depending on the circumstances, these may include:

• Authorised personnel responsible for handling your enquiry or engagement.
• Service providers supporting website hosting, email, IT, security and business administration, acting on our behalf.
• Professional advisers, such as legal advisers, accountants and auditors, where their involvement is necessary.
• Business or programme partners where sharing is necessary for an engagement you have requested and is consistent with the stated collection purpose. Additional information or consent will be sought where required.
• Courts, regulators, law-enforcement agencies or other parties where disclosure is required or permitted by law or necessary to establish, exercise or defend legal rights.

We do not sell personal data. Where a service provider processes personal data on our behalf, we use contractual or other appropriate measures to address confidentiality, security and retention.

Our website, email and other service providers may process or store information outside Hong Kong. The laws in those locations may differ from Hong Kong's privacy laws.

Where we arrange an overseas transfer, we take reasonable steps to ensure that the information receives appropriate protection, including contractual or other safeguards where appropriate, and comply with applicable requirements. You may contact us for information about the handling of your personal data.

The website uses essential technologies for its operation. It stores your cookie-notice choice in your browser's local storage under the name “ct-cookie-consent” so the notice does not appear on every visit. This preference is stored on your device rather than submitted through an enquiry form.

We have not configured optional analytics or advertising trackers for this website. Selecting “Accept” in the cookie notice does not currently activate an analytics service. If optional analytics are introduced, they will remain off until you accept, and this notice will be updated to explain their use.

The website loads fonts from Google Fonts. When your browser requests those fonts, Google receives technical information associated with the request, such as your IP address and browser information, under its own privacy policy. Website hosting and delivery providers may also process technical request data.

You can manage cookies and clear local storage through your browser settings. Blocking essential technologies may affect how the website works; clearing local storage will reset your cookie-notice choice.

An enquiry does not sign you up to a marketing list. We will not use your personal data for direct marketing unless we have provided the information and obtained the consent or indication of no objection required by Hong Kong law. We will not provide your personal data to another party for its direct marketing without the legally required consent.

If you receive direct marketing from us, you may ask us to stop at any time, without charge, by emailing contact@cloudtraderhk.com. This does not prevent correspondence needed to respond to a request, manage an engagement or meet legal obligations.

We retain personal data only for as long as necessary for the purpose for which it was collected or a directly related purpose, taking account of applicable legal, accounting and record-keeping requirements and the need to resolve disputes.

Retention periods depend on the nature of the enquiry, whether it leads to an engagement and any applicable obligations. When information is no longer required, we take practicable steps to delete it or anonymise it. Information in backups is subject to the relevant backup and deletion cycles and is not retained for unrelated use.

We take reasonably practicable steps to protect personal data against unauthorised or accidental access, processing, erasure, loss or use. Measures are proportionate to the nature of the information and may include access restrictions, appropriate technical safeguards and confidentiality requirements for personnel and service providers.

No website, email transmission or storage system is completely secure. Please avoid including sensitive information in ordinary email unless we have agreed an appropriate method of sharing it.

Under the Personal Data (Privacy) Ordinance, you may request confirmation of whether we hold your personal data, request access to that data and request correction of inaccurate data, subject to applicable exemptions. Please send requests to the contact below. We may need information to verify your identity or authority to act for someone else.

We will handle data access and correction requests within the statutory period, generally 40 days after receipt. If we cannot comply within that period or an exemption applies, we will provide the notice and reasons required by law. A fee for a data access request, if charged, will not exceed the costs of complying with the request.

You may also contact us about deletion, withdrawal of consent or another privacy concern. We will consider these requests in light of applicable law and any records we must retain. Withdrawal of consent does not affect processing already lawfully carried out and may affect our ability to continue an engagement.

If you are not satisfied with our handling of a privacy concern, you may contact the Office of the Privacy Commissioner for Personal Data, Hong Kong, at www.pcpd.org.hk.

Links to external websites and services are governed by those providers' own privacy notices. Where a third party handles personal data independently, including in connection with a programme engagement, its own collection statements and privacy terms apply to that handling.

We may update this notice to reflect changes in our practices or legal requirements. The date above identifies the latest version. Where a change requires additional notice or consent, we will take the appropriate steps before using personal data for the changed purpose.

For privacy enquiries, data access or correction requests, or complaints, please write to: