Privacy Policy
Last updated: [Insert Date]
1. Introduction
Trivara Consulting Services ("Trivara", "we", "us", or "our"), of 3906, 39/F, The Center, 99 Queen's Road Central, Hong Kong, is committed to protecting the privacy of visitors to trivaraservices.com (the "Website") and the individuals we interact with in the course of our business. This Privacy Policy explains what personal data we collect, how we use it, and the rights available to you under applicable law, including Hong Kong's Personal Data (Privacy) Ordinance, Cap. 486 ("PDPO") and, where applicable, the EU General Data Protection Regulation ("GDPR").
We handle personal data in line with the PDPO's six Data Protection Principles, covering the purpose and manner of collection, accuracy and retention, use, security, openness about our policies, and your rights of access and correction.
2. Personal Data We Collect
We collect personal data that you provide directly to us, primarily through our Contact form. This may include:
- Your name
- Company name
- Email address
- The service you are enquiring about
- The content of your message
Providing this information is voluntary. However, if you do not provide your name, email address, and message, we will not be able to respond to your enquiry.
We do not knowingly collect sensitive personal data (such as health, biometric, or financial account information) through the Website.
Our hosting infrastructure may also automatically log basic technical information (such as IP address, browser type, and access times) for security and website-operation purposes. This is separate from the cookies described in Section 9 below.
3. How We Use Your Personal Data
We use the personal data we collect to:
- Respond to enquiries submitted through the Contact form
- Provide, discuss, and deliver our consulting services where you engage us
- Maintain records of our business communications and relationships
- Comply with applicable legal, regulatory, and accounting obligations
We do not sell personal data, and we do not use it for unsolicited marketing without your consent.
4. Legal Basis for Processing (GDPR)
Where the GDPR applies to our processing of your personal data (for example, because you are located in the European Economic Area), we rely on the following legal bases:
- Legitimate interests — responding to enquiries and maintaining business relationships
- Contractual necessity — where processing is required to perform a contract with you or your organisation
- Legal obligation — where we are required by law to process or retain certain information
5. Third-Party Service Providers
We use third-party service providers to help operate the Website and deliver our services, including:
- Resend — an email delivery service used to transmit Contact form submissions to our mailbox
These providers process personal data on our behalf and are contractually restricted from using it for any other purpose. Personal data submitted through the Contact form may be transmitted via servers located outside Hong Kong (including in the European Economic Area) as part of this email delivery process.
6. International Data Transfers
As we operate across Hong Kong, Europe, the Middle East, and Asia, personal data may be transferred to, stored, or processed in jurisdictions other than the one in which you are located. Where such transfers occur, we take reasonable steps to ensure personal data continues to be protected to a standard consistent with this Privacy Policy and applicable law.
7. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable legal, regulatory, or accounting obligations. Enquiry records that do not result in an engagement are typically retained for a limited period before being deleted.
8. Your Rights
Under the PDPO, you have the right to:
- Check whether we hold personal data about you and request access to it
- Request correction of inaccurate personal data
- Request that we cease using your personal data for direct marketing
We will respond to a data access or correction request within 40 days, as required by the PDPO. We may charge a reasonable fee to cover the cost of complying with a data access request. In certain circumstances specified under the PDPO, we may decline a request — where this applies, we will explain the reason.
If the GDPR applies to you, you additionally have the right to:
- Request erasure of your personal data
- Request restriction of processing
- Object to processing based on legitimate interests
- Request data portability
- Lodge a complaint with your local data protection supervisory authority
To exercise any of these rights, please contact us using the details in Section 11 below.
9. Cookies
The Website does not currently use cookies for analytics or marketing purposes. If this changes in the future, this Privacy Policy will be updated and, where required, a cookie consent mechanism will be implemented before any such cookies are set.
10. Data Security & Breach Notification
We take reasonable technical and organisational measures to protect personal data against unauthorised access, alteration, disclosure, or destruction. However, no method of electronic transmission or storage is completely secure, and we cannot guarantee absolute security. In the event of a data breach affecting your personal data, we will take reasonable steps to notify affected individuals and the PCPD in line with the PDPO's breach notification requirements.
11. Contact Us
If you have questions about this Privacy Policy or wish to exercise any of your rights, please contact us at:
Trivara Consulting Services
3906, 39/F, The Center, 99 Queen's Road Central, Hong Kong
info@trivaraservices.com
You also have the right to lodge a complaint with the Hong Kong Office of the Privacy Commissioner for Personal Data (PCPD), or, if the GDPR applies to you, with your local data protection supervisory authority.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Any changes will be posted on this page with an updated "Last updated" date.
