Privacy Policy

1. Introduction

This Privacy Policy describes how Hong Kong Huali International E-Commerce Limited, with its registered office at Rm 5 8/F MEGA CUBE, 8 WANG KWONG RD, Kowloon Bay, Hong Kong (HK), collects, uses, discloses, and protects personal information in connection with this website and the services we provide. The digital services presented on this website, including this website itself, are developed and operated by the developer HualiEcom on behalf of the company. We act with care and respect for the privacy of every visitor, client, and partner who interacts with us.

We are committed to handling your personal information openly, lawfully, and securely. This policy describes the categories of data we process, the reasons we process them, the choices available to you, and the ways you can reach us. It also explains how we keep your information safe and how we share it when we must. We encourage you to read this policy carefully before you share any information with us.

By accessing this website or using our services, you acknowledge the practices described below. If you do not agree with any part of this policy, please stop using our website and our services. This policy is a living document, and we review it regularly to keep it accurate and current as our services and the law evolve.

2. Information We Collect

We collect several categories of personal information depending on how you interact with us. The categories we most commonly handle are described below.

• Contact and identity information, such as your name, email address, telephone number, job title, company name, and country of residence, when you complete a form, write to us, or request a proposal.
• Business and project information, such as requirements, briefs, architecture documents, code samples, and other materials you share with us during an engagement.
• Technical information, such as your IP address, browser type and version, operating system, device identifiers, and the pages you visit on our website.
• Usage information, such as the dates and times of your visits, the pages you view, the links you follow, and the search terms you use within our website.
• Communication information, such as the content of your emails, messages, and support tickets, together with the metadata attached to them.

We collect some of this information directly from you, some automatically when you browse our website, and some from third parties, including business directories, professional networks, and publicly available sources. We only collect information that is relevant to the purposes described in this policy, and we do our best to limit collection to what we actually need.

We generally do not collect special categories of data, such as health information, racial or ethnic origin, or religious beliefs. In the unlikely event that you provide such information to us in the course of a project, we will only process it where you have clearly provided it to us and where we have a lawful basis to do so. We ask that you avoid sending us sensitive information unless it is genuinely necessary for the work you are requesting.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

• To provide and manage the services you request, including computer systems design, computer integrated systems design, development, integration, and ongoing support.
• To respond to your enquiries, prepare proposals, and maintain accurate records of our conversations and agreements.
• To operate and improve our website, including troubleshooting, analytics, and product and service development.
• To secure our website, systems, and data, and to detect, prevent, and investigate fraud or abuse.
• To comply with legal, regulatory, and accounting obligations that apply to our business.
• To send you updates, newsletters, or marketing materials when you have asked for them and where we have a lawful basis to do so.
• To support business administration, including invoicing, audits, insurance, and internal reporting.

We will not process your personal information in ways that are incompatible with the purposes described in this policy. Where we intend to use your information for a new purpose, we will consider whether the new purpose is compatible with the original one. Where necessary, we will update this policy, provide you with appropriate notice, and seek your consent before any new processing begins.

4. Legal Bases for Processing

We process personal information only where we have a lawful basis to do so. The main bases we rely on are described below.

• Performance of a contract, when we process information to deliver services that you have asked us to provide under an agreement with us.
• Legitimate interests, when we process information for purposes that are reasonable and that we have carefully weighed against your rights and interests, such as improving our website, securing our systems, and managing our business operations.
• Legal obligation, when we must process information to comply with laws, regulations, or court orders that apply to us.
• Consent, when you have given us clear permission to process your information for a specific purpose, such as receiving marketing communications.

Where we rely on legitimate interests, we carry out a balancing assessment to confirm that our interests do not override your rights and freedoms. Where we rely on consent, you may withdraw it at any time, and this will not affect the lawfulness of processing that took place before your withdrawal. If you would like to know more about the specific legal basis we rely on for any particular processing activity, please contact us using the details in the Contact Information section.

5. Cookies and Tracking Technologies

Our website uses cookies and similar technologies to remember your preferences, understand how visitors use the site, and improve your experience. Cookies are small text files that a website places on your device when you visit. They help the website function correctly and help us measure how our content is used.

• Strictly necessary cookies are required for the website to function, such as cookies that remember security choices or keep a session active.
• Preference cookies remember choices you make, such as your language or display settings, so that you do not have to make them again on every visit.
• Analytics cookies help us understand how visitors navigate the website, which pages are popular, and where visitors encounter problems, so that we can improve the site.

We do not use cookies to build advertising profiles of you without your consent, and we do not sell advertising based on your browsing behaviour. You can control cookies through your browser settings, which allow you to block or delete cookies and to be notified when a new cookie is set. If you disable certain cookies, parts of the website may not work correctly. Because the exact cookie settings vary between browsers, we encourage you to review the help section of your browser to learn how to manage cookies effectively.

6. How We Share Your Information

We do not sell your personal information to anyone. We share your personal information only in limited circumstances, and always with safeguards in place:

• With service providers who help us operate our business, such as hosting providers, analytics services, communication tools, and payment processors, and who process information only on our instructions.
• With professional advisers, including lawyers, accountants, and insurers, where necessary to protect our business, manage risk, or comply with our obligations.
• With business partners, where you have asked us to do so, or where sharing is necessary to deliver a service you have requested.
• With authorities or regulators, when we are required to do so by law, by a court order, or in response to a lawful request from a competent authority.
• In connection with a merger, acquisition, or sale of assets, where your information may be transferred as part of that transaction, and where we will require the receiving party to protect it to a standard consistent with this policy.

Before we share your information with any third party, we will confirm that the sharing is lawful and that appropriate safeguards are in place. Where a third party processes information on our behalf, we enter into a written agreement that sets out how the information must be handled and that requires the third party to protect it to a standard consistent with this policy.

7. International Data Transfers

Your personal information may be transferred to, and processed in, countries other than the one in which you are located. Our company is based in Hong Kong, and some of our service providers operate in other regions, including the United States, Singapore, and members of the European Economic Area. Cross-border transfers are a normal part of providing technology services in an international market.

When we transfer personal information across borders, we apply safeguards designed to protect it. These safeguards may include standard contractual clauses approved by the relevant authorities, binding contractual commitments from our providers, and technical measures such as encryption of data in transit. We will take reasonable steps to ensure that any party receiving your information abroad applies a level of protection that is consistent with the principles described in this policy.

If you would like a copy of the safeguards we rely on for a particular transfer, or details of the countries to which information may be sent, please contact us using the details in the Contact Information section.

8. Data Retention

We retain your personal information only for as long as necessary to fulfil the purposes described in this policy and to comply with legal, accounting, and regulatory requirements. The exact retention period depends on the type of information and the reason it was collected.

For example, contact details associated with an enquiry are typically kept for as long as the enquiry is active and for a reasonable period afterwards, so that we can respond to follow-up questions. Business records related to a delivered project are generally retained for the period required by applicable accounting and tax law, which may be several years. Records created to meet security and anti-fraud obligations are kept for the period needed to serve those purposes.

Where information is no longer needed, we will delete it, anonymise it, or otherwise restrict its use so that it can no longer be linked to you. We review our retention periods on a regular basis to ensure that we do not keep information for longer than is justified.

9. Data Security

We take the security of your personal information seriously and apply a range of technical and organisational measures to protect it. These measures include the following:

• Encryption of data in transit and at rest, using industry-standard protocols.
• Strict access controls that limit which members of our team can view personal information, based on the principle of least privilege.
• Regular security reviews of our systems, software, and processes to identify and address vulnerabilities.
• Secure storage for any physical records and secure procedures for their disposal.
• Ongoing training for our staff on data protection, information security, and privacy best practice.

We also maintain incident response procedures so that, in the unlikely event of a data breach, we can act quickly to limit harm, preserve evidence, and notify affected individuals and the relevant authorities where the law requires it. No method of transmission over the internet is completely secure, and we cannot guarantee the absolute security of information transmitted to us. However, we will do everything reasonably within our power to keep your information safe.

10. Your Privacy Rights

Depending on where you are located, you may have rights over your personal information. These rights may include the following:

• The right to access the personal information we hold about you and to receive a copy of it.
• The right to request the correction of information that is inaccurate or incomplete.
• The right to request the erasure of your information in certain circumstances, such as when it is no longer needed for the purposes for which it was collected.
• The right to restrict or object to the processing of your information in certain circumstances.
• The right to receive your information in a structured, machine-readable format and to ask us to transmit it to another controller, where this right applies.
• The right to withdraw consent at any time where we rely on consent as our legal basis.
• The right to lodge a complaint with a supervisory authority, in particular in the country where you live or work, or where an alleged infringement took place.

To exercise any of these rights, please contact us using the details in the Contact Information section. We will respond to verifiable requests within the time frame required by applicable law, usually within one month. We may need to verify your identity before processing your request, and we may ask you for information that helps us confirm that you are the person to whom the data relates. We will not charge you a fee for making a request, unless the request is clearly excessive or repetitive. Where we believe we cannot comply with a request, we will explain our reasons and, where appropriate, direct you to a supervisory authority.

11. Privacy for Children

Our website and services are directed to business audiences and are not designed for children. We do not knowingly collect personal information from children, and the services we offer are not intended for anyone under the age of sixteen.

If you believe that a child has provided us with personal information without the consent of a parent or guardian, please contact us using the details in the Contact Information section, and include as much information as you can so that we can locate the relevant records. If we learn that we have collected personal information from a child without appropriate consent, we will take steps to delete that information as quickly as possible and to prevent any further collection from that child.

12. Third-Party Links and Services

Our website may contain links to third-party websites, platforms, and services that are not operated by us. This policy does not apply to those third parties, and we are not responsible for the privacy practices of any website or service that we do not operate. When you follow a link to a third party, we encourage you to read the privacy policy of that third party to understand how it collects and uses information.

We may also embed tools or services provided by third parties, such as maps, payment processors, or analytics providers. Those third parties may process information in accordance with their own policies. We will take reasonable steps to ensure that any embedded service makes its practices visible to you and that any information collected through it is handled responsibly.

13. Automated Decision Making and Profiling

We do not use automated decision-making, including profiling, that produces legal or similarly significant effects on you. We may use automated tools for internal purposes, such as detecting anomalies, filtering spam, or maintaining the security and performance of our website, but these tools do not determine your eligibility for services and do not otherwise make decisions about you that would require human review.

If this practice changes, we will update this policy and, where required by law, provide you with information about the logic involved, the significance of the processing, and your right to request human intervention or to contest a decision. We will treat any future use of automated decision-making with care and will ensure that meaningful safeguards are in place before such processing begins.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our services, in technology, or in legal and regulatory requirements. When we make material changes, we will update the effective date at the top of this policy and take reasonable steps to bring the changes to your attention, such as displaying a notice on our website.

We encourage you to review this policy periodically so that you stay informed about how we protect your information. Your continued use of our website and services after changes take effect will indicate your acceptance of the updated policy. If we intend to use your personal information in a materially different way from that described at the time of collection, we will provide appropriate notice and, where required, obtain your consent before doing so.

15. Contact Information

If you have any questions, concerns, or requests about this Privacy Policy or about how we handle your personal information, please contact us using the details below. We will acknowledge your enquiry promptly and respond within the time frame required by applicable law.

Contact person: Zhang Shaofan
Email: service@hualiecom.mom
Telephone: +19804312558

If you are not satisfied with our response to a request, you may also contact the data protection authority in your jurisdiction, where one exists. We will cooperate with the relevant authority to resolve any dispute about how we process your information.