Privacy Policy & Personal Information Collection Statement

We only collect personal data that you choose to provide, namely when you submit an inquiry, request a quotation, register interest in our client portal, or otherwise correspond with us. This typically includes:

• Name, business name and job title.
• Business email address, telephone number and country.
• The contents of any message, RFQ or attachment you send us.
• Basic technical data such as IP address, browser type and pages visited, collected via essential cookies and standard server logs.

• To respond to your inquiry, prepare quotations and process orders.
• To carry out customer due-diligence, sanctions and KYC checks where required.
• To manage our trading relationship, contracts, shipping and after-sales matters.
• To comply with applicable laws, including Hong Kong tax, customs and anti-money-laundering rules.
• To keep our website secure and functioning correctly.

We will not use your personal data for direct marketing without first obtaining your consent, as required by Part VIA of the PDPO.

Your personal data may be disclosed, on a strict need-to-know basis, to:

• Our staff, professional advisers, auditors and bankers.
• Manufacturers, freight forwarders, customs brokers and inspection agents engaged to fulfil your order.
• Government, regulatory or law-enforcement bodies where we are legally required to do so.

Some recipients are located outside Hong Kong. Where data is transferred cross-border we take reasonable steps to ensure a comparable level of protection, consistent with the PDPO and PCPD guidance.

We retain personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by Hong Kong law (for example, accounting and tax records are kept for at least 7 years under the Inland Revenue Ordinance). Inquiry records are retained for up to 24 months unless an active commercial relationship exists.

We apply organisational and technical safeguards including access controls, encryption in transit (TLS), restricted staff access and confidentiality obligations on our service providers.

Under sections 18 and 22 of the PDPO and Data Protection Principle 6, you have the right to:

• Request access to the personal data we hold about you.
• Request correction of any inaccurate personal data.
• Be informed of the kinds of personal data we hold and our policies and practices regarding them.
• Withdraw any consent previously given for direct marketing.

We may charge a reasonable fee for complying with a data access request, as permitted by section 28 of the PDPO.

Our website uses a small number of strictly necessary cookies required for the site to function (for example, remembering that you have seen this notice). We do not currently set advertising or third-party tracking cookies. If this changes we will update this policy and request your consent through our cookie banner.

Requests, complaints and questions about this policy or about your personal data should be addressed to our Data Protection Officer:

Albacom Limited
Unit 10, 15/F, Wayson Commercial Building, 28 Connaught Road West, Hong Kong
info@albacom.com.hk

You may also lodge a complaint directly with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD) — www.pcpd.org.hk.