LEGAL

Privacy Policy

Last Updated: 28 March 2025 | Effective: 28 March 2025

Trevane Consulting Limited ("Trevane", "we", "us", "our") is committed to protecting the privacy of individuals who interact with our services and website. This Privacy Policy explains how we collect, use, store, and protect personal data in connection with our consulting services and this website.

This policy applies to all personal data we hold about current and prospective clients, website visitors, and individuals who contact us. By using our website or engaging our services, you acknowledge this policy.

1. Data Controller

The data controller for the purposes of this policy is:

Trevane Consulting Limited
13/F, 9 Queen's Road Central, Central, Hong Kong
Email: [email protected]
Phone: +852 3847 2596

2. What Personal Data We Collect

We collect personal data only where necessary for the purposes described in this policy. The categories of data we may collect include:

Name, job title, and organisation
Contact details: email address, telephone number, business address
Information you provide through our website contact form or by email
Correspondence and communications during an engagement
Technical data: IP address, browser type, pages visited, and session duration (via cookies and analytics tools)
Financial information necessary to invoice for services (where applicable)

3. How We Collect Personal Data

Personal data is collected through the following means:

Direct submissions via the website contact form
Email correspondence and telephone conversations
Engagement scoping and delivery activities
Cookies and analytics tools on our website (see Section 8)
Referrals from existing clients or professional contacts

4. Legal Basis for Processing

We process personal data on the following legal bases under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong:

Consent: Where you have provided explicit consent, such as submitting a contact form
Contract performance: Where processing is necessary to perform or prepare an engagement
Legitimate interests: Where we have a legitimate business interest, such as maintaining client communication records
Legal obligation: Where processing is required by applicable law

5. How We Use Personal Data

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

To respond to enquiries and provide information about our services
To scope, deliver, and follow up on consulting engagements
To issue and process invoices
To maintain records of client relationships
To improve our website and services using aggregated analytics
To comply with applicable legal and regulatory requirements

We do not use personal data for automated decision-making or profiling.

6. Data Retention

We retain personal data for the following periods:

Contact enquiries that do not result in an engagement: 12 months from last contact
Client engagement records: 7 years from the close of the engagement, in accordance with standard professional practice in Hong Kong
Financial records: 7 years, as required under the Companies Ordinance (Cap. 622)
Website analytics data: 26 months (standard Google Analytics retention)

7. Data Sharing

We do not sell personal data to third parties. Personal data may be shared in the following limited circumstances:

With service providers who process data on our behalf (e.g., email hosting, cloud storage) under appropriate data processing agreements
With professional advisers (e.g., lawyers, accountants) under obligations of confidentiality
Where required by law or by a regulatory authority in Hong Kong

Any third-party service providers are required to maintain appropriate data security standards consistent with this policy.

8. Cookies

Our website uses cookies to improve functionality and understand how visitors use the site. For detailed information on the cookies we use and how to manage your preferences, please see our Cookie Policy.

9. Data Security

We implement appropriate technical and organisational measures to protect personal data against unauthorised access, loss, or disclosure. These include:

Encrypted data transmission (HTTPS)
Access controls limiting data access to relevant personnel
Secure cloud storage with reputable providers
Regular review of our security practices

In the event of a data breach that poses a risk to individuals, we will notify affected parties and relevant authorities as required by applicable law.

10. Your Rights

Under the Personal Data (Privacy) Ordinance (Cap. 486), you have the following rights:

Right of access: To request a copy of the personal data we hold about you
Right of correction: To request correction of inaccurate personal data
Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time
Right to object: To object to processing for direct marketing purposes

To exercise any of these rights, contact us at [email protected]. We will respond within 40 days, as required by the Ordinance.

11. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those websites and encourage you to review their privacy policies independently.

12. Children's Privacy

Our services are directed at business professionals and organisations. We do not knowingly collect personal data from individuals under the age of 18. If you believe we have inadvertently collected such data, please contact us at [email protected] and we will delete it promptly.

13. Policy Updates

This policy may be updated periodically to reflect changes in our practices or legal requirements. The updated version will be posted on this page with a revised "Last Updated" date. Continued use of our website or services after a policy update constitutes acceptance of the revised policy.

14. Contact for Privacy Matters

For any questions, requests, or concerns regarding this Privacy Policy or our data handling practices, please contact:

Privacy contact: [email protected]
Address: 13/F, 9 Queen's Road Central, Central, Hong Kong

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (Hong Kong) if you believe your privacy rights have been violated: www.pcpd.org.hk