Privacy Policy

1. Introduction

Traverse Advisory ("we," "us," or "our") is committed to protecting the privacy of individuals who visit our website and engage with our business consulting services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you interact with our services.

We operate in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and are committed to maintaining the highest standards of data protection.

If you have questions about this policy or your personal data, please contact us at [email protected].

2. Information We Collect

2.1 Information You Provide

We collect information that you voluntarily provide when you:

Contact us through our website form (name, email address, phone number, and message content), request information about our services, enter into a consulting engagement with us, or communicate with us via email or telephone.

2.2 Information Collected Automatically

When you visit our website, we may automatically collect certain information about your device and browsing activity, including:

IP address and general location data, browser type and version, operating system, pages visited and time spent on pages, and referring website addresses. This information is collected through cookies and similar technologies as described in our Cookie Policy.

2.3 Client Engagement Information

For clients who engage our consulting services, we may collect additional information necessary for the provision of our services, including business documents, financial information, organisational data, and other materials relevant to the consulting engagement. This information is handled under separate confidentiality agreements.

3. How We Use Your Information

We use the information we collect for the following purposes:

Service Delivery: To respond to your inquiries, provide consulting services, and fulfil our contractual obligations to clients.

Communication: To send relevant information about our services, respond to questions, and maintain professional relationships.

Website Improvement: To analyse how visitors use our website and improve its functionality and content.

Legal Compliance: To comply with applicable laws, regulations, and legal processes.

Business Operations: To manage our business operations, including administrative and accounting purposes.

4. Legal Basis for Processing

We process your personal data on the following legal bases:

Consent: Where you have given clear consent for us to process your personal data for specific purposes, such as receiving communications from us.

Contract: Where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract.

Legitimate Interests: Where processing is necessary for our legitimate business interests, such as improving our services and website, provided these interests do not override your fundamental rights.

5. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information in the following circumstances:

Service Providers: We may share information with trusted third-party service providers who assist us in operating our website, conducting our business, or servicing you. These providers are bound by confidentiality obligations.

Legal Requirements: We may disclose information where required by law, court order, or government regulation, or where we believe disclosure is necessary to protect our rights or the safety of others.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction, subject to standard confidentiality requirements.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, alteration, disclosure, or destruction. These measures include:

Secure storage of electronic data with access controls, encryption of sensitive data in transit and at rest, regular security assessments and updates, staff training on data protection practices, and physical security measures for paper records.

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining industry-standard protections.

7. Data Retention

We retain personal information for as long as necessary to fulfil the purposes for which it was collected, including:

Contact form submissions are retained for 24 months unless you engage our services or request deletion. Client engagement records are retained for 7 years following completion of services in accordance with professional and legal requirements. Website analytics data is retained for 26 months in aggregated form.

When personal data is no longer required, we securely delete or anonymise it in accordance with our data retention procedures.

8. Cookies and Tracking Technologies

Our website uses cookies and similar tracking technologies to enhance your browsing experience and analyse website usage. Cookies are small text files stored on your device that help us recognise your browser and capture certain information.

For detailed information about the cookies we use and how to manage your preferences, please see our Cookie Policy.

9. Your Rights

Under the Personal Data (Privacy) Ordinance, you have the following rights regarding your personal data:

Right of Access: You may request access to the personal data we hold about you and obtain a copy of that data.

Right of Correction: You may request that we correct any personal data that is inaccurate or incomplete.

Right to Withdraw Consent: Where we process data based on your consent, you may withdraw that consent at any time.

Right to Object: You may object to the processing of your personal data for direct marketing purposes.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 40 days as required by Hong Kong law.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices or content of these external sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Children's Privacy

Our services are directed to businesses and professionals aged 18 and above. We do not knowingly collect personal information from individuals under the age of 18. If we become aware that we have collected personal data from a minor, we will take steps to delete that information.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. When we make material changes, we will update the "Last Updated" date at the top of this page. We encourage you to review this policy periodically.

13. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us:

14. Supervisory Authority

If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong: