Privacy Policy
This Privacy Policy (the "Policy") explains how Win Forever Trustee Company Limited ("we", "us" or the "Company") collects, uses, stores, discloses and protects personal data when you access or use our website and related services. This Policy is formulated in accordance with the Personal Data (Privacy) Ordinance (Cap. 486 of the Laws of Hong Kong) ("PDPO") and other applicable laws and regulations.
Scope of Application and Personal Data We Collect
This Policy applies when you access or browse the Company's website; submit enquiries, contact information or business requests through the website; or communicate or exchange information with us in connection with a potential or actual business relationship. Submission of personal data or enquiries does not in itself constitute a client relationship; any trust or company services are provided only pursuant to a separate formal agreement. This Policy does not apply to personal data collected by third-party websites, platforms or services, even if linked to our website. Depending on the circumstances, we may collect identity and basic information (name, company name, position, nationality or identity-related information); contact information (email address, telephone number and correspondence address); business-related information (enquiry content, background information, documents or communication records); technical and usage information (IP address, browser type, access time, cookies and website usage logs); and legal and compliance information required for AML, CDD or other statutory obligations. If the relevant information is not provided, we may be unable to process your enquiry or provide corresponding services.
Purposes of Use of Personal Data
We use personal data only to the extent lawful, fair and necessary, primarily to respond to your enquiries or business requests; assess and handle potential or actual trust or company service arrangements; comply with applicable legal, regulatory and compliance obligations; improve website content, structure and user experience; internal compliance, audit, risk management and record-keeping; and handle complaints, disputes or legal matters. We will not use your personal data for purposes unrelated to the above without your consent, unless otherwise required by law or regulation.
Disclosure and Sharing of Personal Data
We disclose your personal data only where required to comply with applicable laws, regulatory requirements, court orders or requests from law enforcement authorities; where your explicit consent has been obtained; where disclosure is made to professional third-party service providers subject to confidentiality obligations (such as compliance consultants, auditors, legal advisers, IT or data hosting service providers) and only to the extent necessary for the provision of relevant services; or where disclosure is necessary to protect the lawful rights and interests of the Company, its clients or the public. We do not sell, rent or otherwise disclose personal data to unrelated third parties.
Use of Cookies
We may use cookies or similar technologies on our website to analyse website traffic, optimise functionality and enhance user experience. You may disable cookies through your browser settings, but this may affect the availability or functionality of certain features of the website.
Data Storage, Security and Retention
We adopt reasonable and industry-standard technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration or loss, including data encryption and access control, internal permission management and confidentiality policies, and periodic security reviews and compliance assessments. We also require our employees and entrusted service providers to comply with applicable confidentiality and data protection obligations. Personal data is generally stored in Hong Kong, or in jurisdictions that provide an adequate level of data protection. Unless otherwise required by applicable law, we retain personal data only for as long as necessary to fulfil the purposes for which it was collected; the retention period will not exceed seven (7) years or such other period as required under applicable legal or regulatory requirements.
Your Rights and Policy Updates
In accordance with the PDPO, you have the right to access personal data held by us relating to you; request correction of inaccurate or incomplete personal data; and enquire about the manner and purposes of our processing of personal data. You may submit such requests using the contact details set out below. We will respond within a reasonable period (generally not exceeding 30 days). To the extent permitted by law, we may charge a reasonable administrative fee for handling such requests and will inform you in advance where applicable. We may update this Policy from time to time to reflect changes in our business practices or applicable laws and regulations. The latest version will be published on our website, and continued use of the website after such updates constitutes acceptance of the updated Policy.
Contact Us
If you have any questions, requests or complaints regarding this Policy or our handling of personal data, please contact us at:
Win Forever Trustee Company Limited
Email: contact@trust.obita.xyz
If you believe that we have contravened the PDPO in handling your personal data, you also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong.