ITR Consulting

Legal

Privacy Policy

ITR Consulting Limited (“ITR”, “we”, “us”) operates www.itrhk.com (the “Site”). This policy explains what personal data we collect, why we collect it, who we share it with, how long we keep it, and your rights under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”).

1. Who we are

ITR Consulting Limited, RM 611, 6/F, Fook Cheong Building, 63 Hoi Yuen Road, Kwun Tong, Hong Kong, is the data user (as defined in the PDPO) in respect of personal data collected through the Site.

2. What personal data we collect

Enquiry data: your name, email address, company, phone number, service of interest and message when you contact us through the website or by email. Company and phone are optional. Correspondence records: copies of emails and messages kept to handle and evidence your enquiry or engagement. Technical data: standard server and CDN logs, including IP address, browser and device type, pages visited and timestamps, used for security, abuse prevention and Site operation. We do not collect payment card data, government identifiers or special-category data through the Site.

3. Why we use it (purpose limitation)

We collect personal data for purposes directly related to our work as an IT services provider (PDPO Data Protection Principle 1): responding to enquiries; quoting for and delivering services; recruitment correspondence when you contact us about a role; keeping records required by law; and protecting the Site’s security and integrity. We do not use your data for unrelated purposes without your consent (DPP 3), and we do not sell personal data.

4. Who we share it with (processors)

We engage service providers who process data only on our instructions: Resend for transactional email delivery for website form submissions; Cloudflare for CDN, caching and the web application firewall in front of the Site; and our hosting provider for the servers that run the Site and store its logs. Beyond these processors, we disclose personal data only where required by law, regulation or court order.

5. Cross-border transfer

Some processors operate data centres outside Hong Kong. Where personal data leaves Hong Kong, we apply contractual and technical safeguards, including encryption in transit, processor obligations and least-privilege access. Section 33 of the PDPO (cross-border transfer restrictions) is not yet in force; we nonetheless apply its spirit when selecting processors.

6. How long we keep it (retention)

Enquiry and correspondence records are kept for as long as needed to handle your enquiry or engagement, plus any period required by applicable limitation periods or tax/company records law. Technical logs are kept for a limited period sufficient for security monitoring and incident investigation. Data no longer needed for these purposes is deleted or irreversibly anonymised.

7. Your rights under the PDPO

Access: you may request a copy of the personal data we hold about you (a data access request); a reasonable fee may be charged as permitted by the PDPO. Correction: you may ask us to correct inaccurate personal data. Information: you may ask what kinds of personal data we hold and for what purposes. Complaint: you may lodge a complaint with the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong. To exercise a right, email info@itrhk.com with “Privacy request” in the subject line. We will verify your identity before responding.

8. Security

We protect personal data with encryption in transit (TLS), access controls limited to staff and processors who need it, and routine review of the systems listed in section 4. No method of transmission or storage is 100% secure. If a data breach affecting you occurs, we will notify you and, where required, the PCPD.

9. Cookies and tracking

The Site sets no advertising or third-party tracking cookies. Our CDN and security layer may set strictly necessary cookies to keep the Site functioning and protected. We do not operate behavioural advertising pixels.

10. Children

Our services are directed at businesses and professionals. The Site is not intended for children, and we do not knowingly collect their personal data.

11. Changes and contact

We may update this policy; the current version is always published on this page with its review status. For privacy questions, access requests or corrections, email info@itrhk.com.