1. Overview and Scope
This Privacy Policy explains how the XINMAOTRADE website and the services offered through it collect, use, store and protect personal information. The services described on this site are developed and operated by the developer BillionYield on behalf of the company BILLION YIELD TRADING LIMITED, a trading and systems company registered in Hong Kong with its office at Rm A, 3/F, CHEONG SUN TWR, 116-118 WING LOK ST, Sheung Wan, Hong Kong (HK). This policy applies whenever you visit our website, send us a message, request a consultation or use any of the systems design, integration, data, platform, security or managed care services that we offer.
We have written this policy in plain language so that you understand exactly what happens to your information at every stage of your relationship with us. We respect your privacy and we design our practices around the principle that personal information should be collected only when there is a genuine reason to do so, should be used only for the purposes explained to you and should be protected with the same care that we apply to the trading systems we build for our clients.
This policy covers the website located at the domain xinmaotrade.hair, the contact channels associated with it, and the professional services that we deliver under the XINMAOTRADE name. Where a separate written agreement with a client covers a particular service, the terms of that agreement apply together with this policy. If there is any conflict, the specific agreement takes precedence to the extent permitted by law.
2. The Developer and Company
The XINMAOTRADE service is developed and operated by the developer BillionYield. The developer works under the authority of BILLION YIELD TRADING LIMITED, a company incorporated in Hong Kong with its registered office at Rm A, 3/F, CHEONG SUN TWR, 116-118 WING LOK ST, Sheung Wan, Hong Kong (HK). This company is the operator of the website and the provider of the services described on it.
When this policy refers to we, us or our, it means the developer and the company that operate the service together. When it refers to you, it means the person visiting the website, the person sending an enquiry or the client organisation that engages our services. Our contact details for privacy matters are listed at the end of this policy, and we welcome any question about how your information is handled.
The address Rm A, 3/F, CHEONG SUN TWR, 116-118 WING LOK ST, Sheung Wan, Hong Kong (HK) is our principal place of business. We operate primarily from Hong Kong, and we serve clients across the Asia Pacific region and beyond.
3. Information We Collect
We collect only the information that we need to run the website and to provide the services that you ask for. The categories of information we collect are described below.
- Contact information. When you send us a message through the contact form, we collect your name, your email address and the content of your message. If you choose to provide a subject line, we collect that as well.
- Enquiry details. When you request a consultation or a proposal, we collect the details of your enquiry, including information about your business and the systems you are interested in.
- Client information. When you become a client, we collect business contact details, billing information and the technical details needed to deliver our services.
- Technical information. When you visit the website, our servers and analytics tools may collect technical data such as your device type, browser type, operating system, approximate region and the pages you view.
- Correspondence. We keep records of our correspondence with you, including emails, phone calls and written messages, so that we can serve you consistently.
We do not collect more information than we need, and we never buy personal data from third party brokers. If you do not provide the information requested, we may not be able to respond to your enquiry or provide the service you want.
4. How We Collect Information
We collect information directly from you and automatically from your use of the website.
- Direct submission. You provide contact information and enquiry details when you fill in the contact form, write to us by email, call us or meet with us in person.
- Automated collection. When you browse the website, standard server logs and analytics tools collect technical information automatically, including your internet protocol address, the pages you visit and the actions you take.
- Cookies and similar technologies. We use cookies and similar technologies to remember your preferences, understand how the site is used and keep the site secure. Details are set out in the section on cookies.
- Referrals. If a colleague or partner introduces you to us, we may receive basic contact details from them with your consent.
- Public sources. We may collect limited business information about your organisation from public sources where this is relevant to a project.
We collect information lawfully and transparently. Where we rely on automated tools, we make sure they are configured to gather only what is necessary and to hold it only as long as it is useful.
5. How We Use Information
We use the information we collect for clear and limited purposes. The main purposes are set out below.
- To respond to your enquiries and provide you with information about our services.
- To prepare proposals, quotations and statements of work for your projects.
- To deliver the services you have engaged us to provide, including design, build, integration, security and managed care work.
- To manage our client relationship, including invoicing, billing, support and account administration.
- To operate, secure and improve the website, including diagnosing faults and defending against misuse.
- To comply with legal, regulatory and accounting obligations that apply to a company operating in Hong Kong.
- To send you service updates and notices that relate directly to our engagement with you.
We do not use your personal information for marketing unless you have asked us to, and we do not sell or rent personal information to anyone. Where we send updates, they concern the services you already use or have enquired about, and you can ask us to stop at any time.
6. Legal Bases for Processing
We process personal information only where we have a proper basis to do so. The bases we rely on are described below.
- Contract performance. Where we process information to deliver services you have engaged us to provide, the processing is necessary to perform our contract with you.
- Legitimate interests. Where we process information to run and secure our website, respond to enquiries and manage our business, we rely on our legitimate interests and the interests of our clients in receiving a professional service.
- Legal obligation. Where we are required by law to keep records, report to authorities or respond to lawful requests, the processing is necessary to comply with a legal obligation.
- Consent. Where we rely on consent for a specific processing activity, such as receiving marketing communications, we will ask for your consent clearly and you may withdraw it at any time.
When we rely on legitimate interests, we balance those interests against your rights and freedoms. We never pursue an interest that would override your fundamental privacy rights, and we document that balancing in our internal records.
7. Disclosure of Information
We keep your information within our organisation and our trusted service providers. We disclose personal information only in the circumstances described below.
- Service providers. We share information with providers that help us run the business, such as hosting, email, accounting and security services. Each provider is bound by contract to protect your information and use it only for our purposes.
- Professional advisers. We share information with legal, accounting and insurance advisers where this is necessary to advise and protect the business.
- Legal requirements. We disclose information when required by law, by a court order or by a regulator with proper authority, or where disclosure is necessary to protect the rights, property or safety of our clients, our staff or the public.
- Business transactions. If the business is sold, merged or reorganised, your information may be transferred to the successor organisation as part of the transaction, as described in the section on business transfers.
We do not disclose personal information to marketing companies, data brokers or other third parties for their own purposes. Where we are asked to disclose information by a third party, we verify the authority of the request first.
8. Data Storage and Retention
We store personal information on secure systems located in Hong Kong and, where our service providers are based overseas, in the regions where those providers operate. We retain personal information only as long as it is needed for the purposes described in this policy or as required by law.
Enquiry and contact information is kept for a reasonable period so that we can respond to follow up questions and maintain continuity of service. Client records are kept for the duration of our engagement and for a reasonable period afterwards to meet accounting, legal and audit requirements. Technical logs are retained for a limited time and are aggregated or deleted once they are no longer useful.
When information is no longer needed, we delete it or anonymise it so that it can no longer identify a person. We apply the same retention discipline to digital records, backups and any physical records we hold.
9. International Data Transfers
As a company serving clients across the region, we may use service providers whose systems are located outside Hong Kong. This means your information may be transferred to and processed in other countries, including jurisdictions whose data protection laws differ from those of Hong Kong.
Where information is transferred outside Hong Kong, we ensure that the transfer is protected by appropriate safeguards. This includes contracts with the receiving party that require standards of protection consistent with this policy, and verification that the recipient operates with a strong security posture.
If you are located in a jurisdiction with its own data transfer requirements, we will honour those requirements to the extent they apply to you. You can request details of the safeguards in place by contacting us at the address below.
10. Security Measures
Security is central to our work, because we build systems for firms where trust and availability are non negotiable. We apply the same standards to your personal information.
- Access control. Personal information is accessible only to staff and contractors who need it to perform their duties, on the principle of least privilege.
- Encryption. Data is encrypted in transit using secure protocols, and sensitive data at rest is protected with strong encryption.
- Monitoring. Our systems are monitored for unusual activity, and suspected incidents are investigated promptly.
- Testing. We review and test our security controls regularly, and we rehearse our response to incidents.
- Training. Our staff are trained on privacy and security obligations as part of their work.
No method of transmission or storage is completely infallible, and we cannot guarantee absolute security. However, we maintain controls that reflect the sensitivity of the data we hold and the expectations of the financial sector in which we operate. If we become aware of a security incident affecting your information, we will notify you and the relevant authorities as required by law.
11. Cookies and Similar Technologies
Our website uses small data files called cookies and similar technologies to make the site work properly and to understand how it is used.
- Strictly necessary cookies. These are required for the website to function, such as keeping your session secure. They cannot be switched off.
- Functional cookies. These remember your preferences and settings to improve your experience on the site.
- Analytics cookies. These help us understand which pages are visited and how the site is used, so we can improve it. The information is aggregated and does not identify you personally.
Most browsers let you control cookies through their settings. You can block or delete cookies, but doing so may affect how the website works for you. We do not use advertising cookies, and we do not share cookie data with advertising networks.
12. Your Rights and Choices
You have rights over the personal information we hold about you, and we will honour them. Depending on the jurisdiction in which you are located, your rights may include the following.
- Access. You can ask for a copy of the personal information we hold about you.
- Correction. You can ask us to correct information that is inaccurate or incomplete.
- Deletion. You can ask us to delete personal information where there is no lawful reason to keep it.
- Restriction. You can ask us to limit how we process your information in certain circumstances.
- Objection. You can object to processing based on legitimate interests.
- Portability. You can ask for your information in a structured, commonly used format where this applies.
- Withdrawal of consent. Where processing is based on consent, you can withdraw that consent at any time.
To exercise any of these rights, contact us using the details in the final section. We will respond within a reasonable time and normally within thirty days. We may ask you to verify your identity before acting on your request, and we may decline a request where the law permits us to do so.
13. Privacy for Children
Our website and services are directed at businesses and professionals in the computer systems and trading sectors. They are not directed at children, and we do not knowingly collect personal information from children under the age of sixteen.
If you believe that a child has provided us with personal information, please contact us immediately using the details at the end of this policy. We will take reasonable steps to delete the information from our records and to prevent any further collection.
We expect parents and guardians to supervise the online activity of children in their care and to ensure that children do not submit personal information to commercial websites without appropriate supervision.
14. Third Party Services
Our website and services may include links to third party websites, tools and platforms, such as email services, document sharing platforms and industry resources. These third parties operate independently and have their own privacy practices.
When you follow a link to a third party service, the privacy policy of that service applies to the information it collects from you. We encourage you to review the privacy policy of any third party service before you use it.
We are not responsible for the privacy practices of third party services that we do not control. This policy covers only the personal information that we collect and process ourselves.
15. Business Transfers
If BILLION YIELD TRADING LIMITED or the XINMAOTRADE service is involved in a merger, acquisition, restructuring or sale of assets, your personal information may be transferred as part of that transaction.
If a business transfer takes place, we will take reasonable steps to ensure that the recipient continues to protect your personal information in a manner consistent with this policy. We will update this policy or notify you if the identity of the data controller changes materially.
You will not be asked to consent to the transfer of your information for a purpose that is materially different from the purposes described in this policy without being given a fresh opportunity to object or consent.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, in the services we offer or in legal requirements.
When we make a significant change, we will update the date at the top of this policy and, where appropriate, notify you through the contact details we hold. The most current version of the policy will always be published on this page.
If you continue to use our website or services after a change takes effect, you will be treated as having accepted the updated policy. If you do not agree with a change, you may stop using the services and contact us to discuss your options.
17. Contact Us
If you have any question about this Privacy Policy, about the personal information we hold about you, or about the exercise of any of your rights, please contact us.
Company: BILLION YIELD TRADING LIMITED
Address: Rm A, 3/F, CHEONG SUN TWR, 116-118 WING LOK ST, Sheung Wan, Hong Kong (HK)
Email: hello@xinmaotrade.hair
Phone: +17243145625
We take every privacy concern seriously and we aim to resolve issues quickly and fairly. If you remain unsatisfied after contacting us, you may raise the matter with the applicable data protection authority in your jurisdiction.