Privacy Policy

Introduction

Threnn ("we", "us", "our") is committed to handling personal data responsibly and transparently. This Privacy Policy sets out how we collect, use, store, and protect the personal information of individuals who contact us, engage with our services, or visit our website at thrennxx.world.

We operate under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO"). If you have questions about this policy, please contact us at [email protected].

1. Personal Data We Collect

We collect personal data in the following ways:

• Contact enquiries: Name, email address, phone number, and the content of your message when you contact us through our website form or by email.
• Engagement data: Business information, documents, and communications shared as part of a consulting engagement. This data is collected under a separate confidentiality agreement.
• Website usage: Technical data including IP address, browser type, pages visited, and visit duration, collected via analytics cookies (with consent).

We do not collect sensitive personal data (as defined under the PDPO) unless specifically required for an engagement and with your explicit consent.

Retention periods: Contact enquiry data is held for up to 24 months. Engagement data is deleted within 60 days of engagement completion unless retention is required by law or agreed in writing.

2. How We Use Your Personal Data

We use personal data for the following purposes:

• Responding to enquiries and scheduling initial consultations
• Delivering the agreed scope of consulting services
• Managing billing and engagement administration
• Improving our website and understanding how it is used (analytics, with consent)
• Complying with legal obligations

We do not use personal data for direct marketing without consent and do not sell personal data to any third party.

Legal basis: Processing is based on your consent (for enquiries), the performance of a contract (for engagements), and our legitimate interests (for website analytics and security). You may withdraw consent at any time.

3. Data Sharing

We do not share your personal data with third parties except in the following circumstances:

• Service providers: We may share limited data with trusted technology providers (e.g. email hosting, website analytics) who process data on our behalf under data processing agreements.
• Legal requirements: Where required by law, court order, or regulatory authority in Hong Kong.

Third-party services we may use include Google Analytics. We do not have referral or data-sharing arrangements with other advisory or commercial organisations.

4. Data Protection Measures

• Data transmitted via our website is encrypted using TLS/SSL
• Access to client data is restricted to the engagement team
• Engagement documents are stored in access-controlled environments
• Data breaches are reported to the Office of the Privacy Commissioner for Personal Data (PCPD) and affected individuals where required

5. Cookies

Our website uses cookies for functionality and analytics. Essential cookies are necessary for the site to operate. Analytics and preference cookies are only set with your consent. For full details, see our Cookie Policy.

6. Your Rights

Under the PDPO, you have the following rights:

• Access: Request a copy of personal data we hold about you
• Correction: Request correction of inaccurate data
• Erasure: Request deletion of personal data where there is no legal basis to retain it
• Objection: Object to processing for direct marketing
• Complaint: Lodge a complaint with the Office of the PCPD at pcpd.org.hk

To exercise any of these rights, please contact [email protected]. We will respond within 40 days as required under the PDPO.

7. Third-Party Links

Our website may contain links to external websites. We are not responsible for the privacy practices of those sites. We encourage you to review the privacy policies of any external services you visit.

8. Children's Privacy

Our services are directed at businesses and individuals aged 18 and over. We do not knowingly collect personal data from minors. If we become aware that data has been collected from a person under 18 without consent, we will delete it promptly.

9. Changes to This Policy

We may update this policy from time to time. Material changes will be notified via our website. Continued use of our services following an update constitutes acceptance of the revised policy.

10. Contact Information

For all privacy-related enquiries: