Privacy Policy

POTIS GROUP LIMITED · Rm 1002 10/F EASEY COML BLDG, 253-261 HENNESSY RD, Wan Chai, Hong Kong

Contents of this Policy

  1. Introduction and Identity of the Developer
  2. Scope of this Privacy Policy
  3. Information We Collect
  4. How We Obtain Information
  5. Purposes of Processing
  6. Lawful Basis for Processing
  7. Cookies and Similar Technologies
  8. Analytics and Measurement
  9. How We Share Information
  10. Service Providers and Processors
  11. Cross Border Transfers
  12. Retention of Records
  13. Security of Personal Data
  14. Your Rights and Choices
  15. Marketing Communications
  16. Privacy for Children
  17. Third Party Links and Services
  18. Changes to this Policy
  19. How to Contact Us
  20. Governing Law and Jurisdiction

1. Introduction and Identity of the Developer

This Privacy Policy explains how personal data is collected, used, stored and protected by POTIS GROUP LIMITED, the developer and operator of this website and of the chamber services described on it. POTIS GROUP LIMITED is a Hong Kong company whose registered office is at Rm 1002 10/F EASEY COML BLDG, 253-261 HENNESSY RD, Wan Chai, Hong Kong. In this document the words we, us, our and the Company refer to POTIS GROUP LIMITED, and the words you and your refer to any person who visits this website, writes to the chamber desk, calls our telephone line or otherwise engages with the chamber.

POTIS GROUP LIMITED takes the privacy of every visitor and every venture seriously. We are a chamber of ventures that keeps counsel, seals accounts and chairs companies, and the trust placed in us by founders, directors, staff and counterparties depends on our handling of information being careful, lawful and transparent. This Policy sets out in plain language what we do with personal data, why we do it, how long we keep it and what choices you have.

This website is informational. It describes the holding structure design, cross company accounting, compliance and filings, shared service desk, venture board reporting and treasury coordination services offered by the Company. We do not sell goods on this website, and we do not operate a customer account system here. The personal data we hold is therefore limited to what is needed to respond to enquiries, to seat ventures at the chamber and to carry out the professional work that has been agreed with those ventures.

2. Scope of this Privacy Policy

This Policy applies to personal data processed through this website at www.potisgroup.lat, through the chamber desk email address info@potisgroup.lat, through the chamber telephone line +85259464806 and through the professional engagements that POTIS GROUP LIMITED accepts with the ventures it seats.

This Policy does not apply to websites operated by third parties, even where we provide a link to them. It also does not apply to the internal records of a venture that has its own independent privacy obligations, except where we process that information on the instructions of that venture as a service provider. Where we act on instructions, the venture remains responsible for the lawfulness of the instructions it gives us.

By using this website or contacting the chamber desk, you acknowledge that you have read this Policy and understand how your personal data will be handled. If you do not agree with any part of this Policy, you should not submit personal data to us through the website or by email, although you are of course free to read the public pages of the site without providing any information at all.

3. Information We Collect

The categories of personal data that we may collect are set out below. We collect only what is reasonably necessary for the purpose at hand, and we do not set out to gather information that we have no use for.

  • Identity data such as your full name, the organisation you represent and your role or title.
  • Contact data such as your email address, telephone number, postal address and any preferred method of contact.
  • Enquiry data such as the subject and content of messages sent to the chamber desk, including any attachments you choose to provide.
  • Engagement data such as the names of companies in a venture group, shareholding information, director and officer details and the correspondence connected with a professional engagement.
  • Financial data such as invoicing details, payment references and accounting records connected with a venture that we serve.
  • Technical data such as the internet protocol address from which a request is made, the browser and device type, the pages viewed and the time of the visit, collected in server logs.
  • Communications data such as records of calls, emails and meetings, kept so that there is an accurate account of what was agreed.

We do not collect special category data such as information about health, ethnicity, religious belief, political opinion or sexual orientation in the ordinary course of operating this website. If such information is ever sent to us unsolicited, we will delete it unless we are legally required or professionally obliged to retain it.

4. How We Obtain Information

Most of the personal data we hold comes directly from you. You provide it when you complete the contact form on this website, when you write to info@potisgroup.lat, when you call +85259464806 or when you attend a meeting at our chamber address in Wan Chai.

We may also receive personal data from a venture that has engaged the Company, for example where a director provides the details of fellow officers, staff or advisers so that we can carry out the agreed work. In such cases the venture is responsible for ensuring that the individuals concerned have been told what information is being shared and why.

Some technical data is generated automatically when you visit the website. This includes request logs and similar records produced by the web server and the network that serves the site. This data helps us keep the website secure and available and does not by itself identify you as an individual.

5. Purposes of Processing

We use personal data for the following purposes, all of which are connected with the operation of the chamber and the services we provide:

  • To receive, log, route and answer enquiries sent to the chamber desk.
  • To assess whether a venture can be seated and to design a suitable holding structure.
  • To carry out cross company accounting, bookkeeping and financial reporting on behalf of seated ventures.
  • To maintain compliance calendars and to prepare and lodge statutory filings on time.
  • To operate the shared service desk, including invoicing, payroll coordination and records archiving.
  • To prepare board papers, management accounts and minutes for venture board reporting.
  • To coordinate treasury, payment runs, forecasting and banking mandates for the group.
  • To maintain and secure the website and to diagnose technical faults.
  • To meet legal, regulatory, tax and accounting obligations that apply to the Company.
  • To establish, exercise or defend legal claims where this becomes necessary.

We do not use personal data for automated decision making that produces legal effects concerning you, and we do not build profiles of website visitors for the purpose of selling advertising.

6. Lawful Basis for Processing

Where the law requires us to identify a lawful basis, we rely on the following grounds. In each case the basis matches the purpose described in the preceding section.

Consent. When you voluntarily submit the contact form or write to the chamber desk, you consent to our use of the information for the purpose of answering you. You may withdraw that consent at any time by writing to info@potisgroup.lat, although withdrawal does not affect processing carried out before the withdrawal.

Contract. Where a venture has engaged the Company, we process personal data because it is necessary to perform the engagement, to seat the venture and to deliver the agreed chapters of chamber practice.

Legal obligation. We process certain records because Hong Kong law and applicable accounting and tax rules require us to keep them and to file them with the relevant authorities.

Legitimate interests. We process limited technical and communications data because it is necessary for the secure and effective operation of the website and for the proper administration of the chamber, provided that this does not override your rights and interests.

7. Cookies and Similar Technologies

This website is built as a set of static pages and is designed to work without advertising trackers. We do not use cookies to build advertising profiles, and we do not place third party marketing cookies on your device through this site.

If we use a cookie or a comparable technology at any time, it will be only for a functional purpose such as remembering a preference you have expressed or supporting the basic delivery of the site. You can set your browser to refuse cookies or to alert you when a cookie is set, and you can delete cookies already stored on your device through your browser settings. Refusing a functional cookie may affect how some part of the website behaves, but the public content will remain readable.

We may revise our use of cookies as the site develops. Any material change will be reflected in this Policy and, where required, accompanied by a fresh request for consent.

8. Analytics and Measurement

We may measure the use of this website in a way that does not identify individuals. Aggregate figures such as the number of visits, the pages requested and the general region from which requests come help us understand whether the site is useful and where it can be improved.

Where an analytics tool is used, we configure it to avoid collecting information that would identify you and to avoid combining its data with other records we hold. We do not use analytics to make decisions about individuals, and we do not sell analytics data to any third party.

Server logs are kept for a limited period and are used mainly for security, fault diagnosis and capacity planning. They are not used to track your activity across other websites.

9. How We Share Information

We do not sell personal data. We do not rent personal data. We do not trade personal data for advertising. We share personal data only in the limited circumstances described below and only to the extent necessary.

  • Within the chamber. Authorised personnel and officers of POTIS GROUP LIMITED may access information where this is needed to answer an enquiry or to serve a seated venture.
  • With professional advisers. We may share information with auditors, accountants, legal advisers and other professionals where this is required to carry out a chapter of chamber practice or to obtain advice.
  • With service providers. We use a small number of providers for functions such as email, hosting and document storage. They act on our instructions and are bound to protect the data they handle.
  • With authorities. We may disclose information where we are required to do so by law, by a court order or by a competent regulator, or where disclosure is necessary to protect the rights and safety of the Company or others.
  • In a corporate event. If the Company is reorganised, merged or transferred, information may be shared with the successor body under equivalent protections.

Whenever we share personal data we minimise what is shared and we require the recipient to use it only for the purpose for which it was provided.

10. Service Providers and Processors

Like most organisations, we rely on service providers for routine functions. These providers may process personal data on our behalf and are therefore treated as processors. Typical functions include secure email, website hosting, data backup and document archiving.

We choose providers with care and we impose written terms that require them to process personal data only on our documented instructions, to apply appropriate technical and organisational security measures, to restrict access to trained staff, to assist us in meeting our legal duties and to delete or return data when the engagement ends.

We remain responsible for personal data that a processor handles on our behalf. If you have a question about a processor, you may write to info@potisgroup.lat and we will explain the arrangement to the extent that we are able to do so without breaching confidentiality owed to others.

11. Cross Border Transfers

The chamber is based in Hong Kong, and personal data is primarily stored and processed here. Some service providers used for email, hosting or archiving may operate infrastructure in other jurisdictions.

Where personal data is transferred outside Hong Kong, we take reasonable steps to ensure that it continues to receive a level of protection consistent with this Policy and with applicable law. Those steps may include contractual terms, vendor security assessments and limiting the categories of data that may leave Hong Kong.

If you are located outside Hong Kong and contact the chamber, you understand that your information will be handled in Hong Kong and may be processed in the jurisdictions where our providers operate.

12. Retention of Records

We keep personal data only for as long as it is needed for the purpose for which it was collected, or for as long as the law requires. The actual period depends on the kind of record involved.

  • Enquiries that do not lead to an engagement are kept for a short period so that we can answer follow up questions, after which they are deleted.
  • Engagement and accounting records are kept for the period required by Hong Kong tax and company law, because those records must be available for inspection.
  • Board papers, minutes and sealed records are kept for the life of the chamber relationship and for a reasonable period afterwards, because they are the memory of the council.
  • Technical logs are kept for a limited period and are then overwritten or deleted.

When a retention period ends, we delete the data or make it anonymous so that it can no longer be linked to any individual. Where data has been shared with a provider, we instruct the provider to delete it as well.

13. Security of Personal Data

We protect personal data with administrative, technical and physical measures appropriate to the sensitivity of the information. These measures include access controls that limit data to authorised personnel, secure storage for chamber records, encrypted transmission where the technology allows and routine backup of critical files.

Our personnel are trained to handle information carefully and are bound by duties of confidentiality. Access to a venture record is granted only to those who need it to carry out the work, and access is reviewed as the relationship changes.

No method of transmission over the internet and no method of electronic storage is perfectly secure. We therefore cannot promise absolute security, but we work continuously to reduce risk and we act promptly to investigate and remedy any incident that affects personal data. Where a breach is likely to result in a risk to your rights, we will notify you and the relevant authority as required by law.

14. Your Rights and Choices

Subject to the law of Hong Kong and to any overriding obligation we may have, you have the following rights in relation to the personal data we hold about you.

  • Access. You may ask whether we hold personal data about you and request a copy of it.
  • Correction. You may ask us to correct data that is inaccurate or incomplete.
  • Deletion. You may ask us to delete data that we no longer have a lawful reason to keep.
  • Restriction. You may ask us to limit how we use data while a question about it is resolved.
  • Objection. You may object to processing that we carry out on the basis of legitimate interests.
  • Withdrawal of consent. Where we rely on consent, you may withdraw it at any time.
  • Portability. Where the law provides for it, you may ask for data you provided to be given to you in a usable form.

To exercise a right, write to info@potisgroup.lat with enough detail for us to identify you and to understand the request. We may ask for proof of identity before acting, so that we do not disclose data to the wrong person. We will respond within the period allowed by law and will explain any reason why a request cannot be granted in full.

15. Marketing Communications

We do not send marketing messages to people who have simply visited this website. If you write to the chamber desk, we will use your details to answer your enquiry, not to add you to a promotional list.

Where we would like to share chamber news, a counsel circular or a notice about the winter council calendar, we will ask for your agreement first and we will make it easy for you to decline. If you agree and later change your mind, you may ask us to stop at any time by writing to info@potisgroup.lat or by calling +85259464806, and we will remove you from the relevant list.

Even if you decline marketing, we may still contact you about an active engagement or about a legal or accounting matter that requires communication.

16. Privacy for Children

This website and the chamber services are intended for companies, their directors and their professional advisers. They are not directed at children, and we do not knowingly collect personal data from a child.

If you are a parent or guardian and believe that a child has provided personal data to the chamber, please write to info@potisgroup.lat. We will investigate and, where appropriate, delete the information promptly. If we become aware that we have collected data from a child without proper consent, we will take steps to remove it from our records.

17. Third Party Links and Services

This website may contain links to other websites, for example the site of a professional body or a counterparty. Those websites are not controlled by POTIS GROUP LIMITED, and this Policy does not apply to them.

When you follow a link away from this site, you should read the privacy statement of the site you reach. We are not responsible for the content, security or privacy practices of any external site, and a link from our pages does not imply that we endorse everything that appears at the destination.

The same caution applies to any third party form, payment page or messaging service that you may reach from a venture engagement. Where we control such a service, this Policy applies. Where a third party controls it, that party is responsible for the data it collects.

18. Changes to this Policy

We review this Policy from time to time and may update it to reflect changes in the law, in our services or in the way the chamber operates. When we make a material change, we will publish the revised Policy on this page and adjust the effective date shown at the foot of the page.

We encourage you to read this Policy again when you return to the website, so that you always know how your information is handled. Continued use of the website after a revision takes effect means that you accept the revised Policy.

If a change affects an active engagement, we will draw it to the attention of the venture concerned through its usual channel of communication.

19. How to Contact Us

If you have a question about this Policy, a request about your personal data or a concern about how information has been handled, please contact the chamber desk.

  • Email: info@potisgroup.lat
  • Telephone: +85259464806
  • Post: POTIS GROUP LIMITED, Rm 1002 10/F EASEY COML BLDG, 253-261 HENNESSY RD, Wan Chai, Hong Kong

We take every privacy concern seriously and we will acknowledge your message promptly and work with you towards a fair resolution.

20. Governing Law and Jurisdiction

This Policy is prepared in accordance with the laws of Hong Kong and in particular the requirements of the Personal Data (Privacy) Ordinance and related rules that apply to the handling of personal data in Hong Kong.

Any dispute arising out of or in connection with this Policy is subject to the exclusive jurisdiction of the courts of Hong Kong. If any part of this Policy is held to be unenforceable, the remaining parts will continue in full force, and the unenforceable part will be read down so as to give effect to the intention behind it as far as the law allows.

This Policy should be read together with our Terms of Service, which govern the use of this website and the basis on which the chamber offers its services. Together they describe the full understanding between you and POTIS GROUP LIMITED in relation to this website.

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POTIS GROUP LIMITED · Rm 1002 10/F EASEY COML BLDG, 253-261 HENNESSY RD, Wan Chai, Hong Kong

Email: info@potisgroup.lat · Phone: +85259464806

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