Thermetery Technology (Hong Kong) Co., Limited
Privacy Policy
Effective Date: February 9, 2026
Last Updated: February 9, 2026
1. Introduction
Thermetery Technology (Hong Kong) Co., Limited (“Thermetery,” “we,” “our,” or “us”) respects the privacy of our clients, partners, and website visitors.
This Privacy Policy explains:
- What information we collect
- Why we collect it
- How we use it
- When we disclose it
- How long we retain it
- Your rights, where applicable
Thermetery operates primarily as a business-to-business (B2B) engineering and research consultancy.
2. Information We Collect
We collect only information reasonably necessary to conduct our business.
2.1 Business Contact Information
- Name
- Company name
- Business or shipping address
- Email address
- Telephone number
- VAT or tax identification number (if applicable)
2.2 Transaction Information
- Invoice records
- Payment confirmations
- Contractual documents
- Shipping documentation
- Customs-related documentation
2.3 Website Usage Information (if applicable)
- IP address
- Basic technical or usage data
We do not intentionally collect special categories of personal data.
3. Purpose of Processing
We process personal information solely for legitimate business purposes, including:
- Contract formation and performance
- Engineering services delivery
- Order fulfillment and shipment
- Customs clearance
- Accounting and tax compliance
- Legal compliance
- Responding to inquiries
We do not sell personal data.
We do not engage in behavioral advertising or profiling.
4. Legal Basis for Processing (Where Applicable)
Where the General Data Protection Regulation (EU) 2016/679 (“GDPR”) applies, we rely on:
- Contract performance (Article 6(1)(b))
- Legal obligation (Article 6(1)(c))
- Legitimate interests (Article 6(1)(f)), where appropriate
5. Disclosure of Information
We never sell or commercially monetize any form of personal data.
We disclose personal information only when necessary for legitimate business operations:
5.1 Logistics and Customs
To deliver goods or equipment, we may transmit necessary contact information (including name, address, phone number, and email address) to:
- Courier services
- Freight forwarders
- Customs brokers
- Customs authorities
Such disclosure is limited to what is necessary for shipment and regulatory compliance.
5.2 Legal Requirements
We may disclose personal information in response to:
- Valid court orders
- Subpoenas
- Regulatory investigations
- Other legally binding requests
6. International Transfers
As a Hong Kong-based company operating internationally, we may transfer information across jurisdictions where necessary to:
- Perform contractual obligations
- Process international shipments
- Comply with customs and tax regulations
Where applicable, transfers are conducted in accordance with lawful transfer mechanisms.
7. Data Retention
We retain personal data only for as long as necessary to fulfill contractual obligations and comply with legal requirements.
Statutory Record Retention
Pursuant to the Hong Kong Inland Revenue Ordinance (Cap. 112, Sec. 51C) and other applicable accounting and tax regulations, Thermetery is legally required to retain certain accounting and transaction records, including invoices and related contractual, payment, shipping, and customs documentation, for a minimum period prescribed by law (typically not less than seven (7) years).
Where personal data is contained within such records, we must process and retain that data on the basis of legal obligation. As a result, we may be unable to delete or erase such information until the applicable statutory retention period has expired.
Retention periods may be extended where required for audit, regulatory investigation, dispute resolution, or other legal proceedings.
8. Data Security
We implement reasonable technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, or destruction.
Access to client information is restricted to personnel with a legitimate business need.
9. Individual Rights
Where applicable law provides rights (including access, correction, restriction, objection, or deletion), individuals may submit requests using the contact information below.
Certain requests may be declined where retention is required to comply with legal obligations.
10. Contact
Thermetery Technology (Hong Kong) Co., Limited
Room 33, 14/F, Pioneer Centre, 750 Nathan Road, Kowloon, Hong Kong SAR, China
jiacheng@thermetery.com