Privacy Policy

Last updated: 29 June 2026

This Privacy Policy explains how we collect, use, store and protect your personal data when you visit trafalgaradvisory.com (the "Website") or otherwise interact with us. We are committed to handling your personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of the laws of Hong Kong (the "PDPO").

1. Who we are

The Website is operated by TRAFALGAR LIMITED, trading as Trafalgar Advisory. We are the data user responsible for your personal data under the PDPO.

2. The personal data we collect

We may collect and process the following categories of personal data:

• Information you provide to us — for example your name, email address, company, and the contents of any message when you contact us by email or otherwise correspond with us.
• Technical and usage data — when you visit the Website, our hosting provider and any analytics tools we use may automatically collect information such as your IP address, device and browser type, referring pages, and pages viewed.
• Cookies and similar technologies — as described in section 6 below.

3. How we use your personal data

We use personal data to:

• respond to your enquiries and communicate with you;
• provide, operate and improve our services and the Website;
• maintain the security and integrity of the Website;
• comply with applicable laws and regulatory obligations.

4. Direct marketing

We will not use your personal data for direct marketing purposes without first obtaining your consent, in accordance with the PDPO. Where you have consented, you may withdraw that consent at any time by contacting us at david@trafalgaradvisory.com.

5. Disclosure and transfer of personal data

We do not sell your personal data. We may disclose it to:

• service providers who support our business and the Website (for example hosting, IT, and analytics providers), who are required to handle it securely and only on our instructions;
• professional advisers, regulators or authorities where required or permitted by law.

Some of these parties may be located outside Hong Kong. Where personal data is transferred outside Hong Kong, we take reasonable steps to ensure it is afforded a level of protection consistent with the PDPO.

6. Cookies and tracking technologies

The Website may use cookies and similar technologies (such as pixels, tags and analytics scripts), placed by us or by third parties, to make the Website work, to remember your preferences, and to understand how the Website is used. These may include:

• Strictly necessary cookies, required for the Website to function;
• Performance and analytics cookies, which help us understand how visitors use the Website (for example Google Analytics or similar tools);
• Functionality cookies, which remember your choices and preferences;
• Advertising and targeting cookies, which may be used to measure and improve the relevance of marketing.

Where required by applicable law, we will seek your consent before placing non-essential cookies, and you will be able to manage your preferences through a cookie banner or settings tool. You can also control or delete cookies through your browser settings. Disabling certain cookies may affect how the Website functions.

7. Data retention

We retain personal data only for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy any legal, accounting or reporting requirements, after which it will be deleted or anonymised.

8. Security

We take practicable steps to protect personal data against unauthorised or accidental access, processing, loss or use. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

9. Your rights under the PDPO

Subject to the PDPO, you have the right to:

• request access to the personal data we hold about you (a data access request);
• request correction of any inaccurate personal data (a data correction request);
• ascertain our policies and practices in relation to personal data.

To exercise any of these rights, please contact us at david@trafalgaradvisory.com. We may charge a reasonable fee for complying with a data access request, as permitted by the PDPO.

10. Third-party websites

The Website may contain links to third-party websites. We are not responsible for the privacy practices or content of those websites and encourage you to review their privacy policies.

11. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version will always be posted on this page with the "Last updated" date shown above.

12. How to contact us

If you have any questions about this Privacy Policy or how we handle your personal data, please contact us at david@trafalgaradvisory.com. If you are not satisfied with our response, you may make a complaint to the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD).