Privacy Policy

1. Who We Are

KOMERS TRADING LIMITED is a company registered and operating in Hong Kong. Our office sits at Rm 13F Golden Dragon Coml Bldg, 522 Nathan Rd, Yau Ma Tei, Hong Kong (HK). We work in the field of computer systems design and related services, and we also provide integrated trade and sourcing support that connects digital records with physical cargo movements.

For the purposes of applicable data protection law, KOMERS TRADING LIMITED is the controller of the personal information described in this policy. That means we decide why information is collected and how it is used, and we remain accountable for the way it is handled. The developer name associated with this website is Komers Trade, which is the trading identity under which our team presents its systems design work.

If you have any question about this policy, or if you wish to exercise any right described below, you may write to legal@doublel.hair or call +15855225330. We welcome enquiries and we aim to answer them promptly and clearly.

2. Scope Of This Policy

This policy applies to personal information that we collect through our website at doublel.hair, through email and telephone contact, through forms you submit, and through the delivery of our services to clients and prospective clients. It covers information about individuals, including client contacts, supplier contacts, visitors to our website and people who send us messages.

This policy does not apply to information that is not personal in nature, such as anonymised operational statistics, aggregate route data that cannot be linked to any person, or business information that is publicly available. It also does not apply to third party websites that we may link to, each of which has its own privacy practices that we do not control.

Where we act as a processor on behalf of a client, meaning the client decides the purpose and we only handle information on the client instructions, the terms of the client agreement govern that work and this policy serves as a general statement of our security and handling standards.

3. Information We Collect

The categories of personal information we may collect include the following.

Identity and contact information

Name, job title, employer, business email address, business telephone number, business postal address and any contact details you choose to provide when you write to us or complete a form.

Enquiry and service information

The content of messages you send, the services you ask about, route or shipment references you share, claim details, documents you attach, and notes our team records while handling your request.

Technical and usage information

Internet protocol address, browser type and version, device type, operating system, referring pages, pages viewed, time and date of visits, and general location derived from the network address. This information is used to keep the website working, secure and useful.

Financial and transaction information

Where you engage our services, we may collect billing details, purchase order references, payment records and the tax or registration details needed to invoice you correctly. We do not store full payment card numbers on our own systems.

Recruitment information

If you apply to work with us, we may collect the details in your application, including your employment history and any references you provide.

4. How We Collect Information

We collect personal information in several ways. You provide most of it directly when you send an email, submit a contact form, place a telephone call or share documents with our team. When you use our website, some information is collected automatically by the server and by standard security tooling.

We may also receive information about you from your colleagues, from a client organisation that introduces you as a contact, from a supplier or carrier involved in a shipment, or from publicly available business directories. Where we receive information indirectly, we treat it with the same care as information you provide yourself, and we use it only for the purposes described in this policy.

We do not buy personal information from data brokers, and we do not build marketing profiles of individuals who have not chosen to engage with us.

5. Why We Use Your Information

We use personal information for the following purposes.

• To respond to your enquiries, answer your questions and provide the information you request.
• To deliver, support and improve the design, integration and trade services we provide.
• To prepare quotations, issue invoices, process payments and maintain accurate business records.
• To coordinate shipments, filings, claims and capacity planning where you have engaged us to do so.
• To keep our website secure, prevent abuse and diagnose technical problems.
• To comply with legal, tax, regulatory and accounting obligations that apply to us.
• To establish, exercise or defend legal claims where that becomes necessary.
• To send service updates and relevant business information to clients who expect them.

We do not use your personal information for automated decision making that produces legal effects concerning you, and we do not sell your personal information to any party.

6. Legal Bases For Processing

Where data protection law requires a legal basis for processing, we rely on one or more of the following. We process information because it is necessary to perform a contract with you or to take steps at your request before entering a contract. We process information because we have a legitimate interest in running our business, provided that interest is not overridden by your rights and freedoms. We process information to comply with legal obligations. Where we rely on consent, for example for optional communications, you may withdraw that consent at any time.

If you have questions about the legal basis that applies to a particular activity, please contact us using the details in this policy, and we will explain the reasoning in plain terms.

7. Cookies And Similar Technologies

Our website is built to work with as little tracking as possible. We may use a small number of cookies or similar storage mechanisms that are strictly necessary to keep the site functioning, to remember basic preferences and to protect against abuse. Strictly necessary cookies do not require consent because the site cannot operate correctly without them.

If we ever introduce optional analytics or measurement tools, we will present a clear notice and, where the law requires it, ask for your consent before those tools are loaded. You can also control cookies through your browser settings. Blocking some cookies may affect how parts of the website behave, but the core content remains readable.

We do not use tracking technologies to follow you across unrelated websites for advertising purposes, and we do not permit third party advertising networks to set cookies through our pages.

8. How We Share Information

We share personal information only where it is necessary and only with parties who are bound to protect it. The categories of recipients are set out below.

Service providers

Hosting providers, email providers, information technology support, professional advisers and similar suppliers who help us operate. They receive only the information they need to perform their function.

Trade counterparties

Where you have engaged us to coordinate a shipment, we may share relevant details with carriers, agents, port authorities and inspectors so that the work can be completed. We share the minimum necessary for each task.

Professional advisers

Lawyers, auditors, insurers and accountants where their advice or coverage is required, subject to professional confidentiality duties.

Authorities and legal requirements

Courts, regulators and law enforcement where we are required by law to disclose information, or where disclosure is necessary to protect rights, safety or property.

We do not sell personal information, and we do not share it for the independent marketing purposes of any third party.

9. International Data Transfers

KOMERS TRADING LIMITED is based in Hong Kong, and the information we collect may be stored and processed in Hong Kong and in other locations where our service providers operate. Some of those locations may have data protection laws that differ from the laws of your own country.

Where we transfer personal information across borders, we take steps to ensure that it remains protected. Those steps may include contractual commitments that require the recipient to apply appropriate safeguards, selection of providers that maintain recognised security certifications, and limiting transfers to what is genuinely necessary for the service concerned.

If you would like more detail about the safeguards used for a particular transfer, you may write to us and we will provide an explanation.

10. How Long We Keep Information

We keep personal information only for as long as it is needed for the purposes described in this policy, and for any additional period required by law. Retention periods are set by considering the nature of the information, the risk of harm from unauthorised use, the purposes of processing, and the legal and accounting rules that apply to our business.

As a general guide, enquiry correspondence is kept for a reasonable period after the enquiry closes, client and transaction records are kept for the period required by tax and company law, and website security logs are kept for a short period unless they are needed to investigate an incident. When a retention period ends, we delete or anonymise the information in a secure manner.

11. How We Protect Information

We take the security of personal information seriously. Our safeguards include encryption of data in transit, access controls that limit information to staff who need it, strong authentication for internal systems, regular review of permissions, and secure configuration of the servers that host our website.

We train our team to recognise common threats such as fraudulent email and social engineering, and we maintain procedures for responding to incidents. If a security incident occurs that is likely to result in a risk to your rights, we will notify the relevant authorities and affected individuals as required by law.

No method of transmission or storage is completely secure, and we cannot promise absolute security. We do promise to apply appropriate technical and organisational measures and to keep improving them as threats evolve.

12. Your Privacy Rights

Depending on where you live, you may have some or all of the following rights in relation to your personal information.

• The right to be informed about how your information is used.
• The right to request access to the information we hold about you.
• The right to request correction of information that is inaccurate or incomplete.
• The right to request deletion of information in certain circumstances.
• The right to request that we restrict processing in certain circumstances.
• The right to object to processing based on legitimate interests.
• The right to data portability where processing is based on consent or contract.
• The right to withdraw consent at any time where consent is the basis for processing.
• The right to lodge a complaint with a supervisory authority.

To exercise any of these rights, write to legal@doublel.hair or call +15855225330. We may need to verify your identity before acting on a request, and we will respond within the time required by applicable law. Exercising your rights will never result in unfair treatment, and we do not charge a fee except where a request is clearly unfounded or excessive.

13. Privacy For Children

Our website and services are intended for business and professional audiences. They are not directed at children, and we do not knowingly collect personal information from children. If you believe that a child has provided personal information to us, please contact legal@doublel.hair so that we can take appropriate steps to remove it.

Where we discover that we have inadvertently collected information from a child without the required consent, we will delete that information as quickly as we reasonably can and will review how it was collected so that the same situation is not repeated.

14. Third Party Links And Services

Our website may contain links to websites, maps, forms or tools operated by other organisations. We provide those links for convenience, and we do not control the privacy practices of the destinations. When you follow a link away from our site, we encourage you to read the privacy notice of the site you reach.

Some features of our service may rely on third party platforms, such as email delivery or cloud hosting. Those providers process information under their own terms and safeguards, and we select them with care. This policy does not extend to their independent processing activities.

15. Changes To This Policy

We may update this policy from time to time to reflect changes in our practices, in technology or in the law. When we make a material change, we will revise the effective date at the top of this page and, where appropriate, provide a more prominent notice on the website or by direct communication.

We encourage you to review this page periodically so that you remain aware of how we protect personal information. Continued use of our website or services after an update means that you accept the revised policy as it applies to future interactions.

16. How To Contact Us

If you have a question, a concern or a request about privacy, please contact us through any of the channels below. We treat privacy enquiries as important and we route them to a person who can act on them.

KOMERS TRADING LIMITED
Rm 13F Golden Dragon Coml Bldg, 522 Nathan Rd, Yau Ma Tei, Hong Kong (HK)
Email: legal@doublel.hair
Phone: +15855225330

When you contact us about privacy, please include enough detail for us to understand your request, such as the nature of your relationship with us and the information concerned. Please do not send sensitive documents unless we ask for them, and never send payment card details by email.

17. Governing Law And Complaints

This policy is governed by the laws of Hong Kong, without regard to conflict of law rules, except where mandatory consumer or data protection law in your own jurisdiction provides you with stronger protection. If you are not satisfied with our response to a privacy concern, you have the right to complain to the relevant supervisory authority in your jurisdiction.

We would prefer the chance to resolve your concern directly first. Writing to legal@doublel.hair gives our team the opportunity to investigate and to explain what we have found. We take every complaint seriously, and we keep a record of how it was handled so that we can improve.

18. Summary Of Commitments

To close, here is a plain summary of what KOMERS TRADING LIMITED promises in relation to personal information. We collect only what we need for clear and stated purposes. We use information to serve you, to run our business lawfully and to meet our obligations. We do not sell personal information. We share it only with parties who need it and who are bound to protect it. We apply real security measures and we review them. We honour the rights that the law gives you. We tell you when our practices change. And we remain reachable at legal@doublel.hair and on +15855225330 for any question you may have.

Thank you for taking the time to read this Privacy Policy. Your trust matters to us, and the developer name Komers Trade stands behind every commitment written on this page.