Privacy Policy

1. Introduction and Scope

This Privacy Policy explains how LUOKUN GROUP LIMITED collects, uses, stores, shares and protects personal data. LUOKUN GROUP LIMITED is a holding group administration and trade desk that coordinates sourcing mandates, joint venture paperwork and container shipping documentation for its operating companies. In the course of that work the group handles business contact details, correspondence and commercial records, and this policy describes the rules the group applies to that handling.

This policy applies to personal data collected through the group website, through email and telephone contact, through the contact form, and through the ordinary course of group administration and trade desk activity. It applies to visitors, enquirers, supplier contacts, partner contacts and representatives of group companies.

By using the website or contacting the group, you acknowledge that you have read this policy. If you do not agree with the practices described here, please do not use the website or submit personal data to the group. Questions about this policy may be sent to the contact address given in the final section.

2. Who We Are

The data controller for the purposes of this policy is LUOKUN GROUP LIMITED, whose registered and operating office is at 12/F SAN TOI BLDG, 137-139 CONNAUGHT RD C, Sheung Wan, Hong Kong (HK). The group can be reached by email at contact@luokungroup.mom and by telephone at +85259984023.

The group operates as a Hong Kong holding entity. It does not run a retail business, it does not sell consumer goods, and it does not collect payment card details through this website. Its data activity is limited to the business contact and commercial records that support the desk services described on the services page.

Where a group company acts as its own data controller for its own customers, that company is responsible for its own notices. This policy covers the central desk operated by LUOKUN GROUP LIMITED and the website that the desk maintains.

3. Data We Collect

The group collects the following categories of personal data.

• Identity and contact data, such as a name, job title, company name, business email address, business telephone number and business postal address.
• Correspondence data, such as the content of messages sent through the contact form, by email or by telephone, including attachments and supporting documents.
• Commercial record data, such as the details of sourcing mandates, joint venture packs, shipping files, contract reviews, trade finance matters and compliance filings that involve a named contact.
• Technical data, such as the internet protocol address, browser type, device type and pages viewed when a visitor uses the website, collected in an aggregated and non-identifying manner where possible.
• Preference data, such as a stated preference for a contact method or a request to receive or stop receiving group updates.

The group does not knowingly collect special category data such as health information, religious belief or biometric data, and it asks that such information not be sent through the website or by email. If special category data is sent without request, the group will delete it unless it has a clear and lawful reason to keep it.

4. How We Collect Data

The group collects personal data in several ordinary ways. A visitor may complete the contact form on the website, which prepares an email message that the visitor then sends from a personal or business email account. A contact may write to the group directly by email or telephone. A supplier or partner may send a commercial document that names an individual. A group company may pass on the details of a representative who is authorised to handle a file.

Technical data may be collected automatically when the website is used, through server logs and similar mechanisms. This data is used to keep the website working, to understand which pages are useful and to protect the website from abuse. It is not used to build a personal profile of a visitor.

The group may also receive data from third parties such as freight forwarders, banks, registries or professional advisers, where that data is necessary to complete the work a group company has asked the desk to perform.

5. Why We Use Data

The group uses personal data for the following purposes.

• To respond to enquiries and to provide the information a contact has asked for.
• To perform the desk services described on the services page, including opening sourcing mandates, assembling joint venture paperwork, checking container shipping documentation, reviewing supplier contracts, liaising on trade finance and supporting compliance filings.
• To maintain commercial records and an audit trail for the group and its operating companies.
• To communicate about an open file, including reminders about deadlines and requests for missing documents.
• To keep the website secure and functioning, and to understand how the website is used in aggregate.
• To meet legal, regulatory and internal record keeping obligations that apply to a Hong Kong holding group.

The group does not use personal data for automated decision making that produces a legal effect, and it does not sell personal data to any third party.

6. Legal Basis for Processing

Where the group processes personal data, it relies on a lawful basis. The basis is usually the performance of a contract or the steps taken before a contract, for example when the group is preparing documents for a group company or a partner. The basis may also be the legitimate interests of the group in running its desk and keeping proper records, provided those interests are not outweighed by the rights of the individual.

In some cases the basis is consent, for example where a contact has asked to receive group updates. Consent can be withdrawn at any time by writing to contact@luokungroup.mom. In other cases the basis is a legal obligation, for example where the group must keep a record to satisfy a regulatory requirement.

Where the group relies on legitimate interests, it considers the nature of the data, the expectations of the individual and the impact of the processing before it proceeds.

7. How We Share Data

The group shares personal data only where it is necessary for the work being done. A shipping file may need to be shared with a freight forwarder or a carrier. A trade finance presentation may need to be shared with a bank. A joint venture pack may need to be shared with a partner and its advisers. A compliance filing may need to be shared with a registry or an authority.

The group may also share data with professional advisers such as accountants and legal counsel, with insurers, and with information technology providers that help run the website and the desk. In every case the group shares only what the task requires.

The group does not sell personal data and does not trade personal data for advertising purposes. Where the group is required by law or by a valid legal request to disclose data, it will do so, and it will disclose only what is properly required.

8. Service Providers and Processors

Where the group uses a service provider, the provider acts on the instructions of the group and under a contract that requires appropriate protection for personal data. Providers are selected with care, and they are asked to keep data confidential, to use it only for the agreed purpose and to return or delete it when the work ends.

Typical providers include hosting and email services, document storage services, and professional firms that support the desk. The group reviews its providers from time to time and will change a provider where its protections are not adequate.

Where a provider is located outside Hong Kong, the group considers the transfer safeguards described in the section on international transfers before any data is sent.

9. International Transfers

A Hong Kong holding group works across borders. A shipping file may involve a supplier in one country, a forwarder in another and a bank in a third. As a result, personal data may be transferred to and processed in a country other than the one in which it was collected.

Where the group transfers personal data across borders, it takes steps to ensure the data remains protected. Those steps may include contractual protections, checks on the receiving organisation, and limiting the transfer to the data that is genuinely needed for the task.

A contact who wishes to understand where a particular file is processed may write to the group at contact@luokungroup.mom and the desk will explain the position for that file.

10. Data Retention

The group keeps personal data only for as long as it is needed for the purpose for which it was collected, or for as long as a law or regulation requires. Commercial records connected to sourcing mandates, joint venture packs, shipping files, contract reviews, trade finance matters and compliance filings are generally kept for the period that a Hong Kong holding group must retain business records, after which they are securely deleted or anonymised.

Correspondence that does not lead to an open file is kept for a shorter period and is then removed. Technical data held in server logs is kept for a limited period and is used only in aggregate where possible.

When the retention period ends, the group deletes the data or removes the details that identify an individual. Where data cannot be deleted immediately because it is held in a backup, it is isolated until the backup cycle removes it.

11. How We Protect Data

The group protects personal data with technical and organisational measures that are appropriate to the risk. Measures include access controls that limit data to staff and advisers who need it, protected accounts, routine backup, and physical security at the Sheung Wan office.

The desk also applies a documentary discipline. A file is opened with a number and an owner, changes are recorded, and access is granted on a need to know basis. This discipline is not only good for the work, it is good for privacy, because it keeps the data in a small number of known hands.

No method of transmission or storage is perfectly secure. The group works to reduce risk, and it asks that contacts avoid sending special category data or unnecessary sensitive details through the website or by email. If a contact believes that data has been compromised, the group should be told at once using the contact details in the final section.

12. Cookies and Similar Technologies

The website is built to work without advertising trackers. It may use a small number of technical mechanisms that help the pages load and help the group understand which pages are useful. These mechanisms do not identify an individual by name and are not used to follow a visitor across other websites.

A visitor can control or block cookies through the settings of a browser. Blocking cookies may affect how some parts of the website behave, but the main content of the website remains readable without them.

The group does not use cookies to build advertising profiles and does not share cookie data with advertising networks.

13. Marketing Communications

The group sends business updates only where a contact has asked to receive them or where there is an existing relationship and the update is relevant to that relationship. Updates are limited to matters such as seasonal documentation windows and changes to the desk.

Every update includes a way to stop receiving further updates. A contact can also write to contact@luokungroup.mom at any time and ask to be removed from the update list. The group will act on that request promptly and will keep only the minimum record needed to honour it.

The group does not rent, sell or trade contact lists.

14. Privacy for Children

The website and the desk services are intended for business use by adults. The group does not knowingly collect personal data from children, and it does not direct any part of the website at children.

If the group learns that it has collected personal data from a child without appropriate consent, it will delete that data as soon as it can. A parent or guardian who believes that a child has sent data to the group may write to contact@luokungroup.mom and the group will act on the request.

This section is sometimes described as Privacy for Children. It applies to the whole website and to all desk services.

15. Your Rights

Depending on where you live, you may have a set of rights over your personal data. These rights can include the right to be told what data the group holds, the right to ask for a copy, the right to ask for a correction, the right to ask for deletion in certain circumstances, the right to ask for processing to be restricted, the right to object to certain processing, and the right to ask for data in a portable form.

Where the group relies on consent, you have the right to withdraw that consent at any time. The withdrawal does not affect processing that took place before the withdrawal.

To exercise a right, write to contact@luokungroup.mom with enough detail for the group to identify the data concerned. The group may ask for proof of identity before it acts, to protect the data from an unauthorised request. The group aims to respond within the period allowed by the applicable law.

16. Access and Correction Requests

A contact who wants a copy of the personal data the group holds, or who wants an inaccuracy corrected, may send a written request to contact@luokungroup.mom or by post to 12/F SAN TOI BLDG, 137-139 CONNAUGHT RD C, Sheung Wan, Hong Kong (HK).

The group will confirm receipt, check the request, gather the relevant data and reply within the period allowed by law. Where a request is complex, the group will explain the reason for any delay and keep the requester informed.

Where the group cannot act on a request, it will explain the reason and set out any further step that is available. The group may charge a reasonable fee where the law permits a fee for a request, and it will tell the requester before any fee is applied.

17. Third Party Links

The website may link to websites run by other organisations. The group does not control those websites and is not responsible for their privacy practices. A visitor who follows a link should read the privacy notice of the website being visited.

A link from this website does not mean that the group endorses the content or the practices of the linked website.

If a link on this website appears to lead to content that is misleading or harmful, please report it to contact@luokungroup.mom so that the desk can review it.

18. Changes to This Policy

The group may update this policy from time to time to reflect a change in the law, a change in the services, or a change in the way the desk works. The effective date at the top of the page shows when the current version took effect.

Where a change is significant, the group will make that clear on the website. Continued use of the website or continued contact with the desk after a change means that the updated policy applies.

A contact who wants a copy of an earlier version of this policy may request it from the group using the contact details below.

19. How to Contact Us

Questions, requests and concerns about this policy or about personal data may be sent to LUOKUN GROUP LIMITED at the following details. The desk reads every message that arrives.

If a contact is not satisfied with the response, the contact may raise the matter with the relevant privacy authority in the jurisdiction where the contact lives or works. The group will cooperate with any lawful process that follows.

This policy is provided in English. The group keeps the English version as the governing text for all purposes.