Privacy Policy
Trocadero Ltd.
www.trocadero.pro
Effective Date: July 23 th, 2026
1. Introduction
Trocadero Ltd. (“Trocadero”, “we”, “us” or “our”) is a company incorporated in Hong Kong. This Privacy Policy explains how we collect, use, store and disclose personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”).
This Policy applies to personal data collected through:
Our website
Direct communications (including email)
Advisory engagements
Our website is informational only. Engagements are governed by separate written agreements.
2. Personal Data We Collect
We collect only data that is relevant to our advisory activities.
This may include:
Name
Business email address
Telephone number
Company name and role
Information provided in enquiry messages
Information provided during advisory discussions
Billing and contract-related information (where applicable)
We may also collect technical data automatically when you visit our website, including:
IP address
Device and browser type
Pages visited
Basic analytics data
We do not intentionally collect sensitive personal data.
3. Purpose of Collection
Your personal data may be used for the following purposes:
Responding to enquiries
Assessing suitability of an engagement
Providing advisory services
Managing contractual relationships
Invoicing and administration
Maintaining business records
Complying with legal or regulatory obligations
Website analytics and performance improvement
We do not sell personal data.
4. Voluntary Provision of Data
Providing personal data is voluntary.
However, if you do not provide sufficient information:
We may be unable to respond to your enquiry
We may be unable to assess or enter into an engagement
5. Disclosure and Transferees
Personal data may be transferred to:
Professional advisers (legal, accounting)
Service providers supporting hosting, email, analytics, or IT systems
Payment processors
Regulatory authorities or law enforcement where legally required
Where service providers are located outside Hong Kong, we take reasonable steps to ensure appropriate protection of personal data. We do not disclose personal data for unrelated third-party marketing purposes.
6. Data Retention
Personal data is retained only for as long as reasonably necessary for the purposes stated above, or as required by law.
Typical retention periods:
Enquiry correspondence: up to 3 years
Contract and financial records: up to 7 years or longer if legally required
Website analytics data: typically up to 12 months
When no longer required, data will be deleted or securely destroyed.
7. Cookies and Website Analytics
Our website may use cookies or similar technologies to:
Ensure functionality
Understand website usage
Improve performance
You may control cookies through your browser settings. If retargeting or advertising technologies are introduced in the future, this Policy will be updated accordingly.
8. Data Security
We take reasonable technical and organisational measures to safeguard personal data, including:
Access controls
Secure service providers
Secure communication practices
Limiting access to data on a need-to-know basis
No internet transmission is completely secure, but reasonable safeguards are implemented.
9. Your Rights
Under the PDPO, you have the right to:
Request access to your personal data
Request correction of inaccurate personal data
Requests may be subject to identity verification and, where permitted by law, a reasonable administrative fee.
10. Contact for Access and Correction
Requests relating to personal data should be directed to:
Trocadero Ltd.
Unit 2A, 17/F, Glenealy Tower
No.1 Glenealy
Central, Hong Kong
Email: contact@trocadero.pro
We will respond within a reasonable period in accordance with the PDPO.
11. Changes to This Policy
We may update this Privacy Policy from time to time. The current version will always be available on our website.