NVTHK Limited (“NVT”, “we”, “us”, or “our”) is committed to protecting the privacy and security of your personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal data in connection with our services, including our software, platforms, and related technology solutions (collectively, the “Services”). We operate from Hong Kong and provide our Services primarily to institutional clients.

This Privacy Policy complies with the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (“PDPO”) and reflects our commitment to transparency and data protection. By using our Services, you agree to the practices described in this Privacy Policy.

This Privacy Policy applies to personal data we collect from:

• Clients: Representatives of institutional clients who engage with our Services, such as employees or authorized agents.
• Website Visitors: Individuals who visit our website at www.nvt.com.hk.
• Other Contacts: Individuals who contact us, such as through inquiries or business communications.

If you are an end-user of a client’s services (e.g., a customer using a platform powered by NVT’s technology), your data is primarily managed by our client, who acts as the data controller. In such cases, you should refer to our client’s privacy policy, though we may process your data on their behalf as a data processor.

We collect personal data to provide and improve our Services. The types of data we collect depend on how you interact with us:

• Data You Provide Directly:
  1. Contact details, such as your name, email address, phone number, and company name, when you register for our Services, submit inquiries, or enter into a contract with us.
  2. Business information, such as your job title or role, to facilitate client communications.
  3. Billing information, such as bank details or payment information, to process transactions.
• Data Collected Automatically:
  1. Usage data, such as IP addresses, browser types, and access times, when you visit our website or use our Services.
  2. Technical data, such as system logs or performance metrics, to monitor and optimize our platforms.
  3. Cookies and similar technologies on our website to enhance functionality and analyze traffic (see our Cookie Policy for details).
• Data from Third Parties:
  1. Information from partners or service providers, such as cloud hosting providers, to support our Services.
  2. Data provided by clients about their authorized representatives to manage access to our platforms.

We only collect personal data that is necessary for the purposes outlined in this Privacy Policy.

We use your personal data for the following purposes:

• To Provide and Manage Our Services:
  1. To set up and administer client accounts.
  2. To deliver software, platforms, and support services as per our agreements.
  3. To process payments and manage billing.
• To Communicate with You:
  1. To respond to inquiries or provide customer support.
  2. To send updates about our Services, such as new features or maintenance schedules.
• To Improve and Secure Our Services:
  1. To analyze usage patterns and optimize platform performance.
  2. To detect and prevent security threats or unauthorized access.
• To Comply with Legal Obligations:
  1. To meet requirements under Hong Kong law, such as record-keeping or responding to regulatory requests.
• For Business Operations:
  1. To manage client relationships and contracts.
  2. To conduct internal audits or business planning.

We will not use your personal data for purposes beyond those described unless we obtain your consent or as permitted by law.

We may share your personal data in the following circumstances:

• With Service Providers: We engage trusted third parties, such as cloud hosting providers or IT support vendors, to assist in delivering our Services. These providers are bound by confidentiality agreements and only process data on our behalf.
• With Clients: If you are an authorized representative, we may share your details with your organization to manage access to our platforms.
• For Legal Purposes: We may disclose data to comply with legal obligations, respond to regulatory authorities, or protect our rights, such as in response to a court order.
• In Business Transfers: If NVT is involved in a merger, acquisition, or sale of assets, your data may be transferred to the relevant party, with safeguards to ensure continued protection.

We do not sell or rent your personal data to third parties for marketing purposes.

We take reasonable measures to protect your personal data from unauthorized access, loss, or misuse. These measures include:

• Encryption of data in transit and at rest, where applicable.
• Access controls to limit who can view or process your data.
• Regular security assessments and updates to our systems.
• Staff training on data protection best practices.

While we strive to maintain robust security, no system is completely immune to risks. If you have concerns about our security practices, please contact us.

Under the PDPO, you have the following rights regarding your personal data:

• Access: Request a copy of the personal data we hold about you.
• Correction: Request corrections to inaccurate or incomplete data.
• Objection: Object to certain uses of your data, where applicable.
• Erasure: Request deletion of your data, subject to legal or contractual obligations.

To exercise these rights, please contact us at [email protected] . We will respond within a reasonable timeframe, typically within 40 days, as required by the PDPO. If you are an end-user of a client’s services, please direct your request to the client, who controls your data.

We retain personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with legal obligations. For example:

• Client contact data is kept for the duration of our business relationship and up to 7 years thereafter, per Hong Kong record-keeping laws.
• Website usage data is retained for up to 12 months for analytics purposes.
• Billing records are kept for 7 years to meet tax requirements.

When data is no longer needed, we securely delete or anonymize it.

Your personal data may be stored or processed outside Hong Kong, such as in cloud servers managed by our service providers. When this occurs, we ensure appropriate safeguards are in place, such as:

• Contracts requiring equivalent data protection standards.
• Adherence to recognized frameworks or certifications.

We take steps to ensure your data remains protected regardless of its location.

Our website uses strictly necessary cookies for:

• Maintaining temporary session identification.
• Ensuring secure website operations.

These technical cookies are essential for core functionality and cannot be disabled. Continued use of the site indicates your acceptance of this necessary cookie usage.

Our website or Services may contain links to third-party websites or platforms. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before sharing personal data.

We may update this Privacy Policy to reflect changes in our practices or legal requirements. When we make material changes, we will notify you via email or a notice on our website before the changes take effect. Your continued use of our Services after such updates constitutes acceptance of the revised policy.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact our officer at:

We aim to respond to all inquiries promptly and in accordance with the PDPO.