Privacy Policy

Privacy Policy – Hong Kong

Who is Responsible for Data Processing and How Can I Contact Them?

‍The entity responsible for data processing is
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‍Meteor Commodities Limited,

and you can reach our Privacy Officer at:
‍
Email: info@meteorcommodities.com

‍What Sources and Data Do We Use?

‍We process personal data obtained from our clients in the course of our business relationship. Additionally, we may process data from publicly available sources (e.g., business registers, press, internet) or data lawfully provided by third parties such as KYC and due diligence providers. This data may include personal details (name, address, contact information, date and place of birth, nationality), identification details (passport/ID information), authentication data (e.g., signatures), transaction and contract data, marketing preferences, and compliance-related information.We also utilize Google Analytics to analyze site usage and improve user experience, ensuring all data collected is anonymized.

‍Purpose of Data Processing and Legal Basis

‍We process personal data in accordance with Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) and other applicable data protection regulations:

- To Fulfill Contractual Obligations: Processing data is necessary to provide commodity trading and financial services, including needs assessments, client support, and transaction execution.
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- Legitimate Interests: We process data beyond contract fulfillment for purposes such as market research, legal claims, IT security, crime prevention, business development, and risk management. We may also use publicly available sources for client acquisition.

- With Your Consent: Where consent is provided (e.g., marketing communications or transaction analysis), data processing is lawful until consent is withdrawn. Withdrawal does not affect past processing activities.

‍Legal and Regulatory Compliance: As a commodity trading firm, we comply with various legal obligations (e.g., Hong Kong’s Anti-Money Laundering and Counter-Terrorist Financing Ordinance) requiring identity verification, fraud prevention, tax reporting, and regulatory audits.

‍Who Receives My Data?

Data is shared only with authorized service providers and regulatory bodies, where necessary, for contract fulfillment and compliance. These may include IT service providers, financial institutions, logistics partners, consultants, legal advisors, and auditors, all of whom are bound by confidentiality obligations.

‍Will Data Be Transferred Internationally?

We may transfer data outside Hong Kong to fulfill transactions, comply with legal requirements, or where client consent is given. Any international data transfer complies with applicable data protection laws and safeguards.

‍How Long Will My Data Be Stored?

‍We retain personal data as long as necessary to fulfill contractual and legal obligations. If no longer required, data is deleted unless needed for:
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- Regulatory retention obligations under commercial and tax laws.
- Legal holds requiring indefinite retention for compliance and dispute resolution.

‍What Are My Data Privacy Rights?

You have the right to access, correct, erase, restrict processing, and object to data processing. If applicable, you may also have the right to data portability and the right to lodge a complaint with the relevant data protection authority in Hong Kong.

‍Am I Required to Provide Data?

‍Providing certain personal data is necessary for contract execution and regulatory compliance. Anti-money laundering laws require identity verification before entering a business relationship. Failure to provide required information may prevent us from offering services.

‍Automated Decision-Making & Profiling

‍We do not use automated decision-making in establishing client relationships. However, we may use profiling for regulatory compliance, fraud prevention, and risk assessment in accordance with applicable laws.

For further inquiries regarding data protection, please contact our Privacy Officer at info@meteorcommodities.com.