TRIFINITY Advertising & Marketing Limited

Privacy Policy (Hong Kong & Macau)

Last Updated: December 2025

Trifinity Advertising & Marketing Limited ("Trifinity", "we", "us", or "our") is committed to protecting and respecting your personal data privacy. This Privacy Policy explains how we collect, use, store, and protect personal data in compliance with:

1.	The Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of Hong Kong ("PDPO").
2.	The Personal Data Protection Act (Law No. 8/2005) of Macau ("LPDP").

This policy applies to our website, our corporate operations, and the marketing, lead generation, and event management services we conduct on behalf of our enterprise clients across Hong Kong and Macau.

1. Our Role

Trifinity provides B2B services—such as corporate event management, email marketing, and lead generation—to enterprise clients who act as the Data Controllers. When we handle personal data strictly on behalf of a client like Dell, we process that data solely in accordance with our client’s explicit instructions, platform requirements, and the specific Data Processing Agreements in place.

2. Types of Personal Data We Collect

Depending on your interaction with us or our client campaigns, we may collect and process the following categories of business-related personal data:

•	Identity & Contact Data: Name, job title, company name, corporate email address, and phone number.
•	Event Registration Data: Attendance preferences, webinar logs, seminar selections, and event-related participation details.
•	Technical & Usage Data: Internet Protocol (IP) addresses, browser type, cookies, and digital interaction data from our campaign landing pages, event platforms, or digital forms.

We do not collect or process any sensitive or special categories of personal data (such as financial account details, health information, or government identification numbers) during our standard marketing operations.

3. How and Why We Use Your Data

We use personal data only for the explicit purposes disclosed at the time of collection, including:

•	Executing Lead Generation Campaigns: Identifying, qualifying, and validating business prospects for our corporate clients.
•	Email Marketing: Sending authorized B2B marketing communications, product updates, and promotional materials on behalf of our clients.
•	Event Management: Organizing, managing, and facilitating physical or virtual corporate events (including registration, attendance tracking, and follow-up communications).
•	Website Optimization: Analyzing website traffic and campaign engagement to improve user experiences.

Direct Marketing Compliance (HK & Macau Laws)

We strictly adhere to direct marketing regulations in both jurisdictions (HK PDPO Part 6A and Macau LPDP Article 12). We will never use your personal data for direct marketing purposes, or provide your data to third parties for direct marketing, without obtaining your explicit, prior, and voluntary consent.

4. Data Sharing and Cross-Border Transfers

We do not sell, rent, or trade your personal data to third parties. We share personal data only under the following secure conditions:

•	With Our Corporate Clients: Data collected during joint or client-branded campaigns (e.g., lead generation forms or event registrations) is securely transferred back to the respective client hosting the campaign.
•	With Client-Approved Systems: To minimize risk, we process campaign data directly within secure, enterprise-approved environments provisioned and controlled by our clients (such as Dell-approved systems).
•	Legal Requirements: When required to do so by applicable laws, regulations, or government authorities in Hong Kong or Macau.

5. Security and Data Retention

We implement industry-standard technical and organizational security measures to protect personal data from unauthorized access, accidental loss, alteration, or destruction. We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or to satisfy the strict contractual requirements of our enterprise clients and applicable regional legal schedules. Once data is no longer contractually or legally required, it is securely deleted or completely anonymized.

6. Your Rights Under Hong Kong & Macau Law

Under the Hong Kong PDPO and Macau LPDP, you have strong rights regarding your personal data, which you can exercise at any time for free:

•	Right of Access: You have the right to request confirmation on whether we hold your personal data and request a copy of that data.
•	Right of Correction / Rectification: You have the right to request the correction of any inaccurate, outdated, or incomplete personal data.
•	Right to Object / Opt-Out: You have the absolute right to object to your data being used for direct marketing or profiling purposes.
•	Right to Erasure (Macau LPDP): Under specific legal conditions in Macau, you may request the deletion of your personal data when it is no longer required for the purpose it was collected.

7. Contact Us

If you wish to exercise any of your data privacy rights, or if you have any questions regarding how your data is handled across our Hong Kong and Macau operations, please contact our privacy lead at +852 2866 4500.