Privacy Policy of Harbourline Painting Solutions

Effective Date: 20 May 2026

1. Introduction and Company Information

This Privacy Policy explains how Harbourline Painting Solutions (“we”, “us”, “our”) collects, uses, stores, discloses, and protects personal data in connection with our painting services and related business operations in Hong Kong.

We are committed to handling personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and the Data Protection Principles set out therein.

Data Controller / Operator: Harbourline Painting Solutions

Address: Harbourline Painting Solutions, 12/F, China Hong Kong City, 33 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong

Email: [email protected]

Phone: +852 2867 4938

2. Data Collection and Processing

We may collect and process the following categories of personal data, depending on your interaction with us:

• Identification and contact details: name, company name, email address, phone number, postal address, and other contact information.
• Service-related information: property address, project requirements, preferred colours, scope of work, quotations, site access details, scheduling information, and communications relating to painting services.
• Billing and payment information: invoice details, payment records, and transaction-related information.
• Technical and usage data: IP address, browser type, device information, and website usage data if you visit our website or interact with our online forms.
• Correspondence and records: emails, messages, call notes, complaint records, feedback, and other communications.
• Images and site documentation: photographs or videos of premises, surfaces, or completed work where necessary for quotations, project planning, quality control, or dispute handling.

We generally collect personal data directly from you, such as when you contact us, request a quotation, book services, make payments, submit feedback, or communicate with us. We may also receive personal data from third parties such as property managers, contractors, suppliers, or payment service providers where relevant to our services.

Where you provide personal data of another person, you should ensure that you have the authority to do so and that the person is aware of this Privacy Policy.

3. Purpose of Data Processing

We process personal data for the following purposes:

• to respond to enquiries and provide quotations;
• to assess, plan, schedule, and deliver painting and related services;
• to communicate with clients, site contacts, contractors, and suppliers;
• to prepare contracts, invoices, receipts, and other business records;
• to process payments and manage accounts;
• to arrange site visits, inspections, and project coordination;
• to maintain service quality, handle complaints, and resolve disputes;
• to comply with legal, regulatory, tax, accounting, and record-keeping obligations;
• to protect our business, staff, clients, and property from fraud, misuse, or security incidents;
• to improve our services, operations, customer experience, and internal processes;
• to send administrative or service-related communications;
• to support lawful business transfers, reorganisations, or asset transactions, where applicable.

We will not use personal data for purposes that are incompatible with the original purpose of collection unless permitted or required by law or with your consent where necessary.

4. Legal Basis for Processing

Under Hong Kong law, we process personal data in a manner consistent with the PDPO and the Data Protection Principles. Depending on the context, our processing is based on one or more of the following grounds:

• Performance of a contract: where processing is necessary to provide quotations, enter into agreements, or deliver painting services.
• Legitimate business interests: where processing is necessary for our ordinary business operations, service improvement, fraud prevention, security, and record management, provided such interests are not overridden by your rights and interests.
• Compliance with legal obligations: where processing is required to comply with applicable laws, regulations, tax rules, accounting requirements, court orders, or lawful requests from authorities.
• Consent: where we rely on your consent for specific optional activities, such as certain marketing communications or the use of images beyond operational necessity.

Where consent is the basis for processing, you may withdraw it at any time, subject to legal or contractual restrictions.

5. Data Sharing and Third Parties

We may disclose personal data to the following categories of recipients where necessary for the purposes described in this Privacy Policy:

• employees, management, and authorised personnel of Harbourline Painting Solutions;
• subcontractors, painters, site supervisors, and other service providers assisting with project delivery;
• suppliers of paint, materials, equipment, and related products;
• accountants, auditors, lawyers, insurers, and professional advisers;
• payment processors, banks, and financial institutions;
• IT, cloud hosting, communications, and data storage service providers;
• property owners, property managers, building management offices, or site contacts where necessary to perform services;
• government authorities, regulators, law enforcement agencies, or courts where required by law or to protect our legal rights.

We require third parties who process personal data on our behalf to protect it appropriately and to use it only for authorised purposes. However, where third parties act as independent data users, their own privacy policies and practices may apply.

6. Data Transfer to Third Countries

We primarily store and process personal data in Hong Kong. In some cases, personal data may be transferred to, stored in, or accessed from jurisdictions outside Hong Kong, for example where we use overseas cloud services, email systems, software providers, or technical support services.

Where such transfers occur, we will take reasonable steps to ensure that the recipient provides a standard of protection comparable to that required under Hong Kong law, including appropriate contractual, technical, and organisational safeguards where practicable.

By using our services or communicating with us, you acknowledge that cross-border transfers may occur as part of our business operations.

7. Storage Duration

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law, contract, accounting, insurance, or dispute-resolution needs.

In general, retention periods may include:

• Quotation and enquiry records: retained for a reasonable period to manage follow-up, customer service, and business records.
• Contract, project, and invoice records: retained for the period required by applicable legal, tax, accounting, and business obligations.
• Correspondence and complaint records: retained for as long as necessary to address the matter and for a further period where needed for legal defence or audit purposes.
• Marketing-related data: retained until you opt out or withdraw consent, subject to legal requirements.

When personal data is no longer required, we will take reasonable steps to delete, anonymise, or securely destroy it.

8. User Rights

Subject to the PDPO and any applicable exemptions, you may have the following rights in relation to your personal data:

• Access: to request access to personal data we hold about you.
• Rectification: to request correction of inaccurate, incomplete, or outdated personal data.
• Erasure: to request deletion of personal data where it is no longer necessary or where deletion is otherwise permitted by law.
• Restriction: to request that we limit the processing of your personal data in certain circumstances.
• Data portability: to request a copy of certain personal data in a structured, commonly used format where applicable and technically feasible.
• Objection: to object to certain processing activities, including direct marketing where applicable.

To exercise any of these rights, please contact us using the details provided below. We may need to verify your identity before responding. We will respond within a reasonable time and in accordance with applicable law.

9. Withdrawal of Consent

Where we rely on your consent to process personal data, you may withdraw that consent at any time by contacting us. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

Please note that if you withdraw consent for certain data processing activities, we may not be able to provide some services or communications that depend on that consent.

10. Right to Complain

If you believe that we have handled your personal data in a manner that does not comply with the PDPO or this Privacy Policy, you may contact us first so that we can investigate and address your concern.

You also have the right to lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (“PCPD”).

PCPD Website: https://www.pcpd.org.hk

11. Data Security

We implement reasonable technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures may include:

• access controls and role-based permissions;
• password protection and secure authentication practices;
• secure storage and backup procedures;
• confidentiality obligations for staff and contractors;
• regular review of operational and security practices;
• careful selection of service providers with appropriate safeguards.

However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect personal data, we cannot guarantee absolute security.

12. Contact Information

If you have any questions, requests, or concerns regarding this Privacy Policy or our handling of personal data, please contact:

Harbourline Painting Solutions
12/F, China Hong Kong City, 33 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong
Email: [email protected]
Phone: +852 2867 4938

13. Changes to Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or operational needs. Any revised version will be posted on our website or otherwise made available to you, with the updated effective date where appropriate.

We encourage you to review this Privacy Policy periodically to stay informed about how Harbourline Painting Solutions protects your personal data.