Privacy Policy

Trax Concierge ("Trax", "we", "us", "our") is a private concierge and sourcing service operating from Hong Kong with international clientele. We take the privacy of our clients and prospective clients with the utmost seriousness. This Privacy Policy describes how we collect, use, retain, and disclose personal information.

This policy applies to information collected through our website (trax-concierge.com), our messaging channels (telephone, WhatsApp, email), and any communications conducted in the course of providing our services.

I.Information We Collect

In the ordinary course of providing our services, we may collect the following categories of personal information:

• Identification & Contact Data: name, postal address, email address, telephone numbers, WhatsApp identifiers, nationality, residency.
• Transactional Data: details of services requested, items sourced, preferences expressed, communication history with our advisors.
• Financial Data: payment instructions, banking coordinates, source-of-funds documentation where required by anti-money-laundering ("AML") regulations.
• Identity Verification Data: for AML and Know-Your-Client ("KYC") obligations, we may collect government-issued identification, proof of address, and beneficial ownership information.
• Technical Data: IP addresses, browser type, device information, and pages visited, collected automatically through our website.

II.How We Use Your Information

We process personal information only for legitimate business purposes, including:

• Providing the concierge, sourcing, and advisory services you request from us.
• Communicating with you regarding ongoing or prospective mandates.
• Fulfilling our regulatory and legal obligations, including AML, KYC, and sanctions screening.
• Maintaining business records and managing client relationships.
• Improving our services and tailoring them to client preferences.
• Protecting our legitimate business interests, including fraud prevention and dispute resolution.

We do not engage in profiling for marketing purposes, do not sell client data to third parties, and do not use personal information for unsolicited promotional communications.

III.Legal Basis for Processing

For clients located within the European Economic Area, the United Kingdom, or other jurisdictions with comprehensive privacy frameworks, we process personal information on the following legal bases:

• Performance of a contract — to provide services you have requested.
• Legal obligation — to comply with AML, tax, and other regulatory requirements.
• Legitimate interests — for business administration, security, and fraud prevention, where these interests do not override your rights.
• Consent — where required, for example for non-essential cookies or marketing communications.

IV.Disclosure to Third Parties

Trax does not sell personal information. We may share information with:

• Service partners strictly as necessary to fulfil your specific instructions (e.g., a vendor of a sourced item, a private aviation operator, a property agent).
• Professional advisors such as legal counsel, accountants, and auditors, under professional confidentiality obligations.
• Regulatory authorities where required by law, including in response to valid legal process.
• Banking partners for the purpose of executing transactions you have authorised.

All third-party service partners are bound by contractual confidentiality obligations, and we share only the minimum information necessary to perform the requested service.

V.International Data Transfers

As an international concierge, we frequently transfer personal information across jurisdictions to fulfil client mandates. Where personal information is transferred outside the European Economic Area, the United Kingdom, or other regulated jurisdictions, we implement appropriate safeguards including standard contractual clauses, adequacy decisions where applicable, and reliance on derogations such as the necessity of contract performance.

VI.Data Retention

We retain personal information only for as long as necessary to fulfil the purposes for which it was collected, including any legal, accounting, or reporting requirements. Specifically:

• Active client records are retained for the duration of the relationship and a minimum of seven years thereafter, in line with Hong Kong record-keeping obligations.
• AML and KYC documentation is retained for a minimum of five years following the end of the business relationship.
• Marketing-related data is retained until consent is withdrawn or for a maximum of three years.

VII.Your Rights

Depending on your jurisdiction of residence, you may have the following rights:

• Right of access — to obtain confirmation of whether we hold information about you and a copy of that information.
• Right of rectification — to correct inaccurate or incomplete information.
• Right of erasure — to request deletion of your information, subject to our legal retention obligations.
• Right to restrict processing — to limit how we use your information in certain circumstances.
• Right to data portability — to receive your information in a structured, machine-readable format.
• Right to object — to processing carried out on the basis of legitimate interests.
• Right to withdraw consent — where processing is based on consent.

To exercise any of these rights, please contact us using the details below. We will respond within thirty days.

VIII.Cookies & Website Tracking

Our website uses minimal cookies — strictly necessary cookies for site functionality, and where applicable, analytics cookies to understand site usage. We do not use advertising or tracking cookies. You may disable cookies through your browser settings.

IX.Security

We implement appropriate technical and organisational measures to protect personal information, including encryption of communications, restricted access on a need-to-know basis, secure storage of physical documents, and regular review of our security practices. Despite these measures, no system can be guaranteed completely secure, and we encourage clients to use encrypted channels (such as WhatsApp end-to-end encryption) for sensitive communications.

X.Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. Material changes will be communicated to active clients directly. The most current version is always available on our website.