Privacy Policy

1. Who we are

AirPalm Limited is the data controller for the activities described in this Policy. It is a private company limited by shares incorporated in Hong Kong on 2 April 2015. Our registered office is Flat 2, 19/F, Henan Building, 90–92 Jaffe Road, Wan Chai, Hong Kong.

Privacy questions and requests may be sent to privacy@airpalm.com.

2. Personal data we collect

• Business contact data, including your name, work email address, telephone number, country or region.
• Professional data, including company name, job title, team size, industry and business interests.
• Inquiry data, including the product or solution requested, message, meeting preferences and correspondence.
• Technical and usage data, including IP address, browser and device information, language, access time, referring page, pages viewed, cookie identifiers and consent preferences.
• Marketing attribution data, such as campaign and referral parameters, when used.
• Other information that you choose to provide. Please do not submit sensitive personal data through a general inquiry form.

3. How we collect and use personal data

We collect personal data directly from you, automatically through our website and permitted cookies or similar technologies, from your organisation, and from business partners or public business sources where lawful.

Why we use it

• To respond to inquiries, arrange demonstrations and provide requested information.
• To qualify, assign and follow up business leads and maintain related sales records.
• To operate, secure, troubleshoot and improve the website and our communications.
• To measure website use and campaign performance where permitted and, where required, after consent.
• To send business marketing communications where permitted. You may unsubscribe at any time.
• To comply with law, protect rights and security, and establish, exercise or defend legal claims.

Where applicable law requires a legal basis, we rely on steps taken at your request, our legitimate interests in operating a business-to-business website and responding to prospective customers, consent, and compliance with legal obligations. We use consent where required for non-essential cookies or direct marketing.

4. How we share personal data

We share personal data only as reasonably necessary with companies supporting website hosting, security, communications, scheduling, analytics, professional advice and customer relationship management. We may also share data with affiliates, transaction counterparties and public authorities where legally required. Service providers must process data for agreed purposes and protect it appropriately.

Website leads are transferred to the Qince lead-management platform for storage, lead assignment and sales follow-up. AirPalm Limited determines the purposes and essential means of processing those website leads. Qince and its supporting service providers process data to provide the platform and related services.

We do not sell personal data for money. If future advertising activities constitute a sale, sharing or targeted advertising under an applicable law, we will provide the required notice and opt-out method before using the data in that way.

International transfers

AirPalm is based in Hong Kong and serves businesses internationally. Website lead data entered into Qince may be processed or stored in mainland China. Other service providers may process data in additional countries. Where required, we use contracts, consent or other recognised safeguards and assess whether the recipient provides protection required by applicable law.

5. Retention and security

If a website inquiry does not become an active sales opportunity, we retain the lead for six months after the last meaningful interaction and then delete or anonymise it. We may retain information longer where an active business relationship continues or where necessary for contracts, accounting, security, legal obligations, complaints or disputes. Cookie consent records, suppression records and security logs are kept for periods reasonably necessary for their specific purposes and applicable law.

We use reasonable administrative, technical and organisational measures appropriate to the nature and risk of the data, including access controls, transmission security, logging, backups and service-provider oversight. No internet service can guarantee absolute security.

6. Your rights and choices

Depending on where you are located, you may have rights to request access, correction, deletion, restriction or portability; object to certain processing; withdraw consent; opt out of marketing; and complain to a competent authority. These rights may be subject to legal conditions and exceptions.

Send requests to privacy@airpalm.com. We may verify your identity and authority before responding. We will respond within the period required by applicable law. You may unsubscribe from marketing through the link in a message and manage non-essential cookies through the Manage cookies control.

Cookies

We use cookies and similar technologies as described in the Airpalm Cookie Policy. Where consent is required, non-essential technologies remain disabled until you enable them.

Children

The website is intended for business users and is not directed to children. We do not knowingly collect personal data from children through website inquiry forms. Contact us if you believe a child has submitted personal data.

7. Regional information

Hong Kong

Where the Personal Data (Privacy) Ordinance applies, we process personal data in accordance with the applicable Data Protection Principles. At collection, we identify the purpose, whether requested information is required or optional, relevant transferee classes, and the method for requesting access and correction. We do not use personal data for a new purpose without the consent required by law.

Indonesia

Where Indonesia Law No. 27 of 2022 applies, we provide required information about the controller, purposes, legal basis, data categories, retention, processing and rights. We support applicable rights including access, correction, withdrawal of consent, restriction, deletion or destruction, objection to certain automated decisions and portability, subject to law. We apply appropriate safeguards to cross-border transfers and notify qualifying personal data breaches within the period required by Indonesian law. A Bahasa Indonesia version should be read together with this English version for the Indonesian website.

European Economic Area and United Kingdom

Where the GDPR or UK GDPR applies, you may exercise the rights described above and complain to your local supervisory authority. Transfers use an adequacy decision, approved contractual clauses or another valid mechanism where required. We will identify a representative if applicable law requires one.

Singapore

Where Singapore's Personal Data Protection Act applies, we notify purposes, provide withdrawal and access or correction methods, protect the data, limit retention and use comparable protection for overseas transfers.

California

If AirPalm becomes subject to the California Consumer Privacy Act, California residents may have rights to know, delete and correct personal information and to opt out of sale or sharing. We will provide any additional notice and request methods required at that time.

8. Changes and contact

We may update this Policy when our practices or legal obligations change. We will post the revised version and effective date and provide additional notice where required.