BLR Trading Limited ("BLR Trading", "we", "us") respects the privacy of every visitor, client, partner, and candidate who interacts with us. This policy explains what personal data we collect, how we use it, and the rights you hold over it.
01Who this policy applies to
This policy applies to personal data we process about:
- Visitors to blr-trading.com;
- Representatives of our clients, prospects, and commercial partners;
- Candidates who apply for roles at BLR Trading;
- End users whose data is processed on behalf of our clients in the course of media buying, attribution, and audience operations (where we act as a processor).
02Personal data we collect
We collect personal data directly from you when you contact us, exchange business correspondence, sign an engagement, or otherwise interact with our services. We also receive data from our clients and from advertising and analytics platforms we operate.
Identification and contact data
Name, work email, company, role, and any business communications you send us.
Commercial data
Engagement scope, contracts, invoices, and records of services delivered.
Technical data
IP address, browser type, device identifiers, referring URL, and timestamps captured by our servers and standard web logs.
Platform & campaign data
Aggregate and pseudonymous campaign performance metrics, including impressions, clicks, conversions, and audience attributes, accessed via the advertising platforms operated on behalf of our clients.
03How we use it
- To respond to enquiries and operate our commercial relationship with you;
- To deliver the services we are engaged to provide, including media buying, attribution analysis, and reporting;
- To meet our legal, accounting, tax, and regulatory obligations in Hong Kong and the jurisdictions in which we operate;
- To improve our services, our site, and our internal operations;
- To protect our rights, our clients, and the integrity of the platforms we work with.
04Lawful bases
Where the EU General Data Protection Regulation or the UK GDPR applies to our processing, we rely on the following lawful bases: contract (to perform an engagement); legitimate interests (to operate, secure, and grow our business in a balanced way); legal obligation (to meet tax, accounting, and regulatory requirements); and consent (where we have asked for it). For Hong Kong residents, our processing is governed by the Personal Data (Privacy) Ordinance (Cap. 486).
05Sharing & transfers
We share personal data only where it is necessary to operate our services or meet our legal obligations. Recipients include:
- Clients on whose behalf we deliver services;
- Advertising platforms we operate, including Meta, Google, TikTok, Taboola, Outbrain, Yahoo Native, Microsoft Ads, LinkedIn, and similar networks, and the affiliate networks we work with;
- Service providers who support our operations (cloud hosting, accounting, legal counsel, payment processors);
- Authorities, where required by law or to defend a legal claim.
Because we operate globally, personal data may be transferred outside the jurisdiction in which it was collected. Where required, we put appropriate safeguards in place, including Standard Contractual Clauses for transfers from the EEA and UK.
06Retention
We keep personal data for as long as it is needed for the purposes for which it was collected, plus any period required by applicable law (typically seven years for commercial records under Hong Kong tax and accounting rules). When retention is no longer required, data is securely deleted or anonymised.
07Your rights
Depending on where you live, you may have the right to access, correct, port, restrict, or delete personal data we hold about you, and to object to certain processing. You can also withdraw consent at any time where we rely on it.
To exercise any of these rights, email privacy@blr-trading.com. We aim to respond within thirty days. You also have the right to complain to the Office of the Privacy Commissioner for Personal Data in Hong Kong, or to a supervisory authority in your country of residence.
08Security
We apply reasonable technical and organisational measures to protect personal data against loss, misuse, and unauthorised access. These include access controls, encryption in transit, vendor due diligence, and ongoing staff training. No system is perfectly secure, but we take this responsibility seriously.
09Cookies & analytics
Our website does not currently set advertising or tracking cookies. We may use limited first-party analytics to understand how the site is used, on the basis of legitimate interests. Where required by law, we will request your consent before deploying any non-essential cookies.
10Changes & contact
We may update this policy from time to time. The "last updated" date at the top reflects the most recent revision. Material changes will be communicated through our website.
For any privacy-related question, contact:
BLR Trading LimitedAttn: Privacy
RM 705, 7/F, Fa Yuen Commercial Building
Nos. 75–77, Fa Yuen Street
Kowloon City, Hong Kong
privacy@blr-trading.com