# Privacy Policy of Loctranslation
Effective Date: August 4, 2026
Jurisdiction: Hong Kong Special Administrative Region, China
Governing Laws: Hong Kong Personal Data (Privacy) Ordinance (Chapter 486, PDPO), General Data Protection Regulation (GDPR) of the European Union, and internationally recognized data protection standards

## 1. Introduction
Loctranslation (“we”, “us”, “our”) is a Hong Kong-based enterprise focusing on Traditional Chinese translation, multilingual localization, document proofreading and linguistic refinement services. We attach great importance to the protection of personal information, business confidential documents and privacy of website visitors, clients, freelance translators, partners and other data subjects.

This Privacy Policy defines how we collect, store, use, disclose and protect your personal data and confidential materials. By accessing our official website loctranslation.com, submitting translation requests, consulting quotations, registering accounts, signing service contracts or receiving any services provided by us, you acknowledge that you have fully read, understood and unconditionally agreed to all terms of this Policy. If you disagree with any clauses herein, please stop using our website and all our services immediately.

## 2. Definition of Key Terms
1. **Personal Data**: As defined under Hong Kong PDPO, any information that can directly or indirectly identify a living natural person, including full name, email address, phone number, residential address, ID/passport number, bank account information, job title, signature, profile pictures and other identifiable personal information.
2. **Confidential Client Materials**: Manuscripts, product documents, commercial plans, project drafts, source codes, internal business files and other non-public materials entrusted to us for translation and localization processing. Such content is protected by our internal confidentiality rules in addition to personal data regulations.
3. **Data Subject**: The natural person to whom personal data belongs.
4. **Data Processing**: Any operation on personal data including collection, recording, storage, arrangement, access, transmission, sharing, amendment, deletion and permanent destruction.
5. **Third-Party Processors**: Authorized service providers commissioned by us, including cloud server providers, enterprise email service providers, payment institutions, encrypted transmission platforms and collaborative office tools.

## 3. Information We Collect
### 3.1 Information You Voluntarily Submit
We collect information you actively provide when you consult cooperation, place orders, sign contracts or apply for translator cooperation:
– Basic contact information: name, company name, email, mobile phone number, mailing address, official website;
– Billing & contractual information: billing title, bank account, tax information, identity certification of contract signatories;
– Translator cooperation information: resume, qualification certificates, bank account, portfolio and identity verification documents;
– Project materials: translation manuscripts, demand notes, term banks, project briefs and customized localization requirements.

### 3.2 Automatically Collected Technical Information
When you browse our website, we automatically collect non-sensitive technical data via cookies and website logs: visitor IP address, device model, browser type, access time, page browsing track and stay duration. Such data is only used for website operation optimization, access statistics and anti-abuse management, and will not be associated with your sensitive personal data.

### 3.3 Collection Restriction
We will not actively collect personal data of minors under 16 years old. If personal information of minors is submitted without guardian consent, we reserve the right to delete such information without prior notice.

## 4. Purpose of Data Usage
All collected personal data and client materials shall only be applied to the following legitimate purposes, and shall never be used for irrelevant purposes without your explicit written consent:
1. Deliver translation, localization, proofreading and linguistic polishing services, track project progress and communicate technical details;
2. Process order settlement, invoice issuance, payment collection and financial accounting;
3. Conduct identity verification for cooperating translators and management of cooperation relations;
4. Respond to customer consultation, after-sales service, complaint handling and technical support;
5. Optimize website experience, maintain network security, prevent fraud, malicious attacks and illegal use of our platform;
6. Comply with legal obligations under Hong Kong PDPO, GDPR and other applicable laws;
7. Send necessary service reminders, order notifications and routine business communication (we will never send spam marketing emails without your opt-in permission).

## 5. Information Storage & Security Protection
1. **Storage Period**
Personal data will be retained only for the period necessary to fulfill service contracts and legal obligations:
– Ordinary client contact information: reserved for 7 years after the completion of the last order for after-sales traceability;
– Translator cooperation information: reserved during the cooperation period plus 5 years after cooperation termination;
– Project manuscripts: original manuscripts will be permanently deleted 30 working days after project delivery upon client request; if no deletion instruction is received, manuscripts will be encrypted and archived for a maximum of 3 years for revision services only.

2. **Security Measures**
– We adopt end-to-end encryption for document transmission, encrypted cloud storage, access permission classification and regular server security inspection;
– Internal employee access to confidential materials is strictly limited with identity authentication and operation logs; all staff sign non-disclosure agreements;
– Third-party processors are required to sign data protection agreements and meet international security standards; we conduct regular security audits on partners.

## 6. Information Disclosure & Sharing Principles
We will never sell, rent or trade your personal data and confidential commercial materials to unrelated third parties. We may disclose your information only under the following limited circumstances:
1. Obtain your explicit written authorization before sharing data with designated third parties;
2. Authorized third-party processors need data to provide commissioned services for us, with binding confidentiality obligations;
3. Required by Hong Kong judicial authorities, law enforcement agencies or statutory legal procedures;
4. Protect legitimate rights of Loctranslation, clients and the public against fraud, infringement and safety threats.

## 7. Rights of Data Subjects
In accordance with PDPO and GDPR, you enjoy the following rights free of charge:
1. **Access Right**: Request a copy of your personal data stored by us;
2. **Rectification Right**: Ask us to correct inaccurate or incomplete personal information;
3. **Erasure Right**: Apply for permanent deletion of your personal data when the storage purpose is fulfilled;
4. **Restriction of Processing Right**: Request to suspend data processing under legitimate reasons;
5. **Data Portability Right**: Obtain your data in standard readable format for transmission to other institutions;
6. **Opt-out Right**: Unsubscribe business marketing emails at any time;
7. **Objection Right**: Raise objections against illegal data processing activities.

You may submit applications via official email for privacy-related requests, and we will reply and handle valid applications within 15 working days.

## 8. Cross-border Data Transmission
Our clients cover global regions including Europe, Southeast Asia and North America. When cross-border data transmission is required:
1. We ensure overseas data recipients meet GDPR and local data protection requirements;
2. All cross-border transmission of confidential manuscripts adopts encrypted channels;
3. We will not transmit sensitive personal data to regions lacking adequate data protection certification without your consent.

## 9. Cookie Policy
Cookies are used only to record browsing preferences and improve website experience. You can disable cookies through browser settings at any time, but partial website functions may be restricted after disabling. We will not use cookies to collect sensitive personal information.

## 10. Amendment to This Privacy Policy
We reserve the right to revise this Privacy Policy according to law updates and business adjustments. Updated versions will be published on our official website with updated effective date. Continued use of our services after revision release means your acceptance of the updated policy.

## 11. Contact Information for Privacy Inquiries
Official Email: [Reserved Official Business Mailbox of Loctranslation]Registered Address: Hong Kong
Privacy Compliance Person: Dedicated Data Protection Officer of Loctranslation