Privacy Policy
Tai Wo Management Limited
Effective Date: 1 Aug 2025
Last Updated: 1 Aug 2025
1. Introduction
Tai Wo Management Limited, a company duly incorporated and existing under the laws of Hong Kong Special Administrative Region (“we,” “our,” “us,” or the “Company”), is committed to protecting and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and protect your personal data when you access our website at https://taiwo.hkcot.com/, engage our consulting services, utilize our taxi rental services, or interact with us through various communication channels including but not limited to Facebook, WhatsApp Business, and other social media platforms.
This Privacy Policy has been prepared in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and constitutes our commitment to protecting your personal data in compliance with all applicable data protection laws and regulations in Hong Kong.
By using our services or providing us with your personal data, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein.
2. Definitions and Interpretation
For the purposes of this Privacy Policy, “personal data” means any data relating directly or indirectly to a living individual from which it is practicable to ascertain the identity of the individual, and in respect of which the individual is the data subject. This definition aligns with the PDPO and encompasses all information that we collect about you through your interaction with our services.
The terms “data processor,” “data subject,” and “processing” shall have the meanings ascribed to them under the PDPO and other applicable data protection legislation.
3. Information We Collect
In the course of providing our services, we collect various categories of personal data. The personal information that you provide directly to us includes your full name, contact details including email addresses, telephone numbers, and physical addresses, business information such as company name, job title, and business address, and service-related information including taxi booking details, pickup and drop-off locations, preferred routes, and special requirements. We also collect payment information, which may include credit card details and billing information, though such sensitive financial data is processed through secure, PCI-compliant payment processors. Additionally, we maintain records of your consultations with us, including business requirements, project specifications, and consultation notes, as well as all communication records such as email correspondence, WhatsApp messages, and telephone call logs.
Our systems automatically collect certain information when you interact with our digital platforms. This includes device information such as your IP address, browser type and version, operating system, and device identifiers. We also collect usage data including pages visited, time spent on each page, click patterns, and navigation paths through our website. When you use our taxi services and grant us permission, we may collect location data through GPS technology to facilitate service delivery and improve route optimization. Our website employs cookies and similar tracking technologies, including session cookies for maintaining your logged-in state and analytics cookies for understanding user behavior and improving our services.
We may also receive information about you from third-party sources, including social media platforms when you interact with our official accounts on Facebook, WhatsApp Business, or other platforms, business verification information from publicly available sources and commercial databases, and references or recommendations from existing clients or business partners.
4. Legal Basis and Purposes of Processing
We process your personal data on several legal bases as recognized under the PDPO and international data protection standards. The primary legal basis for most of our processing activities is the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract. This includes processing necessary to deliver our taxi services, provide consulting solutions, manage bookings and appointments, and process payments.
We also process personal data where necessary for compliance with legal obligations to which we are subject, including maintaining business records as required under Hong Kong law, complying with tax and accounting regulations, responding to lawful requests from law enforcement agencies, and fulfilling our obligations under transportation and business licensing requirements.
Furthermore, we process personal data based on our legitimate interests, provided such interests are not overridden by your fundamental rights and freedoms. Our legitimate interests include improving and optimizing our services, ensuring the safety and security of our operations, conducting internal business analysis and reporting, preventing fraud and maintaining cybersecurity, and managing our business relationships effectively.
Where required by law or where we process personal data for purposes beyond those originally notified to you, we will obtain your explicit consent. This particularly applies to marketing communications, the use of cookies for analytics purposes, and any sharing of your data with third parties beyond what is necessary for service delivery.
5. Data Sharing and International Transfers
We maintain strict controls over the sharing of your personal data and only disclose it to third parties in specific circumstances and with appropriate safeguards. We engage various service providers who assist us in delivering our services, including payment processors who handle transaction processing under strict security standards, cloud infrastructure providers who host our data with enterprise-level security measures, information technology service providers who maintain our systems and ensure their security, and professional advisors including lawyers, accountants, and auditors who are bound by professional confidentiality obligations.
In the context of our taxi services, we share limited information with our network of affiliated drivers to facilitate service delivery. Such information is restricted to what is necessary for the specific journey and is subject to confidentiality agreements. For our consulting services, we may engage partner consultants or specialists, but only with your prior consent and under appropriate confidentiality arrangements.
We may be required to disclose your personal data to comply with legal obligations, including responding to subpoenas, court orders, or other legal processes, cooperating with law enforcement agencies in criminal investigations, meeting regulatory requirements imposed by the Transport Department or other relevant authorities, and protecting our rights, property, or safety, or that of our clients, employees, or others.
Your personal data may be transferred to and processed in jurisdictions outside of Hong Kong. When such transfers occur, we ensure that appropriate safeguards are in place, including the use of standard contractual clauses approved by relevant data protection authorities, ensuring that the receiving jurisdiction provides an adequate level of data protection, or obtaining your explicit consent for the transfer where required.
6. Data Security and Retention
We have implemented comprehensive technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security measures include encryption of data both in transit using SSL/TLS protocols and at rest using industry-standard encryption algorithms, multi-factor authentication for access to systems containing personal data, regular security assessments and penetration testing conducted by qualified third parties, continuous monitoring of our systems for suspicious activities, and comprehensive incident response procedures to address any potential data breaches.
All employees who have access to personal data receive regular training on data protection principles and are bound by confidentiality obligations that survive the termination of their employment. We maintain strict access controls based on the principle of least privilege, ensuring that personal data is only accessible to those who need it for legitimate business purposes.
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal requirements. Our retention periods are determined based on the nature of the data and applicable legal requirements. Customer records and transaction data are retained for seven years after the last service provision to comply with Hong Kong business record-keeping requirements. Marketing contact lists are maintained until you opt out or after three years of inactivity, whichever comes first. CCTV footage, where applicable in our premises or vehicles, is retained for thirty days unless required for a specific investigation or legal proceeding. Consultation records and project documentation are retained for seven years after project completion to manage potential disputes and comply with professional standards.
Upon expiration of the applicable retention period, personal data is securely destroyed using methods appropriate to the sensitivity of the information, including secure deletion of electronic records and confidential shredding of physical documents.
7. Your Rights and Choices
Under the PDPO, you have significant rights regarding your personal data. You have the right to access your personal data and request a copy of the information we hold about you. We will respond to such requests within forty days as required by law, though we may charge a reasonable fee for processing your request if permitted under the PDPO.
You have the right to request correction of any personal data that is inaccurate or outdated. Upon receiving such a request, we will investigate and, if the data is indeed inaccurate, correct it within forty days or inform you of our refusal and the reasons thereof.
You may opt out of receiving marketing communications from us at any time by clicking the unsubscribe link in our emails, replying STOP to our SMS or WhatsApp messages, or contacting us directly using the contact information provided below. Please note that opting out of marketing communications does not affect our ability to send you service-related communications that are necessary for the delivery of our services.
While the PDPO does not explicitly provide for data portability or the right to be forgotten, we strive to accommodate reasonable requests to delete or transfer your data where technically feasible and not contrary to our legal obligations.
8. Cookies and Tracking Technologies
Our website uses various types of cookies and similar tracking technologies to enhance your experience and gather information about how our services are used. Essential cookies are necessary for the basic functionality of our website and cannot be disabled without significantly impacting your ability to use our services. Performance cookies help us understand how visitors interact with our website by collecting anonymous information about page visits, traffic sources, and user behavior. Functionality cookies remember your preferences and choices to provide a more personalized experience.
We also use analytics services, including Google Analytics, to gather insights about website usage patterns. These services may use cookies and similar technologies to collect information about your use of our website and other websites over time. You can control cookie preferences through your browser settings, though disabling certain cookies may limit your ability to use some features of our website. For more detailed information about the cookies we use and how to manage them, please refer to our Cookie Policy available on our website.
9. Third-Party Services and Links
Our website and services may contain links to or integrate with third-party websites, applications, and services, including social media platforms like Facebook and WhatsApp Business, payment gateways and financial institutions, mapping and navigation services, and business verification platforms. We are not responsible for the privacy practices of these third parties, and this Privacy Policy does not apply to their collection and use of your data.
We strongly encourage you to review the privacy policies of any third-party services you access through or in connection with our services. When you use social login features or connect your social media accounts to our services, you may be sharing information with those platforms according to their privacy policies.
10. Children’s Privacy
Our services are not intended for individuals under the age of eighteen, and we do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child under eighteen, we will take immediate steps to delete such information from our systems. Parents or guardians who believe that we may have collected information from their child should contact us immediately using the contact information provided below.
11. Changes to This Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time to reflect changes in our practices, technologies, legal requirements, or business operations. When we make material changes to this Privacy Policy, we will notify you by posting the updated policy on our website with a new “Last Updated” date, sending email notifications to registered users where we have your consent to do so, and displaying a prominent notice on our website for a reasonable period after the changes are made.
Your continued use of our services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with any changes, you should discontinue use of our services and contact us to close your account if applicable.
12. International Users
While our services are primarily intended for users in Hong Kong, we recognize that we may have users accessing our services from other jurisdictions. If you are accessing our services from outside Hong Kong, please be aware that your personal data will be transferred to, stored, and processed in Hong Kong where our servers are located and where we operate. By using our services, you consent to such transfer and acknowledge that data protection laws in Hong Kong may differ from those in your jurisdiction.
13. Contact Information and Complaints
If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please contact us at:
Tai Wo Management Limited
Data Protection Officer
Room 7C, 7TH FLOOR
9 PO LUN STREET
LAI CHI KOK
KOWLOON
Email: twm.hongkong@gmail.com
Telephone: 59217214
Business Hours: 9AM-5PM (Monday to Friday, Except PH)
We take all privacy concerns seriously and will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of personal data. If you are unsatisfied with our response or believe we are not processing your personal data in accordance with the law, you have the right to lodge a complaint with:
Office of the Privacy Commissioner for Personal Data, Hong Kong
Wanchai Tower, 12 Harbour Road, Wan Chai, Hong Kong
Website: www.pcpd.org.hk
Enquiry Hotline: (852) 2827 2827
Email: complaints@pcpd.org.hk
14. Language and Interpretation
This Privacy Policy has been prepared in English. We may provide translations in Chinese or other languages for convenience, but in the event of any conflict or discrepancy between the English version and any translation, the English version shall prevail. Any legal interpretation of this Privacy Policy shall be based on the English version.
15. Severability
If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such provision shall be severed from this Privacy Policy, and the remaining provisions shall continue in full force and effect to the maximum extent permitted by law.