Privacy Policy

1. Scope

This Privacy Policy explains how we collect, use, disclose, store and protect personal data when you visit resoongroup.com, use the Scenario Explorer, contact us or submit an enquiry through our Tally form. A separate notice or agreement may apply if you later enter into a client, operator, supplier or partnership relationship with us.

2. Personal Data We Collect

Depending on how you interact with us, we may collect:

• Contact information — your full name and work email address.
• Professional and organisation information — organisation name and type, role, company website, country or region.
• Enquiry and programme information — enquiry type, recovery capabilities, product situation and category, approximate volume, asset location, decision timeframe, desired outcomes, available evidence and any explanation you choose to provide.
• Privacy records — your acknowledgement or consent, the notice version shown to you and submission time.
• Technical and performance information — limited request, device, browser, IP-address, security and page-performance information processed when you access the website or form.

Please do not submit passwords, payment-card information, government identifiers, medical information or other sensitive personal information through the form. Do not submit confidential product data or personal information about another person unless it is necessary and you are authorised to provide it.

3. Scenario Explorer

Scenario Explorer inputs and results are calculated in your browser and are not intentionally transmitted to or stored by RESOON. If you select Request a Demo and submit the Tally form, only the information entered into that form is processed under this Privacy Policy.

4. Purposes and Basis for Processing

• assess and respond to your enquiry;
• arrange a demonstration or focused discussion;
• evaluate a potential Managed Recovery Programme, operator relationship, partnership or other business engagement;
• maintain relevant correspondence and business records;
• operate, secure and improve the website and enquiry process;
• comply with applicable legal duties and establish, exercise or defend legal claims; and
• create de-identified or aggregated operational learning that does not identify an individual.

Depending on the applicable law and context, we process personal data with your consent, to take steps at your request before entering into a contract, to perform a contract, to comply with legal duties, or for another basis permitted by the applicable law. For individuals in Mainland China, we rely only on a basis recognised by the PIPL, principally consent, processing necessary to take requested pre-contract steps or perform a contract, and processing necessary to comply with legal duties. Where a particular form of consent is legally required, we ask for it separately.

We do not sell personal data. We do not use website-enquiry data for newsletters, advertising or other direct marketing. We do not make decisions that produce legal or similarly significant effects solely by automated processing.

5. Required and Voluntary Information

Providing personal data is voluntary. Fields marked as required are necessary for us to identify you, understand the enquiry and respond. If you do not provide them, we may be unable to process the enquiry. Optional fields help us route the discussion but may be left blank.

6. Who Receives or Processes Personal Data

Access is limited to people and organisations that need the information for the purposes above:

• Authorised RESOON personnel and contractors — to handle enquiries and assess programme or partnership fit.
• Tally BV — form hosting and submission processing; Sint-Pietersnieuwstraat 11, 9000 Gent, Belgium; [email protected]. Tally states that form data is stored in the European Union.
• Notion Labs, Inc. — lead-database hosting and management on our instructions; 685 Market Street, San Francisco, CA 94105, United States; [email protected]. Notion states that workspace data remains hosted in the United States unless an eligible data-residency migration is completed.
• Cloudflare, Inc. — website delivery, DNS, security and privacy-focused web performance analytics; 101 Townsend Street, San Francisco, CA 94107, United States; [email protected]. Cloudflare operates a global network and states that relevant information may be stored primarily in the United States and European Economic Area.
• Professional advisers and public authorities — where reasonably necessary for legal, accounting, security or dispute purposes, or where disclosure is required by law.

We do not ordinarily share identifiable enquiry data with prospective recovery operators or delivery partners at the initial enquiry stage. If a later programme discussion requires such sharing, we will limit the information, apply confidentiality controls and provide further notice or obtain consent where required.

The form information is collected electronically through Tally, transmitted to and stored in Tally and Notion, and reviewed by authorised people for the purposes above. Cloudflare automatically handles website request, security and performance information. We do not use these providers to make solely automated decisions with legal or similarly significant effects.

7. International and Mainland China Processing

RESOON is based in Hong Kong. The service providers above operate in other jurisdictions, so personal data may be transferred to or accessed from Hong Kong, Belgium and other European Union locations, the United States and locations in Cloudflare’s global network. We use established providers, limit access, keep appropriate service terms or data-processing arrangements and take other measures appropriate to the nature and risk of the information.

For individuals in Mainland China, we provide the overseas-recipient details above and ask for separate consent to the cross-border provision of the form information. We also assess the purpose, necessity, risk and safeguards of the cross-border flow. You may withdraw consent or exercise the rights described below by contacting RESOON; we will coordinate with the relevant provider where necessary.

8. Retention

If an enquiry does not become an active business relationship, we retain the enquiry record for up to 24 months after the last meaningful contact and then delete or anonymise it where reasonably practicable. If a client, operator, supplier or partnership relationship develops, relevant records may be kept for the relationship and any additional period reasonably needed for operational, contractual, accounting, legal or dispute purposes. Provider backup and recovery cycles may delay final erasure after deletion from an active workspace.

Technical and security records are kept for the shortest period available under the relevant provider configuration or contract and reasonably necessary to operate and secure the website. De-identified, aggregated metrics that no longer identify an individual may be retained longer.

9. Security

We use reasonable administrative and technical safeguards appropriate to the current scale and nature of the information, including HTTPS, controlled workspace access, access limitation and restricted sharing. No online system is completely secure, so please provide only what is necessary for the enquiry.

If a personal-data incident occurs, we will investigate, contain and document it and notify the relevant authority or affected individual where applicable law requires notification.

10. Your Rights

Subject to applicable law, you may ask us to confirm whether we hold your personal data, access or obtain a copy of it, correct or supplement it, delete it, restrict or object to processing, withdraw consent, and obtain an explanation of our processing rules. A Mainland China individual may also exercise any transfer or other rights available under the PIPL and related rules. Withdrawal does not affect processing already carried out lawfully before withdrawal.

Send requests to [email protected]. We may verify your identity and may refuse or limit a request only where permitted by law, explaining the reason where required. You may also complain to the Office of the Privacy Commissioner for Personal Data in Hong Kong or the competent personal information protection authority in Mainland China.

11. Cookies, Web Analytics and Third-Party Pages

The RESOON website currently uses Cloudflare Web Analytics to measure page use and performance. Cloudflare states that this service does not use cookies, localStorage or fingerprinting to collect usage metrics. We do not currently deploy advertising pixels or behavioural-advertising cookies. The Tally form and external LinkedIn, Instagram and Xiaohongshu pages are separate third-party services and are governed by their own privacy terms and technical settings.

12. Children

This business-to-business website and form are not directed to children. We do not knowingly collect personal data from anyone under 18 through the enquiry form. If you believe a child has submitted information, contact us so that we can review and delete it as appropriate.

13. Changes to This Policy

We may update this Privacy Policy when our services, providers or legal duties change. The current version and effective date will be published on this page. Where required, we will highlight material changes or seek renewed consent.

14. Contact

KAILAI SHENGSHI（HK） INTL INVESTMENT TRADE CO., LIMITED

FLAT/RM 502C, 5/F HO KING COMM CTR 2-16 FAYUEN ST MONGKOK, KOWLOON HONG KONG

Email: [email protected]

Hong Kong regulator: Office of the Privacy Commissioner for Personal Data