PRIVACY & COOKIE POLICY

Harbourlink Programme Systems

Last Updated: 10 June, 2025

1. Introduction

Harbourlink Programme Systems (“Harbourlink”, “we”, “us”, or “our”) operates managed programme delivery and coordination environments that support ongoing operational activity.

From our base in Hong Kong, we support organisations managing structured programmes across Asia-Pacific and international markets. Our environments are used continuously by programme and delivery teams as part of everyday operational work.

This Privacy & Cookie Policy explains how we collect, use, store, and protect personal data when:

• You visit our website
• You contact us
• You engage Harbourlink Programme Systems to operate programme environments
• You interact with systems we manage on behalf of clients

2. Company Details

Company Name:
Harbourlink Programme Systems

Headquarters:
Hong Kong

Privacy Contact Email:
privacy@harbourlinkprogrammes.com

3. Our Role in Data Processing

Data Controller
When processing personal data for our own purposes, including website enquiries, commercial discussions, and vendor communications.

Data Processor
When operating programme coordination environments on behalf of clients. In these cases, the client remains the data controller and Harbourlink processes personal data strictly under contractual instruction.

4. Categories of Personal Data We Collect

Business Contact Information

• Name
• Company name
• Job title
• Business email address
• Telephone number
• Information voluntarily submitted in enquiries

Programme Environment Data (Client Systems)

• User account identifiers
• Access logs
• Scheduling records
• Assignment and responsibility data
• Programme tracking information
• Activity and audit logs

Where such data includes personal data, it is processed solely in accordance with client instructions.

Website & Technical Information

• IP address
• Browser type
• Device information
• Pages visited
• Time spent on pages
• Referral source

5. Why We Process Personal Data

• Respond to enquiries
• Operate and maintain programme delivery environments
• Ensure continuity and reliability of services
• Maintain visibility across active programmes
• Monitor performance and platform stability
• Maintain system security
• Comply with legal obligations

Harbourlink Programme Systems does not sell personal data.

6. Legal Basis for Processing

Where applicable under Hong Kong’s Personal Data (Privacy) Ordinance (PDPO) and other relevant data protection laws, we process personal data on the basis of:

• Contractual necessity (providing agreed services)
• Legitimate business interests (ensuring reliable operational systems)
• Legal obligation
• Consent (where required, including for non-essential cookies)

7. Your Rights

Depending on your location and applicable law, you may have the right to:

• Request access to your personal data
• Request correction of inaccurate data
• Request deletion where legally applicable
• Object to certain processing activities
• Withdraw consent where processing is based on consent

Requests may be submitted using the contact details provided above.

8. Data Sharing

We may share personal data with:

• Technology and hosting providers
• Monitoring and operational support partners
• Professional advisers
• Regulatory authorities where legally required

All third parties are required to implement appropriate confidentiality and data protection safeguards.

9. International Data Transfers

As Harbourlink supports organisations operating across multiple markets, personal data may be transferred outside Hong Kong.

Where required by applicable law, we implement appropriate contractual and organisational safeguards to protect personal data during cross-border transfers.

10. Data Retention

We retain personal data only for as long as necessary to support active engagements, maintain operational records, and comply with legal obligations.

Website enquiry data is typically retained for up to 24 months unless a longer commercial relationship is established.

Retention of client platform data is governed by contractual agreements.

11. Data Security

Harbourlink Programme Systems implements appropriate technical and organisational measures to protect personal data, including controlled system access, monitoring, structured change management, and operational continuity controls.

12. What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help websites function properly and provide insight into usage patterns.

13. Types of Cookies We Use

Essential Cookies – Required for core website functionality and security.

Analytics Cookies – Used to monitor website traffic and improve usability. Where required by applicable law, analytics cookies are placed only after consent.

Marketing Cookies – Harbourlink Programme Systems does not currently use advertising or behavioural marketing cookies.

14. Managing or Withdrawing Consent

You may accept or reject non-essential cookies via our cookie banner or adjust your browser settings to block or delete cookies at any time.

15. Children’s Data

Our services are directed at professional and business users. We do not knowingly collect personal data from children.

16. Updates to This Policy

We may update this Privacy & Cookie Policy periodically. The latest version will always be available on our website with the updated revision date displayed above.