Privacy Policy
Personal Information Processing Notice
Scope of This Policy
This policy applies to personal information processing associated with accessing and browsing the Acoeurs Consulting website, submitting the contact form, sending emails voluntarily, and the operation, security, and necessary technical logs of the website.
Personal Information Processor and Contact Details
- Personal information processor:艾克斯（杭州）咨询服务有限公司 (a company registered in Hangzhou, Zhejiang, China)
- Unified Social Credit Code:91330110MAC40RHUXB
- Registered address:浙江省杭州市余杭区仓前街道文一西路1217号11幢806室
- Personal information contact email:info@acoeursconsulting.com
Personal Information That May Currently Be Processed
Server Access & Security Logs
The hosting environment and server logs may record technical information needed for website operation, security, and troubleshooting, such as IP address, basic browser and device information, request time, access path, and HTTP response status.
Contact Form Information
The contact form may process identity type, company or organization name, enquiry area, enquiry subject, enquiry content, name, telephone number, email address, communication language, convenient contact time, privacy-policy confirmation status, submission time, and necessary server and security information.
Emails You Send Voluntarily
When a visitor sends an email voluntarily, we may process the sender’s name, email address, message body, and other information provided by the visitor.
The general enquiry form is not intended for unnecessary identity documents, financial account information, health information, or personal information about children under 14. Please also avoid sending sensitive personal information unrelated to your enquiry by ordinary email.
Contact Form and Information Processing
To submit an enquiry, identity type, enquiry area, name, communication language, and privacy-policy confirmation are required, and at least one of telephone number or email address must be provided. Company or organization name, enquiry subject, enquiry content, and convenient contact time are optional. Without the necessary information, the form cannot be submitted or we may be unable to handle the enquiry.
After being processed by the website, the information is sent through an enterprise email service to info@acoeursconsulting.com and stored in the company mailbox. The website does not maintain a separate enquiry database and is not connected to a customer relationship management system.
The contact form does not support file uploads, is not used for marketing without consent, and does not perform automated customer profiling or automated decision-making.
The website does not automatically send contact-form content to lawyers, accountants, banks, insurers, or other partners. Any disclosure to professional partners required during later human communications or formal services would form part of the relevant subsequent service process.
Processing Purposes and Grounds
Personal information is used mainly to provide and maintain the website, protect the website and forms, prevent misuse, handle enquiries submitted voluntarily by visitors, conduct necessary follow-up using the contact details provided, and meet applicable legal and regulatory requirements.
Depending on the processing context and applicable law, the grounds for processing personal information may include: obtaining the individual’s consent; necessity for entering into or performing a contract to which the individual is a party; necessity for performing statutory duties or legal obligations; and other lawful processing circumstances provided by laws and regulations.
Recipients & Technical Service Providers
Recipients of personal information may include authorized company personnel and competent authorities where required by laws and regulations. The website hosting provider supplies technical support for website operation and security, while the enterprise email provider transmits and stores contact emails.
The website does not currently forward contact-form content automatically to lawyers, accountants, banks, insurers, or other partners.
Offshore Processing and Cross-Border Transfers of Personal Information
The website server is currently deployed in Hong Kong, China. When you visit the website or submit the contact form, some personal information and technical data related to website operation may be processed through Alibaba Cloud hosting infrastructure in Hong Kong. Contact requests are also sent to the company mailbox through the Alibaba Mail enterprise email service.
If such processing constitutes a cross-border transfer of personal information under applicable law, the personal information processor will, based on the actual processing activities, provide the applicable notices, conduct a personal information protection impact assessment, and fulfill other obligations required by laws and regulations. Separate consent will be obtained where required by law.
Retention Periods
General enquiry information that does not lead to a client relationship is retained for no more than six months from the last substantive communication and is then deleted or anonymized. Automated marketing emails or internal-only actions do not restart this period.
We will delete or anonymize information earlier if its processing purpose has been achieved and continued retention is unnecessary, or if earlier deletion is required by law. For records that become part of a formal client relationship, the retention period is determined separately according to the relevant service purpose and applicable legal requirements.
The six-month period above is the company’s retention rule for general enquiry information; it does not apply to all security logs, cookies, or records that must be retained by law. Security and technical logs are retained for the necessary period based on website security, troubleshooting needs, and hosting configuration.
Personal Information Security
The personal information processor uses reasonable technical and organizational measures proportionate to the risks, including access controls, HTTPS, and secure form mechanisms.
Personal Information Rights
Under applicable law, you have the right to know about and decide on the processing of your personal information, and to restrict or refuse processing. You may also request access to, a copy of, correction, supplementation, or deletion of your personal information, withdraw consent, ask us to explain our personal information processing rules, and, where statutory conditions are met, request transfer of your personal information to a designated personal information processor.
Withdrawing consent does not affect the validity of personal information processing carried out on the basis of consent before withdrawal.
You can contact the website operator at info@acoeursconsulting.com to submit a request concerning your personal information. We verify identity only to the extent necessary to handle the request and respond within the scope required by applicable law; if we refuse a request, we will explain the reason.
Complaints and Feedback
If you believe that personal information processing by this website infringes your lawful rights or interests, you may contact us at info@acoeursconsulting.com or submit a complaint or report to a department that performs personal information protection duties in accordance with law.
Minors
The website currently has no online services or registration features designed specifically for children under 14, and the general enquiry form is not intended for their personal information. If such information is processed in the future, the personal information processor will establish appropriate rules under applicable law and obtain the guardian’s consent where legally required.
Policy Changes
This policy will be updated if website features, hosting, contact-form processing, or relevant legal requirements change. We will give appropriate notice of material changes and obtain consent again where required by law.