Privacy Policy
This policy explains how Trofi Group Limited collects, uses, stores and shares personal data in the course of its consignment stall administration work.
Contents
- About this policy
- Who controls the data
- Scope of the policy
- Data we collect
- How we obtain data
- Purposes of processing
- Lawful bases
- Consignment tickets and records
- Settlement and payment data
- Inspection and permit data
- Cookies and site data
- Sharing with third parties
- International transfers
- Retention periods
- How we protect data
- Your rights
- Marketing communications
- Privacy for Children
- Changes to this policy
- Contact and complaints
1. About this policy
Trofi Group Limited is a consignment stall administrator. We book booth rotations, issue consignment tickets, weigh goods at intake, run settlement cycles, allocate vendor slots, schedule stall inspections and prepare season market permits. Almost all of that work depends on personal data: the name of a vendor, the contact details of a stall keeper, the bank line used for a settlement, the identity of an inspector and the correspondence that ties a season together.
This policy is written to be read. It describes the data we handle, why we handle it, how long we keep it and what a person can ask us to do with it. It applies to the website published at www.trofigroup.buzz and to the administration carried out at our office. The policy is issued by the developer of this website, Trofi Groups, together with the operating company named below, and it is maintained as the single public statement of our privacy practice.
We have tried to avoid legal language where plain language will do. Where a term has a specific meaning in the law that applies to us, we explain it the first time it appears. If anything in the policy is unclear, please write to the contact address in the final section and a member of the desk will answer in writing.
In short: we collect only the data a stall administration desk needs, we use it to book, weigh and settle, we keep the paper records defensible, and we do not sell personal data to anyone.
2. Who controls the data
The controller of the personal data described in this policy is Trofi Group Limited, 5/F United Centre, 95 Queensway, Admiralty, Hong Kong - 999077, Hong Kong (HK). The company operates the desk, holds the vendor files and decides how the data is used and how long it is kept.
Enquiries about this policy, about a particular record or about the exercise of a right can be sent to hello@trofigroup.buzz or made by phone on +18658746480. The office answers correspondence in English and keeps its records in English, so that a file reads the same to every party who has to work from it.
Where a venue, a carrier or a payment provider also decides how data is used, that party is a separate controller for its own purposes and its own privacy notice applies to that part of the work. We name the main categories of those parties in the section on sharing.
3. Scope of the policy
This policy covers personal data processed through the website, through email and telephone contact, through the vendor files kept at the desk and through the physical records of a consignment operation. That includes paper tickets, inspection notes, permit files, settlement statements and the tray board on which a run is balanced.
The policy does not cover the websites of other organisations that we may link to, nor the internal records of a venue or a carrier. Those organisations publish their own notices, and a person who deals with them directly should read the notice they provide.
The policy does not cover anonymous market statistics. When we report on the number of booths in a season or the number of settlement runs completed, we do so in aggregate and without identifying any vendor or buyer.
4. Data we collect
We collect identity and contact data for vendors, stall keepers and their staff, including name, business name, postal address, email address, telephone number and the language used for correspondence. For a vendor who is a company, we also collect the registration details needed to contract and to settle.
We collect consignment data: the description of goods, category, count, weight at intake, condition at intake, booth assignment and run dates. This data is recorded on a numbered consignment ticket and is linked to the vendor who handed the goods over.
We collect settlement data: the statement lines for a run, the amount due to or from a vendor, the bank or payment details needed to make a transfer and the correspondence that resolves a query. Where a payment provider processes a transfer on our behalf, that provider collects its own data under its own notice.
We collect inspection and permit data: the notes from a scheduled stall walk, any corrective item and its closure date, the permit application pack and the correspondence with a venue about that pack. Inspection notes normally name the inspector and the stall keeper, because a dated note is only useful if it identifies who was present.
We collect website data that a person chooses to send through the contact form, which includes name, email address, subject line and message. We also collect limited technical data generated by a web server, described in the section on cookies and site data.
5. How we obtain data
Most of the data comes directly from the person concerned, through a booking, an intake, a settlement query or a message sent to the desk. A stall keeper may also give us the details of staff who will work a booth, and in that case the stall keeper is responsible for telling those staff how their details are used.
Some data comes from a venue, which may send us the allocation sheet, the rulebook or a note about a permit. Some comes from a carrier, which may send a delivery note that we match to a consignment ticket at intake. Some comes from a payment provider in the form of a transfer confirmation.
We may also receive data from a public register where the law requires us to check a business identity before contracting. We do not use bought marketing lists and we do not enrich a vendor file with data from social media.
6. Purposes of processing
We use personal data to plan booth rotations and vendor slots, to issue and match consignment tickets, to weigh goods at intake, to run settlement cycles and to produce statements. We use it to schedule and record stall inspections, to prepare and lodge season market permits and to answer questions about any of those steps.
We use data to keep the vendor file complete and readable, so that a query raised months after a season can be answered from the record. We use it to prevent and detect fraud, to reconcile a ticket against a tray and to resolve a shortfall or an overpayment in a transparent way.
We use contact data to reply to enquiries, to confirm a booking, to notify a change in a rotation or a settlement date and to send notice of a permit deadline. We use it to meet accounting and record keeping obligations and to respond to a lawful request from a court or a regulator.
We use aggregate data to review how the desk is running, for example to see which booth categories attract the most queries or which settlement runs take longer to balance. That review is carried out without identifying a particular person.
7. Lawful bases
Where a contract exists, we process the data needed to perform it: booking a booth, ticketing goods, settling a run and issuing a statement. Where no contract has yet been formed, we process the data needed to take steps at the request of the person before a contract is made.
We rely on our legitimate interests to administer the stall, to keep the desk secure, to improve the service and to resolve disputes. We have weighed those interests against the rights of the people concerned, and we limit the processing to what the administration genuinely needs.
We process data to comply with a legal obligation where record keeping, accounting or a lawful request from an authority requires it. Where we ask for consent, for example for an optional marketing message, a person can withdraw that consent at any time and the withdrawal does not affect the work already done.
If a person declines to provide data that is needed for a booking, a ticket or a settlement, the desk may be unable to complete that step. We will explain which data is essential and which is optional before a booking is confirmed.
8. Consignment tickets and records
A consignment ticket is the spine of the record. It carries a number, the vendor, the category, the count, the intake weight and the condition. Because a ticket can be the subject of a later dispute, we keep the stub at the desk and treat it as a business record rather than as correspondence.
A ticket may name a person who handed the goods over and a person who received them. It may also record a carrier reference and a booth assignment. We keep this data for the retention period described below, and we do not alter a ticket after a run has closed; a correction is issued as a new document that refers to the original.
Access to the ticket file is limited to staff who need it for intake, settlement, inspection or a query. A vendor can ask for a copy of the tickets issued to that vendor, and the desk will provide a copy where the request can be verified and where no third party data has to be disclosed.
9. Settlement and payment data
A settlement statement links a vendor to the lines it covers. It may contain the amount due, the adjustment history, the ticket numbers and the date of the run. We keep statements with the tickets so that a query about a line can be answered without reconstructing the facts.
Bank and payment details are collected only where they are needed to make a transfer. We hold them in a restricted part of the vendor file, and only staff who process a settlement can open that part. We do not ask for a card number through the website, and the contact form is not designed to carry payment data.
Where a payment provider processes a transfer, that provider is responsible for the security of the data it handles under its own notice. We receive a confirmation and the reference needed to reconcile the statement, and we keep that confirmation with the run.
10. Inspection and permit data
An inspection note records the date of the walk, the booth, the inspector and the stall keeper. It may record one or two corrective items and the date by which each should be closed. We keep the note because a dated walk shows that the stall has been managed to a consistent standard and because it is the clearest evidence available if a dispute reaches the desk.
A permit file contains the application, supporting documents, venue correspondence and the closing return. Some of those documents contain personal data, such as the name and contact details of the applicant or the signature of a responsible person. We keep the file together so that a venue query can be answered from one place.
Where a corrective item is closed, we record the closure date and the confirmation we received. We do not keep a photographic record of a booth unless a venue rule requires it, and where a photograph is taken we avoid capturing a person who is not part of the inspection.
13. International transfers
The desk operates from Hong Kong, and the vendor file is normally held there. A venue or a carrier may be in another jurisdiction, and a settlement may involve a bank or a payment provider outside Hong Kong. When data moves across a border, we take reasonable steps to ensure that it remains protected to a standard comparable with the one described in this policy.
Those steps may include a written agreement with the recipient, a check on the security practice of a provider and a limit on the data sent to what the particular task requires. A person who wants to know more about a transfer that affects that person can write to the contact address and the desk will explain what has been done.
14. Retention periods
We keep a vendor file for the period in which the vendor is active and for a further period afterwards so that a query, an audit or a legal claim can be answered. The normal period for tickets, statements and inspection notes is seven years from the end of the season to which they relate, because that is the period in which a financial or contractual question is most likely to arise.
We keep a permit file for seven years from the closing return. We keep an enquiry that does not lead to a booking for two years, so that a returning enquirer does not have to repeat the same details. We keep a record of a consent and a withdrawal of consent for as long as the consent is relied upon and for a short period afterwards.
When a period ends, we delete the data or make it anonymous. Where a document has to be kept beyond the normal period because of a live dispute or a legal hold, we keep only that document and we restrict access to the staff who need it.
15. How we protect data
Access to the vendor file is limited to staff who need it for intake, settlement, inspection or a query. Paper tickets and statements are held at the desk in a locked cabinet, and the tray board is cleared into the file at the close of each run rather than being left on the desk overnight.
Office systems are protected by an account and a password, and a shared account is not used for settlement work. A device that holds a vendor file is kept up to date, and a backup is held so that a record can be restored after a failure. Staff are briefed on the handling of a ticket, a statement and a permit document, and the briefing is repeated when a process changes.
No system is perfect. If a breach occurs that is likely to result in a risk to the rights of a person, we will notify the affected person and the relevant authority where the law requires it, and we will describe what happened and what we have done about it.
16. Your rights
A person can ask for a copy of the personal data we hold about that person and for an explanation of how it is used. A person can ask us to correct data that is wrong or to complete data that is incomplete, and a person can ask us to delete data where there is no longer a good reason for us to keep it.
A person can ask us to restrict the use of data while a question is being resolved, and a person can object to a use that relies on our legitimate interests. Where a use relies on consent, a person can withdraw that consent at any time.
A request can be sent to hello@trofigroup.buzz or made by phone on +18658746480. We may ask for proof of identity so that we do not disclose a vendor file to the wrong person. We answer a request within a reasonable period and normally within thirty days, and if a request is complex we will explain why more time is needed.
If a request concerns a record that a venue or a carrier holds independently, the desk will explain that the record is held by that organisation and will point the person to the right contact where it can.
17. Marketing communications
We do not send a marketing message unless a person has asked for one. A vendor who books a season receives service messages about that season, such as a booking confirmation, a rotation change or a settlement date, and those messages are part of the service rather than marketing.
Where we offer an occasional note about a new season or a change in the desk, a person can opt in and can opt out at any time. An opt out is recorded in the vendor file, and we will not add a person to a list again after an opt out unless that person asks us to.
We do not share a contact list with a partner for that partner to market to the people on it.
18. Privacy for Children
The service is designed for businesses and for adults who run a stall. We do not knowingly collect personal data from a child, and the contact form is not intended for use by a child. If a child sends a message, we will delete it once we are aware of it.
Where a family stall involves a young person, the adult who holds the booking is responsible for the data given to the desk, and the desk will deal with that adult rather than with the young person. If a person believes that a child has given us data without an adult being aware, the person can write to hello@trofigroup.buzz and we will remove the data.
19. Changes to this policy
We review this policy when a process changes or when the law requires it. When a change is material, we update the date at the top of the page and, where a vendor file is affected, we notify the vendor in writing before the change takes effect.
A change that only improves the wording does not alter the way data is handled, and a person can always read the current version on this page. We keep a copy of an earlier version for the period in which a question about it could reasonably arise.
20. Contact and complaints
Questions about this policy, a request to exercise a right, or a complaint about the handling of data can be sent to Trofi Group Limited, 5/F United Centre, 95 Queensway, Admiralty, Hong Kong - 999077, Hong Kong (HK). The email address is hello@trofigroup.buzz and the phone number is +18658746480.
We take a complaint seriously. The desk will acknowledge a complaint in writing, explain what it has found and tell the person what it has done to put the matter right. If a person is not satisfied with the answer, the person can complain to the privacy authority that applies in that person jurisdiction, and we will cooperate with that authority.
Please include enough detail for the desk to locate the record, such as the vendor name, the booth number, the ticket number or the date of the run. The clearer the reference, the faster the desk can answer.