This Privacy Policy is issued by Reigning Horizon Holding Limited, the developer and operator of this website and the holding company responsible for the administration services described here. The company is registered at Rm 601-602 TOPSAIL PLZ, 11 ON SUM ST, Sha Tin, Hong Kong (HK) and can be reached at reservations@reigninghorizon.lat or on +12697786003.
We respect the privacy of every person who visits this website, sends us an enquiry, enters a mandate with us or is named in the records we administer. This policy sets out what we collect, why we collect it, how long we keep it, who may see it and what rights you hold over it. We have written it in plain language so that it can be understood without legal training, while still covering the standards we are held to under applicable data protection law in Hong Kong.
By using this website or by providing information to us, you accept the practices described in this policy. If you do not agree with any part of it, please do not send us personal information and contact us instead so that we can answer your questions directly.
1. Who We Are
Reigning Horizon Holding Limited is an investment holding company operating in the field of computer systems design and related professional services. We administer portfolios, integrated systems assets, corporate structures and stewardship arrangements for owners who wish their holdings to remain documented and legible across time. In this policy the terms we, us and our refer to Reigning Horizon Holding Limited, and the term you refers to any individual whose personal information we handle.
Our registered office and principal place of business is Rm 601-602 TOPSAIL PLZ, 11 ON SUM ST, Sha Tin, Hong Kong (HK). The company is the data user responsible for the personal information described in this policy. Questions, requests and complaints may be sent to reservations@reigninghorizon.lat or raised by telephone on +12697786003 during business hours.
This policy applies to personal information collected through this website, through email and telephone contact, through mandate documentation and through the ordinary administration of the holdings placed in our care. It does not apply to websites operated by other organisations, even where we link to them.
2. Information We Collect
The information we collect depends on how you interact with us. If you simply read the pages of this website, we collect very little. If you send an enquiry or enter a mandate, we collect the details needed to answer you and to administer the relationship properly.
Categories of personal information we may collect include identity details such as your name, title and the organisation you represent; contact details such as postal address, email address and telephone number; correspondence content including the subject and body of messages you send us; mandate details such as your role, authority and the holdings you ask us to administer; and technical details such as the pages you visit, the time of your visit and the browser you use.
Where a mandate requires it, we may also handle records that contain personal information about other people, such as directors, shareholders, beneficiaries or counterparties. When you provide information about another person, you confirm that you have the authority to do so and that the person understands how their information will be used.
We do not seek to collect special categories of personal information such as health data, political opinions or religious beliefs, and we ask that you do not send such information to us unless it is genuinely necessary for a matter you have asked us to handle.
3. How We Collect Information
Most of the personal information we hold arrives directly from you. You provide it when you complete the enquiry form on this website, when you write to reservations@reigninghorizon.lat, when you call +12697786003 and when you sign and return mandate documentation. We record the substance of those interactions so that the relationship can be administered consistently.
We also collect a limited amount of information automatically when you browse this website. Our web server records standard technical data that any web server records, and our pages may use browser storage to remember small preferences. This information is used to keep the site working and to understand which pages are useful.
Finally, we may receive information about you from third parties in the ordinary course of administration, for example from a registry, an auditor, a bank or another professional adviser working on the same matter. When that happens we treat the information in the same way as information you have given us directly.
4. Why We Use Information
We use personal information to answer enquiries, to assess whether we can accept a mandate, to perform the administration services we have agreed to provide, to issue reports and valuation packs, to keep governance records, to meet legal and regulatory duties and to protect our own legitimate interests in running a careful business.
More specifically, we use personal information to respond to messages sent through this website; to verify identity and authority before acting on instructions; to maintain statutory and internal registers; to prepare and issue reports, notices and governance papers; to manage risk and to conduct oversight reviews; to keep accounts and records for audit; and to comply with requests from courts, regulators and law enforcement where the law requires it.
We may also use information in aggregate form, with personal identifiers removed, to understand how this website is used and to improve the clarity of our published material. Aggregate data of that kind does not identify any individual.
5. Legal Bases For Processing
We process personal information because it is necessary to take steps at your request before entering into an agreement, because it is necessary to perform an agreement we have with you, because we have a legitimate interest in administering our business competently, because we must comply with a legal obligation, or because you have given clear consent for a specific purpose.
Where we rely on consent, you may withdraw that consent at any time by writing to reservations@reigninghorizon.lat. Withdrawing consent does not affect processing that already took place lawfully, and it does not remove obligations we owe under other legal bases, such as record keeping required by law.
Where we rely on a legitimate interest, we weigh that interest against your rights and expectations. Our legitimate interests are limited to the sound administration of mandates, the protection of records, the prevention of fraud and the improvement of our services. We do not treat legitimate interest as a licence to use personal information for unrelated purposes.
6. Cookies And Similar Technologies
This website keeps its use of cookies and similar technologies to a minimum. Cookies are small files placed on your device by a website, and similar technologies include browser local storage and session storage. We use them only where they serve a clear function, such as remembering a display preference or supporting the basic operation of a page.
We do not use cookies to build advertising profiles and we do not sell cookie data to third parties. If we ever introduce a cookie that is not strictly necessary for the operation of the site, we will describe it here and, where the law requires it, ask for your agreement before it is set.
You can control or delete cookies through the settings of your browser. Removing cookies may affect how some pages behave, but the substance of this website remains available to you without cookies. If you have questions about our use of these technologies, please contact us.
7. Analytics And Server Logs
Our web server records standard log entries each time a page is requested. These entries typically include the date and time of the request, the page requested, the referring page, the browser and operating system reported by your device, and a network address. Log entries help us diagnose faults, detect misuse and confirm that the site is available.
If we use an analytics service, it is configured to measure aggregate traffic such as the number of visits to a page and the general region from which visits arrive. We choose settings that reduce the amount of identifying data collected, and we do not attempt to link analytics data to named individuals for marketing purposes.
Log and analytics data are kept for a limited period consistent with the purposes above. Once that period ends, the data are deleted or aggregated so that they no longer relate to an identifiable person.
8. Disclosure To Third Parties
We do not sell personal information. We do not rent it, trade it or make it available to unrelated organisations for their own marketing. We disclose personal information only in the limited circumstances described in this section, and only to the extent needed for the purpose at hand.
We may disclose information to professional advisers such as auditors, accountants and lawyers where their input is required to administer a mandate; to banks and financial institutions where a payment or account relationship must be established or maintained; to registries and regulators where filings or responses are required by law; and to courts and law enforcement where we are compelled by a valid legal order.
We may also disclose information where it is necessary to protect the rights, property or safety of Reigning Horizon Holding Limited, our clients, our staff or the public, or to investigate suspected fraud or unlawful activity. Where a disclosure is made, we keep a record of what was shared, with whom and on what basis.
If our business is ever reorganised, merged or transferred, personal information may be passed to a successor entity that continues the same activities. Any successor would be bound by this policy or by terms that are no less protective, and we would give notice of the change on this page.
9. Service Providers And Processors
Like most organisations, we rely on a small number of service providers to keep our operations running. These may include hosting providers, email providers, document storage services and information technology support. When a provider handles personal information on our behalf, the provider acts as a processor and we remain responsible for the information.
We select processors with care and require them by contract to act only on our written instructions, to apply appropriate security measures, to restrict access to staff who need it, to assist us in meeting our legal duties and to delete or return information when the engagement ends. We do not permit processors to use personal information for their own independent purposes.
Where a processor is located outside Hong Kong, the transfer is handled in the manner described in the section on international transfers below. Providers that cannot meet our standards are not engaged, and engagements are reviewed when the nature of the service or the law changes.
10. International Transfers
Some of our service providers and some of the matters we administer may involve locations outside Hong Kong. When personal information is transferred across a border, we take steps to ensure that the information continues to receive a level of protection comparable to the one it receives here.
Those steps may include contractual commitments that bind the recipient to use the information only for the agreed purpose, to apply suitable security measures and to honour the rights of the individuals concerned. We assess the legal environment of the destination and the nature of the information before any transfer, and we avoid transfers where the risks cannot be managed.
If you would like to know more about how cross border transfers are handled for a particular mandate, please contact us at reservations@reigninghorizon.lat and we will explain the arrangements that apply.
11. Data Retention
We keep personal information only for as long as it is needed for the purpose for which it was collected, plus any additional period required by law or by prudent record keeping practice. Retention periods differ by category because the obligations differ.
Enquiries that do not lead to a mandate are normally kept for a short period so that we can follow up and so that we have a record of what was discussed. Mandate records, statutory registers and governance minutes are kept for the life of the relationship and for the additional period needed to meet legal, tax, audit and succession obligations. Technical logs are kept for a much shorter period unless they are needed to investigate an incident.
When a retention period ends, we delete the information or render it anonymous so that it can no longer be linked to an individual. Where information has been shared with a processor, we instruct the processor to delete or return it at the close of the engagement. If you would like to know the retention period that applies to a particular record, please ask us and we will explain it.
12. Security Measures
We treat personal information as an asset that must be protected. Our measures include restricting access to staff and contractors who need the information to do their work, using access controls and passwords, keeping systems updated, storing documents in controlled repositories and maintaining backups so that records can be recovered after an incident.
We also apply organisational measures. Staff receive guidance on handling information securely, on recognising suspicious requests and on reporting incidents promptly. Instructions that change records of importance are verified before they are acted upon, and unusual activity is reviewed rather than ignored.
No method of storage or transmission is completely secure, and we cannot promise absolute security. We can promise that we work to appropriate standards, that we review our practices, and that if a breach affects your rights we will investigate it, take steps to reduce the harm and notify you and the relevant authority where the law requires it.
13. Your Privacy Rights
Depending on the law that applies to you, you may have the right to request access to the personal information we hold about you, to ask us to correct information that is inaccurate, to ask us to delete information that is no longer needed, to ask us to restrict how we use it, to object to certain uses, and to ask for a copy in a portable form.
To exercise a right, write to reservations@reigninghorizon.lat and describe what you would like us to do. We may ask you to verify your identity before we act, so that we do not release information to the wrong person. We will respond within the period required by law, and if we cannot meet a request in full we will explain why and set out any further options available to you.
You also have the right to complain about our handling of your information. You may raise the matter with us first, using the contact details in this policy, and you may also approach the data protection authority in your jurisdiction. We would prefer the chance to resolve a concern directly, and we treat every complaint as an opportunity to correct a weakness.
14. Direct Marketing
We do not send unsolicited marketing. If we ever wish to send you a newsletter, an update about our services or an invitation to an event, we will ask for your consent first and we will make it easy to decline. You will never be required to accept marketing in order to receive administration services from us.
Where you have agreed to receive communications, every message includes a clear way to stop future messages. When you withdraw consent, we update our records promptly and you should receive no further marketing material from that point, other than correspondence that is necessary for an active mandate or required by law.
15. Privacy For Children
This website and our services are intended for adults and for organisations. We do not knowingly collect personal information from children. If you believe that a child has provided information to us, please contact us at reservations@reigninghorizon.lat and we will take prompt steps to remove it.
Where a mandate involves a trust, an estate or a family arrangement in which a young person has an interest, any personal information about that person is handled through the responsible adult or trustee, and only to the extent needed for the administration of the matter.
16. Third Party Links
This website may contain links to websites operated by other organisations, for example the site of a registry or a professional body. We provide such links for convenience only. We do not control those websites and we are not responsible for their content or their privacy practices.
When you follow a link away from this website, we encourage you to read the privacy notice of the site you are visiting before you provide any personal information. This policy applies only to information collected by Reigning Horizon Holding Limited through this website and through the contact channels described here.
17. Changes To This Policy
We review this policy from time to time and may update it to reflect changes in our practices, in technology or in the law. When we make a change, we publish the revised policy on this page and update the date shown at the top. The revised version takes effect when it is published.
If a change is material, we will take reasonable steps to bring it to the attention of people who have an active relationship with us, for example by email. We encourage you to review this page occasionally so that you always know how your information is handled. Continuing to use this website after a change is published means that you accept the revised policy.
18. How To Contact Us
We welcome questions about this policy and about the way we handle personal information. You can reach Reigning Horizon Holding Limited by email at reservations@reigninghorizon.lat, by telephone on +12697786003 during business hours, or by post at Rm 601-602 TOPSAIL PLZ, 11 ON SUM ST, Sha Tin, Hong Kong (HK).
When you contact us about privacy, please describe your request clearly and include enough detail for us to identify the records concerned. We will acknowledge your message, tell you who is handling it and give you a realistic timeframe for a full reply. Our aim is to resolve every privacy question promptly, transparently and in writing.
This policy is governed by the laws of Hong Kong (HK) and is published by Reigning Horizon Holding Limited from its registered office at Rm 601-602 TOPSAIL PLZ, 11 ON SUM ST, Sha Tin, Hong Kong (HK). Thank you for taking the time to read it.