TWENTY FOUR TWELVE SOCIETY INTERNATIONAL LIMITED

1. Introduction

This Privacy Policy outlines how Twenty Four Twelve Society International Limited (“we”, “our”, or “the Company”) collects, uses, stores, protects, and discloses personal data provided by individuals (“you”, “your”, or “the data subject”) when you access our website, engage with our services, or communicate with us.

We are committed to protecting your privacy and handling your personal information with transparency, integrity, and respect for your rights.

This policy is issued in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong, and, where applicable, considers principles under the EU General Data Protection Regulation (GDPR).

2. Scope of the Policy

This Policy applies to:

• Visitors to our website: https://www.2412society-int-ltd.com;
• Clients and prospective clients;
• Business partners, contractors, and service providers;
• Any other individuals whose personal data we may collect in the course of business.

This Privacy Policy does not apply to third-party websites, services, or platforms that are not owned or controlled by the Company, even if they are linked from our site.

3. Data We Collect

We may collect and process the following categories of personal data:

a. Identity and Contact Information:
Name, email address, phone number, country of residence, business name, and job title.

b. Technical and Usage Data:
IP address, device type, browser type, time zone, website navigation, and cookies.

c. Financial and Transaction Data:
Payment details, invoices, billing history, and related communications.

d. Communication and Support Data:
Messages, support tickets, feedback, and other correspondence.

e. KYC/AML Documentation (if applicable):
Copies of identity documents, proof of address, and other regulatory compliance materials.

We collect data directly from you, through automated technologies (e.g., cookies), or from third-party sources where lawful.

4. Legal Basis and Purpose of Processing

We process your personal data only when there is a lawful basis to do so. This may include:

• Performance of a Contract: To provide services requested by you or your organization;
• Compliance with Legal Obligations: For tax, anti-money laundering (AML), and regulatory compliance;
• Legitimate Interests: For service improvement, fraud prevention, analytics, or business development;
• Consent: Where required, especially for marketing or non-essential cookies.

Each category of data is processed strictly for the purpose it was collected and retained only as long as necessary for such purpose.

5. Use of Cookies and Similar Technologies

Our website uses cookies, web beacons, and similar technologies to enhance user experience, track usage patterns, and optimize performance.

Cookies may be:

• Strictly Necessary: Required for core website functionality;
• Performance and Analytics: To measure site usage and user interaction;
• Functionality Cookies: To remember user preferences;
• Targeting Cookies: To deliver tailored content or ads (only with consent where required).

You may manage or disable cookies through your browser settings. However, disabling certain cookies may impact the website’s functionality.

6. Data Sharing and Disclosure

We do not sell or rent your personal data to third parties.

However, we may disclose your data in the following limited circumstances:

• To service providers or subcontractors who perform functions on our behalf (e.g., IT services, payment processors, legal advisors), subject to strict confidentiality obligations;
• To affiliated companies, subsidiaries, or business partners where such sharing is necessary for operational or compliance purposes;
• To regulators, law enforcement, or government authorities, where required by law, regulation, court order, or in response to lawful requests;
• In the context of a merger, acquisition, or corporate restructuring, where your data may be transferred as part of the transaction, subject to safeguards.

All third parties are bound by contractual obligations to maintain data security and process data in accordance with applicable laws.

7. International Data Transfers

As a company incorporated in Hong Kong with global clients and infrastructure, your personal data may be transferred to and processed in countries outside your country of residence, including jurisdictions that may not offer the same level of data protection.

When we transfer data internationally, we ensure that appropriate safeguards are in place, such as:

• Binding corporate rules;
• Standard contractual clauses approved by regulatory authorities;
• Data processing agreements and encryption protocols.

By using our services or submitting your data, you consent to such international transfers in accordance with this Policy.

8. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including:

• To comply with legal and regulatory obligations (e.g., AML laws, tax and accounting rules);
• To resolve disputes or enforce our agreements;
• For ongoing business needs (e.g., client support, audit records).

When data is no longer required, we securely delete or anonymize it, unless further retention is mandated by law or permitted under legitimate interests.

Our retention periods may vary depending on the category of data and its processing purpose.

9. Security Measures

We implement industry-standard security measures to protect your personal data from unauthorized access, use, alteration, or disclosure. These measures include:

• Encryption of data in transit and at rest;
• Firewall and intrusion detection systems;
• Multi-factor authentication and secure password protocols;
• Regular security audits and access controls;
• Employee training on data protection and confidentiality.

Despite our best efforts, no system can guarantee absolute security. You are encouraged to use strong passwords, avoid sharing login credentials, and report any suspected security incidents to us promptly.

10. Your Rights

Subject to applicable laws, you have the following rights with respect to your personal data:

• Right of Access: To obtain a copy of your personal data held by us;
• Right of Rectification: To correct inaccurate or incomplete data;
• Right of Erasure: To request deletion of your data under certain conditions;
• Right to Object: To object to processing based on legitimate interests or direct marketing;
• Right to Restrict Processing: To limit how we use your data in specific circumstances;
• Right to Data Portability (where applicable): To receive your data in a structured, machine-readable format.

To exercise any of these rights, please contact us at:
[email protected]

We may request additional information to verify your identity before processing your request. We aim to respond within the legal time frame and without undue delay.

11. Children’s Privacy

Our website and services are not intended for, nor directed to, individuals under the age of 18. We do not knowingly collect or process personal data from children.

If you are a parent or legal guardian and believe that your child has provided us with personal information, please contact us immediately. Upon verification, we will take prompt action to delete such information and prevent further processing.

We encourage parents and guardians to supervise their children’s online activities and ensure their personal information is not shared without consent.

12. Marketing Communications

With your explicit consent (where required by law), we may use your personal data to send you promotional emails, newsletters, offers, or updates regarding our services.

You may opt out of receiving marketing communications at any time by:

• Clicking the “unsubscribe” link in the email footer;
• Contacting us at [Insert contact email].

Please note that opting out of marketing communications does not affect service-related communications (e.g., invoices, service updates, legal notices) that are necessary for the operation of your account.

We do not sell your personal information to third parties for marketing purposes.

13. Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time to reflect changes in law, our data practices, or our services.

Any changes will be posted on this page with an updated “Effective Date.” You are encouraged to review this page periodically to stay informed about how we protect your personal data.

In case of material changes, we may notify you by email or through a prominent notice on our website, where feasible.

Continued use of our services following such changes constitutes your acceptance of the revised Policy.

14. Contact Information

If you have any questions, requests, or complaints regarding this Privacy Policy or our data protection practices, please contact us at:

TWENTY FOUR TWELVE SOCIETY INTERNATIONAL LIMITED
RM 602, 6/F, Kai Yue Comm Building, No.2C Argyle Street, Mongkok, Kowloon, HONG KONG
Email: [email protected]

We are committed to addressing your concerns in a timely and respectful manner, and where applicable, cooperating with data protection authorities.

15. Governing Law and Jurisdiction

This Privacy Policy shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region.

Any disputes arising in connection with this Policy shall be subject to the exclusive jurisdiction of the competent courts of Hong Kong, without prejudice to your rights under mandatory data protection laws.

In the event of any conflict between this Policy and applicable local laws, the latter shall prevail to the extent required by law.