Privacy Policy

Effective date / Last updated: 2026-11-06

1. Operator and scope

Touxin International Trade Co., Limited, RM 102, 1/F, THE CLOUD, 111 TUNG CHAU STREET, TAI KOK TSUI, HONG KONG, operates bemolavasolution at bemolava.com and is the data user under the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong for the account, workspace and enquiry processing described here. Registration jurisdiction: Hong Kong SAR. This notice does not imply that the workspace serves advertisements, collects advertising audiences or runs conversion tracking.

2. Information we handle

We handle information provided when registering, updating a profile, saving campaign plans or contacting us: email address, company and optional contact details, country, address, password credentials and message or plan content. Passwords are stored as hashes. A session identifier maintains signed-in access. Requests necessarily transmit technical information such as network address and browser request details to service infrastructure. Do not include sensitive personal information or audience lists in campaign names or enquiries.

3. Purposes and applicable requirements

We use account and workspace details to provide the requested service, enquiry details to respond, and necessary information to administer and protect the service and meet legal obligations. Where applicable law requires a lawful basis, we rely on performance of the service contract, legitimate interests balanced against individual rights, legal obligations or consent, as appropriate to that processing. Where consent is required, you may withdraw it without affecting earlier lawful processing.

4. Recipients

Information is used for service administration and handling enquiries. If hosting or support providers are engaged, disclosure should be limited to the necessary purpose with appropriate protections. Information may be disclosed where required by law, necessary for lawful claims or directed by you. This notice does not assert an active relationship with media suppliers or advertising measurement partners.

5. Cookies and electronic communications

The service uses a necessary session cookie for authentication. Optional cookies and browser storage, if introduced, must comply with applicable law and relevant PCPD guidance and obtain consent where required. Any direct marketing use or provision of personal data must comply with the applicable consent and notification requirements of the Personal Data (Privacy) Ordinance and provide a way to refuse or stop direct marketing. Optional technologies must not be enabled without the required choice. Manage cookies through your browser or contact privacy@bemolava.com about preferences. Blocking necessary cookies may prevent sign-in.

6. Security and retention

Measures designed to protect personal data include password hashing and account access controls. No storage or transmission method is absolutely secure. Information should be retained only as needed to operate the service, handle requests, resolve disputes or meet legal obligations, then deleted or de-identified when no longer required. You may request account closure or deletion.

7. Your rights and complaints

Under Hong Kong's Personal Data (Privacy) Ordinance, you may make a data access request or request correction of personal data, subject to applicable conditions and exemptions. Contact privacy@bemolava.com. We may need proportionate identity verification and will respond as required by applicable law. You may complain to the Office of the Privacy Commissioner for Personal Data (PCPD), Hong Kong. Other rights are available where applicable law provides them.

Where other data protection laws apply to particular processing, including the EU GDPR or US state privacy laws such as CCPA/CPRA, we handle requests in accordance with those laws. This conditional statement does not claim that every law applies to every user or replace any required choices or notices.

8. International processing

This notice does not state that cross-border processing is currently taking place. If a proposed arrangement involves a restricted international transfer, it must meet applicable legal requirements before the transfer, including appropriate contractual protections, assessments or other permitted safeguards where required. Contact us for information relevant to your data.

9. Children and policy updates

The workspace is intended for business use and is not directed to children. We may update this notice to reflect the service and legal requirements with appropriate notice of material changes.

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