PRIVACY POLICY

1. Introduction

Tsunami Innovation Limited (“we”, “our”, or “the Company”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website at tsunamihub.info, in compliance with applicable data protection laws including the General Data Protection Regulation (GDPR) and the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong.

By using our website, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use our website.

2. Data Controller

Tsunami Innovation Limited is the data controller responsible for your personal data. Our contact details are:

Tsunami Innovation Limited

Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong

Email: support@tsunamihub.info

3. Information We Collect

3.1 Personal Data You Provide

When you contact us or inquire about our services, we may collect:

• Full name
• Email address
• Phone number
• Company name and job title
• Billing and payment information
• Any other information you choose to provide in communications with us

3.2 Usage and Technical Data

When you visit our website, we automatically collect certain technical information, including:

• IP address and approximate geographic location
• Browser type, version, and language
• Operating system and device type
• Pages visited, time on page, and navigation paths
• Referring website or search terms
• Date and time of access

3.3 Cookie Data

We use cookies and similar tracking technologies to enhance your experience on our website. For full details, please see Section 9 (Cookies) below.

3.4 Google Ads API Data

Tsunami Innovation Limited uses the Google Ads API solely for internal business operations. We access and manage data only from our own Google Ads accounts, which we own and operate, to run advertising campaigns that promote our clients’ products and services. We do not access, collect, or process any Google Ads data from accounts owned by our clients or any other third parties. Our clients have no connection to or interaction with our Google Ads infrastructure or internal systems.

4. How We Use Your Information

We process your personal data for the following purposes:

• To respond to your inquiries and communicate with you about our services
• To enter into and fulfill service agreements with clients
• To send service-related communications, updates, and administrative notices
• To improve and maintain our website and user experience
• To analyze website traffic and usage patterns
• To comply with our legal and regulatory obligations
• To protect against fraud, abuse, and security threats
• To enforce our Terms of Service and other agreements

5. Legal Basis for Processing (GDPR)

For individuals in the European Economic Area (EEA) and the United Kingdom, we process your personal data on the following legal bases:

• Contract: Processing necessary to fulfill a service agreement or take pre-contractual steps at your request
• Legitimate Interests: Processing necessary for our legitimate business interests, such as improving our services and maintaining website security, where these interests are not overridden by your rights
• Legal Obligation: Processing required to comply with applicable laws and regulations
• Consent: Where we have obtained your explicit consent, such as for marketing communications — you may withdraw consent at any time by contacting us at support@tsunamihub.info

6. Data We Do Not Collect or Process

We do not collect, access, or store any Google Ads account data belonging to our clients. Our clients do not connect their Google Ads accounts to our website or any of our client-facing systems. Our internal platform, Tsug Hub, is not accessible to clients or the public and does not process any visitor data from this website.

We do not collect or process sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data.

We do not knowingly collect personal data from children under the age of 18. See Section 11 for more details.

7. Data Sharing and Disclosure

We do not sell, rent, or trade your personal data. We may share your information only in the following limited circumstances:

• Service Providers: With trusted third-party vendors who assist us in operating our website and business (such as hosting providers, analytics services, and payment processors), who are contractually bound to use your data only for the specified purpose and to protect it appropriately
• Legal Requirements: When required by law, court order, or governmental authority, or when necessary to protect our rights, property, or the safety of our employees and clients
• Business Transfers: In connection with a merger, acquisition, or sale of all or substantially all of our assets, in which case personal data may be transferred as part of the transaction, subject to equivalent privacy protections

We do not share your personal data with Google or any advertising platform for the purpose of targeting you with advertisements.

8. International Data Transfers

Tsunami Innovation Limited is based in Hong Kong. If you are accessing our website from the European Economic Area, the United Kingdom, or other regions with laws governing data collection and use that may differ from Hong Kong law, please be aware that your data may be transferred to and processed in Hong Kong.

Where we transfer personal data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission, or other mechanisms recognized under applicable data protection law.

9. Cookies

9.1 What Are Cookies

Cookies are small text files placed on your device by websites you visit. They are used to make websites function properly, improve efficiency, and provide information to the website owner.

9.2 Types of Cookies We Use

• Essential Cookies: Necessary for our website to function. These cannot be disabled.
• Analytics Cookies: Used to understand how visitors interact with our website (e.g., Google Analytics). These are only set with your consent where required by law.
• Preference Cookies: Used to remember your settings and preferences to improve your experience.

9.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of our website. For more information on managing cookies, visit www.allaboutcookies.org. Where required by applicable law, we will obtain your consent before setting non-essential cookies.

10. Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, disclosure, alteration, or destruction. These measures include:

• Encryption of data in transit using TLS/SSL
• Access controls restricting data access to authorized employees only
• Regular security reviews of our systems and practices
• Employee training on data protection and security

While we take reasonable steps to protect your data, no method of transmission over the internet is completely secure. We cannot guarantee absolute security of your information.

11. Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the relevant supervisory authority without undue delay and, where required by law, notify you directly. We maintain internal procedures for detecting, investigating, and reporting data breaches.

12. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable law. Specifically:

• Client contact and correspondence records: Up to 7 years after the end of a business relationship, for legal and accounting purposes
• Website analytics data: Up to 26 months
• Marketing communication preferences: Until you unsubscribe or withdraw consent

Once data is no longer required, we securely delete or anonymize it.

13. Children’s Privacy

Our website and services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you believe we have inadvertently collected information from a child under 18, please contact us immediately at support@tsunamihub.info and we will take steps to delete such information promptly.

14. Your Data Protection Rights

Depending on your location, you may have the following rights regarding your personal data. To exercise any of these rights, please contact us at support@tsunamihub.info. We will respond within 30 days.

14.1 Rights Under GDPR (EEA/UK Residents)

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data, subject to certain conditions
• Right to Restriction: Request that we restrict processing of your data
• Right to Data Portability: Receive your data in a structured, machine-readable format
• Right to Object: Object to processing based on legitimate interests or for direct marketing
• Rights Related to Automated Decision-Making: We do not make solely automated decisions that have legal or significant effects on you

14.2 Rights Under PDPO (Hong Kong Residents)

• Right of Access: Request access to personal data we hold about you
• Right to Correction: Request correction of personal data that is inaccurate

You also have the right to lodge a complaint with your local data protection supervisory authority at any time.

15. Third-Party Services

15.1 Google Analytics

We use Google Analytics to analyze website traffic. Google Analytics collects data such as pages visited, time on site, and referring sources using cookies and similar technologies. This data is aggregated and anonymous. You can opt out of Google Analytics by installing the Google Analytics Opt-out Browser Add-on available at tools.google.com/dlpage/gaoptout.

15.2 Google Ads

We use Google Ads and Google click tracking technologies to run and monitor the performance of our advertising campaigns. These technologies may collect data on ad clicks, device type, and location. This data is used solely by our internal team to manage and optimize our campaigns. For more information, see Google’s Privacy Policy at policies.google.com/privacy.

15.3 Hosting and Infrastructure

Our website is hosted by third-party infrastructure providers. These providers may process certain technical data (such as server logs and IP addresses) in the course of providing hosting services. All providers are bound by appropriate data processing agreements.

16. Links to Third-Party Websites

Our website may contain links to external sites not operated by us. This Privacy Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party websites you visit.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. Material changes will be indicated by an updated Effective Date at the top of this document. We encourage you to review this page periodically. Your continued use of our website after any changes constitutes your acceptance of the updated Privacy Policy.

18. Contact Us

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

Tsunami Innovation Limited

Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong

Email: support@tsunamihub.info

Website: https://tsunamihub.info

We will respond to all requests within 30 days of receipt.