Privacy Notice

1. Who is responsible for your personal data

SEVELLO LIMITED, of Flat A, 8/F., Kingswell Commercial Tower, 171 Lockhart Road, Wan Chai, Hong Kong, is the data user under the PDPO and, where the GDPR applies to a particular relationship, the data controller for the personal data described in this notice.

For any privacy matter you may write to us at info@sevelloltd.com. We have not appointed a data protection officer, and are not required to; privacy enquiries are handled by the management of the company directly.

2. What personal data we collect

Because this site has no forms, cookies or analytics, browsing it does not send personal data to us. If you contact us by email, we receive the information you include: typically your name, contact details and the content of your message, together with any details you later share while we discuss a possible engagement.

The infrastructure that serves this website (hosting and content delivery) may process technical data such as IP addresses and request logs for the sole purposes of security and reliable delivery. We do not use such data to identify or profile visitors.

3. Why we process personal data

We use the information you send us to respond to your enquiry, to assess and prepare a possible service relationship at your request, to perform services once engaged, to keep proportionate business records, and to comply with legal obligations that apply to us.

For individuals in the EEA, the corresponding legal bases under Article 6 GDPR are: steps taken prior to entering into a contract; performance of a contract; our legitimate interests in running a small, discreet practice securely and keeping ordinary records; compliance with legal obligations; and consent, where we ever rely on it, which you may withdraw at any time.

4. Who may receive your personal data

We do not sell personal data, and we do not share it for marketing.

Access is limited to the people who need it: the small internal team handling your requests; the partners and suppliers engaged to carry out a specific arrangement you have asked for (an airline, a hotel, a charter operator), who receive only what the booking requires; and professional advisers or competent authorities where disclosure is required by law or reasonably necessary to protect legal rights and security.

5. International transfers

Sevello serves clients worldwide, so fulfilling a request will often mean passing necessary details to a partner in the country where the arrangement takes place. We share only what the specific task requires and expect our partners to treat it confidentially.

Where personal data of EEA residents is transferred outside the EEA, we rely on appropriate safeguards recognised by the GDPR, such as adequacy decisions or the European Commission's Standard Contractual Clauses, as applicable to the situation.

6. How long we keep personal data

We keep personal data no longer than is necessary for the purpose for which it was collected. Correspondence about an enquiry that does not lead to an engagement is kept only as long as a courteous follow-up may reasonably require, and then deleted.

Where a client relationship begins, records are retained for its duration and afterwards for the periods required by applicable accounting, tax and other legal obligations.

7. Your rights

Under the PDPO you may request access to the personal data we hold about you and request the correction of inaccurate data. We will respond within the timeframes the Ordinance prescribes.

If you are in the EEA, you additionally have the rights the GDPR provides: access, rectification, erasure, restriction of processing, objection to processing based on legitimate interests, portability of data you provided to us, and the right to withdraw consent at any time without affecting prior processing. To exercise any right, write to info@sevelloltd.com.

8. How we protect personal data

We apply technical and organisational measures proportionate to the modest amount of data we handle: access restricted to those who need it, reputable and secured service providers, and strict internal confidentiality — the same discretion we apply to every other aspect of the work. No internet-based service can promise absolute security, but we take reasonable care at every layer.

9. Cookies and tracking

This website does not set cookies of any kind. It uses no analytics, no advertising technologies, no tracking pixels and no third-party embeds that could observe your visit. That is why you see no cookie banner: there is nothing to consent to.

10. Questions and complaints

If you have a privacy concern, please contact us first at info@sevelloltd.com so that we can put it right.

You may also complain to the Office of the Privacy Commissioner for Personal Data in Hong Kong (PCPD). If you are in the EEA, you may lodge a complaint with the supervisory authority of your habitual residence, place of work or the place of the alleged infringement.