Privacy Policy

1. Introduction

ClusterTrade is a computer integrated systems design practice operated by Cluster Trading Co., Limited. We build, integrate and maintain the computer systems that businesses rely on every day. This Privacy Policy explains how we collect, use, store, share and protect information when you visit our website at https://www.clustertrade.autos, when you contact us, or when you engage our services.

We are committed to handling personal information with care and transparency. We believe that clear privacy practices are not a legal formality but a foundation of trust between us and the people we serve. Please read this policy carefully so that you understand what information we gather, why we gather it, and the choices you have over your own data.

By using our website or our services, you acknowledge that you have read this policy. If you do not agree with any part of this policy, you should stop using our website and services and contact us so we can address your concerns. Capitalized terms not defined in this policy carry the meanings given to them in our Terms of Service.

2. Who We Are

ClusterTrade is the trading name under which Cluster Trading Co., Limited delivers computer integrated systems design and related services. We operate within the Computer Systems Design and Related Services industry, part of the Professional, Scientific, and Technical Services sector.

For the purposes of this Privacy Policy, the data controller is Cluster Trading Co., Limited. Our registered and operating address is set out in the Contact Us section at the end of this policy. When we refer to ClusterTrade, we, us or our in this policy, we are referring to Cluster Trading Co., Limited and its personnel.

3. Information We Collect

We collect only the information we need to operate our website, respond to your inquiries, and deliver our services. The categories of information we may collect are described below.

Information You Provide Directly

• Contact details such as your name, email address, phone number and company name when you submit a contact form or request a consultation.
• Message content and any details about your project, systems or requirements that you choose to share with us.
• Account and billing information if you become a client, including invoicing details and authorized contact names.
• Correspondence records, including emails and any documents you send to us in the course of an engagement.

Information Collected Automatically

• Technical data such as your IP address, browser type, device type, operating system and screen resolution.
• Usage data such as the pages you visit, the time you spend on each page and the referring website that brought you to us.
• Approximate location information derived from your IP address, used only at a regional level for analytics and security.

Information From Third Parties

In some cases we may receive information about you from business partners, service providers or publicly available sources, such as company directories. We only use such information where it is relevant to a legitimate business purpose and where we have a lawful basis to do so.

4. How We Collect Information

We collect information through three primary channels. First, directly from you when you fill out a form, send us an email, call our office or meet with our team. Second, automatically through the use of cookies, server logs and similar technologies when you browse our website. Third, indirectly from third parties such as analytics providers and business directories.

We do not collect information through deceptive means, and we do not purchase personal data lists for marketing purposes. Any information we hold is obtained either because you gave it to us directly or because it was generated through your ordinary use of our website and services.

You are never obligated to provide information we request, but some services cannot be provided without certain details. For example, we cannot respond to a contact form without an email address, and we cannot issue an invoice without a billing contact. Where a field is required, we will make that clear at the point of collection.

5. How We Use Your Information

We use the information we collect for the following purposes:

• To respond to inquiries and provide the information or services you request.
• To prepare proposals, scopes of work and project estimates.
• To deliver, manage and improve our computer systems design and integration services.
• To communicate with you about your project, including status updates, milestones and support matters.
• To process payments, issue invoices and maintain accurate accounting records.
• To personalize and improve our website experience and measure its performance.
• To maintain the security and integrity of our systems and prevent fraud or misuse.
• To comply with legal and regulatory obligations that apply to our business.

We do not use your personal information to make automated decisions that produce legal or similarly significant effects on you, and we do not engage in profiling that would affect your access to services.

6. Legal Bases for Processing

Depending on where you are located and the nature of our interaction, we rely on one or more of the following legal bases to process personal information:

• Performance of a contract, such as when we process information to deliver the services you have engaged us to provide.
• Legitimate interests, such as improving our website, responding to inquiries and protecting our systems, where those interests are not overridden by your rights.
• Consent, where you have given us clear permission to process your information for a specific purpose and where no other legal basis applies.
• Compliance with a legal obligation, such as record keeping, tax and regulatory requirements.

Where we rely on consent, you have the right to withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing that occurred before the withdrawal. We will tell you if a particular use of your information is based on consent at the time we collect it.

7. How We Share Information

We do not sell your personal information, and we do not rent it to third parties for their own marketing. We share information only in the limited circumstances described below.

Service Providers

We engage trusted providers to help us operate our business, such as website hosting, email delivery, analytics, payment processing and cloud infrastructure providers. These providers process information only on our instructions and under contractual obligations to protect it.

Professional Advisors

We may share information with our lawyers, accountants, auditors and insurers where necessary to obtain professional advice or to comply with our obligations.

Legal and Safety

We may disclose information if we believe in good faith that disclosure is required by law, court order or a valid legal request, or where necessary to protect the rights, property or safety of our company, our clients or the public.

Business Transfers

If our business or its assets are sold, merged or otherwise transferred, the information we hold may be included in the transferred assets. We will notify affected parties of any such change and any resulting changes to this policy.

8. Cookies and Similar Technologies

Cookies are small text files stored on your device when you visit a website. We use cookies and similar technologies such as local storage and web beacons to remember your preferences, understand how our website is used and keep our services secure.

The cookies we use fall into these categories:

• Essential cookies that are required for the website to function, such as those that support navigation and security.
• Preference cookies that remember choices you make, such as language or display settings.
• Analytics cookies that help us measure traffic and understand how visitors use our site so we can improve it.

You can control cookies through your browser settings. Most browsers allow you to block or delete cookies, and you can usually configure your browser to alert you when a cookie is set. Please note that blocking essential cookies may affect the functionality of our website. For more detail on managing cookies, consult the help documentation for your browser.

9. Data Retention

We retain personal information only for as long as necessary to fulfill the purposes described in this policy, or as long as required by applicable law. The specific retention period depends on the type of information and the reason it was collected.

• Inquiry and correspondence records are typically retained for up to three years after our last interaction.
• Client project records and related communications are retained for the duration of the engagement and for a reasonable period afterward to handle follow up and support.
• Accounting and invoicing records are retained for the period required by tax and company law.
• Technical and analytics data is retained for a shorter period and is regularly aggregated or deleted.

When information is no longer needed, we securely delete or anonymize it so that it can no longer be associated with you. If you request deletion of your information, we will comply to the extent permitted by our legal retention obligations.

10. Data Security

We take the security of your information seriously and apply technical and organizational measures designed to protect it against unauthorized access, alteration, disclosure or destruction. These measures include encryption of data in transit and at rest, access controls based on least privilege, secure authentication, network monitoring and regular security reviews.

Our personnel receive guidance on handling personal information and access is limited to those who need it to perform their roles. Our service providers are required to maintain equivalent safeguards and to process information only in accordance with our instructions.

No method of transmission or storage is completely secure, and we cannot guarantee absolute security. If we become aware of a breach involving your personal information, we will investigate promptly and notify you and the relevant authorities where required by law.

11. International Data Transfers

ClusterTrade is based in Hong Kong, but our service providers and infrastructure may be located in other countries. This means your information may be transferred to, and processed in, jurisdictions outside your own, including countries whose data protection laws may differ from those in your country of residence.

When we transfer personal information across borders, we take steps to ensure it receives an adequate level of protection. These steps may include relying on contractual clauses, assessing the recipient jurisdiction, or using providers certified under recognized frameworks. Where a specific legal mechanism is required for a transfer to you, we will apply it.

By using our services and providing information to us, you understand that your information may be transferred and processed internationally as described in this policy.

12. Your Rights and Choices

Depending on your location, you may have some or all of the following rights in relation to your personal information:

• The right to access a copy of the information we hold about you.
• The right to correct information that is inaccurate or incomplete.
• The right to request deletion of your information, subject to legal exceptions.
• The right to restrict or object to certain types of processing.
• The right to receive your information in a portable format.
• The right to withdraw consent where processing is based on consent.
• The right to lodge a complaint with a supervisory authority.

To exercise any of these rights, contact us using the details in the Contact Us section below. We will respond to your request within the timeframe required by applicable law, usually within thirty days. We may need to verify your identity before acting on a request, and we may ask for reasonable additional information to help us locate the relevant records.

13. Privacy for Children

Our website and services are intended for business users and are not directed to children under the age of 16. We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided information to us, please contact us immediately.

If we learn that we have collected personal information from a child under the applicable age without verified parental consent, we will take steps to delete that information as quickly as possible. We encourage parents and guardians to supervise the online activity of minors and to teach them about protecting their personal information.

14. Third Party Links and Services

Our website may contain links to third party websites, plugins or services that are not operated by us. This Privacy Policy does not apply to those third parties. We are not responsible for the privacy practices or content of any website we do not control, and we encourage you to review the privacy policies of any third party services you use.

When you interact with a third party service through our website, that service may collect information about you directly. We recommend reviewing the privacy notices of any such service before providing information. Links to third party sites do not imply that we endorse those sites or their practices.

15. Do Not Track and Analytics

Some browsers offer a Do Not Track signal that requests websites not to track your activity across sites. Because there is no widely adopted standard for how websites should respond to this signal, our website does not currently alter its behavior in response to Do Not Track requests.

We use analytics tools to understand aggregate website usage, such as which pages are visited most often and how visitors reach our site. This information is used to improve our content and user experience. The analytics data we review is generally aggregated and does not identify individual visitors in our ordinary reporting.

You can reduce the amount of usage data collected by using browser privacy settings, disabling cookies or using privacy oriented browsing tools. These choices are within your control and do not require any action on our part.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, our services or applicable law. When we make material changes, we will update the last updated date at the top of this page and, where appropriate, provide a more prominent notice.

We encourage you to review this policy periodically so that you remain informed about how we protect your information. Your continued use of our website or services after any changes to this policy constitutes acceptance of the revised terms. If a change materially affects how we use information we already hold, we will take reasonable steps to inform you directly.

17. Contact Us

If you have questions, concerns or requests relating to this Privacy Policy or the way we handle personal information, please contact us using any of the following details:

Email: contact@clustertrade.autos
Phone: +1 585 564 8714
Website: https://www.clustertrade.autos

We aim to acknowledge privacy inquiries within two business days and to resolve them as promptly as possible. If you believe your concern has not been adequately addressed, you have the right to contact your local data protection authority.