Privacy Policy

Introduction

Bethune Capital Limited operates the website located at https://www.bethunecap.mom and provides Computer Systems Design and Related Services, including but not limited to integrated systems design, cloud infrastructure architecture, cybersecurity consulting, data engineering, DevOps platform engineering, and technology advisory services. Our registered business address is Rm 503 5/F, 9 Chong Yip Street, Kwun Tong, Hong Kong (HK). This Privacy Policy forms part of the overall terms governing your use of our website and services.

The developer name BethuneCap represents the trade identity under which Bethune Capital Limited delivers its technology services and digital products. When this policy refers to Bethune Capital, the Company, we, us, or our, it refers to Bethune Capital Limited and its affiliated operations.

This Privacy Policy applies to all visitors, users, clients, and other individuals who access or interact with our website, submit inquiries through our contact form, engage with our consulting or systems design services, or otherwise communicate with Bethune Capital Limited. We take data privacy seriously and have designed our information handling practices around the principles of transparency, data minimization, purpose limitation, and accountability.

Information We Collect

We collect several categories of information depending on the nature of your interaction with Bethune Capital Limited. The types of information we may collect include the following:

Personal Identification Information. When you fill out our contact form, request a consultation, subscribe to communications, or engage our services, we may collect your full name, email address, phone number, company name, job title, and any other information you voluntarily provide through our website forms or in direct correspondence with our team.

Professional and Business Information. In the course of providing Computer Systems Design and Related Services, we may collect information about your organization, technology infrastructure, business requirements, project specifications, and operational data that you share with us for the purpose of our consulting and systems design engagements.

Technical and Usage Data. When you visit our website, our servers automatically record certain information sent by your browser or device. This may include your Internet Protocol address, browser type and version, operating system, referring URL, pages visited, time and date of your visit, time spent on pages, and other diagnostic data. This information is collected passively through standard web server logs and analytics tools.

Communication Data. If you contact us via email, phone, or through our website contact form, we may retain records of that correspondence, including the content of your message, your contact details, and our responses. Phone communications may be logged with timestamps and subject matter for quality assurance and service continuity purposes.

Financial and Transaction Information. For clients who engage our paid services, we may collect billing information, payment details, invoicing records, and transaction histories. Payment processing is handled through secure third-party payment processors, and we do not store full credit card numbers or sensitive payment credentials on our own systems.

How We Collect Information

Bethune Capital Limited collects information through various methods and at different touchpoints in your interaction with our organization. Understanding how we gather data is essential to informed consent and transparency.

Direct Collection. The primary method we use is direct collection, where you voluntarily provide information to us. This occurs when you complete and submit our website contact form, when you send us an email or call our office, when you participate in a consultation or discovery session, when you sign a service agreement or letter of engagement, and when you provide feedback or testimonials about our services.

Automated Collection. As you navigate through our website, we use automated technologies to collect certain technical information. Our web servers log standard HTTP request data, including IP addresses, request timestamps, and user agent strings. We may also use cookies, web beacons, and similar technologies to understand how visitors interact with our website, which pages receive the most attention, and how we can improve the user experience. Detailed information about our cookie practices is provided in the Cookies and Tracking Technologies section below.

Third Party Sources. In limited circumstances, we may receive information about you from third party sources. For example, if a colleague or business partner refers you to Bethune Capital Limited, we may receive your contact information from that individual. We may also access publicly available business information from professional networking platforms, corporate registries, and industry databases to prepare for consultations and to understand the context of a prospective engagement.

Client Engagement Collection. During the delivery of our Computer Systems Design and Related Services, we may collect technical information about your existing systems, infrastructure configurations, security postures, and operational processes. This information is collected through interviews, system audits, documentation reviews, and diagnostic tools, always with your knowledge and consent as part of the engagement scope.

Use of Information

Bethune Capital Limited uses the information we collect for legitimate business purposes that are aligned with the expectations you would reasonably have when providing such information. The specific purposes for which we use information include:

Service Delivery and Fulfillment. We use your personal and business information to deliver the Computer Systems Design and Related Services that you have requested. This includes designing system architectures, developing technical specifications, implementing solutions, providing consulting advice, and managing ongoing client relationships. Your information enables us to understand your requirements, tailor our recommendations, and execute our engagements effectively.

Communication and Support. We use your contact information to respond to inquiries, provide updates about our services, send administrative notices, deliver project deliverables, and communicate about your account or engagement status. We may also use your information to send you relevant technical content, industry insights, or service announcements, but only where you have consented to receive such communications.

Website Improvement and Analytics. Technical and usage data helps us monitor and improve the performance, security, and user experience of our website. We analyze aggregated traffic patterns, identify technical issues, test new features, and make data-driven decisions about our web presence and content strategy.

Legal and Compliance Obligations. We may use and retain information as required by applicable laws, regulations, legal processes, or enforceable governmental requests. This includes maintaining records for tax purposes, complying with anti-money laundering obligations, responding to lawful subpoenas, and enforcing our contractual rights and terms of service.

Business Operations and Development. Aggregated and de-identified data may be used for business planning, financial forecasting, market analysis, and service development. Any such use involves data that has been stripped of personally identifiable characteristics and cannot reasonably be re-associated with any individual.

Sharing and Disclosure of Information

Bethune Capital Limited does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share information only as described in this policy and only under circumstances that respect your privacy expectations.

Service Providers and Vendors. We engage trusted third party companies and individuals to facilitate our business operations, including cloud hosting providers, email delivery services, payment processors, analytics platforms, and professional advisors such as legal counsel and accountants. These service providers have access to your information only to the extent necessary to perform their functions on our behalf and are contractually obligated to protect the confidentiality and security of your data.

Business Transfers. In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving Bethune Capital Limited, your information may be transferred as part of that transaction. We will notify you via email or a prominent notice on our website of any change in ownership or control of your personal information, as well as any choices you may have regarding your information.

Legal Requirements. We may disclose your information when we believe in good faith that disclosure is necessary to comply with a legal obligation, protect and defend the rights or property of Bethune Capital Limited, prevent or investigate possible wrongdoing in connection with our services, protect the personal safety of users of our website or the public, or protect against legal liability.

With Your Consent. We may share your information for any other purpose with your explicit consent, which may be obtained in writing, electronically, or through an affirmative action indicating your agreement to the specific disclosure.

Aggregated and De-Identified Data. We may share aggregated, anonymized, or de-identified information that does not directly identify any individual for purposes such as industry benchmarking, research publications, marketing materials, or demonstrating our capabilities to prospective clients.

Data Retention

Bethune Capital Limited retains personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal, regulatory, accounting, and reporting requirements. The criteria used to determine our retention periods include:

Duration of Engagement. Information collected in connection with an active client engagement is retained for the duration of that engagement and for a reasonable period thereafter to address any follow-up questions, warranty obligations, or post-implementation support requirements. Our standard post-engagement retention period for client project data is seven years following the conclusion of the engagement, consistent with standard professional services recordkeeping practices.

Legal Obligations. Where applicable laws, regulations, or contractual obligations require us to retain certain records for a specified period, we will retain the relevant information for the legally mandated duration. This may include tax records, financial transaction logs, and evidence of compliance with regulatory frameworks applicable to Computer Systems Design and Related Services.

Business Needs. We may retain de-identified or aggregated data indefinitely for analytical, research, and business planning purposes, as such data cannot be linked back to any specific individual. Personal data that is no longer needed for any of the purposes described in this policy is securely deleted, anonymized, or otherwise disposed of in accordance with our data destruction procedures.

Communication Records. General correspondence and inquiry records for individuals who have not become active clients are typically retained for a period of two years from the date of last contact, after which they are securely purged unless a longer retention period is required by law or there is an ongoing business relationship.

Data Security

Bethune Capital Limited implements and maintains administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information. Our security program is built upon industry-recognized frameworks and best practices, including but not limited to defense-in-depth architecture, the principle of least privilege, and continuous monitoring.

Technical Safeguards. We employ encryption in transit using Transport Layer Security for all data transmitted between your browser and our servers. Data at rest is protected using industry-standard encryption algorithms. Our infrastructure is protected by network firewalls, intrusion detection systems, and regular vulnerability scanning. Access to production systems is strictly controlled through multi-factor authentication, role-based access controls, and comprehensive audit logging of all administrative actions.

Administrative Safeguards. All employees and contractors of Bethune Capital Limited undergo privacy and security training as part of their onboarding and at regular intervals thereafter. Access to personal information is restricted to personnel who have a legitimate business need. Our internal policies govern the acceptable use, handling, and disposal of personal data, and violations are subject to disciplinary action up to and including termination of employment or contract.

Physical Safeguards. Our physical office premises at Rm 503 5/F, 9 Chong Yip Street, Kwun Tong, Hong Kong (HK) are secured with access control systems. Server infrastructure and data storage facilities, whether on-premises or at third-party data centers, are housed in facilities with biometric access controls, video surveillance, and environmental monitoring.

Incident Response. Despite our best efforts, no method of transmission over the Internet or method of electronic storage is completely secure. In the event of a data breach involving personal information, we maintain an incident response plan that includes prompt investigation, containment, notification to affected individuals as required by applicable law, and remedial actions to prevent recurrence.

Your Rights and Choices

Depending on your jurisdiction of residence, you may have certain rights regarding the personal information we hold about you. Bethune Capital Limited respects these rights and provides mechanisms for you to exercise them.

Access and Portability. You have the right to request access to the personal information we hold about you and to receive a copy of that information in a structured, commonly used, and machine-readable format. Upon receiving a verifiable request, we will provide you with a summary of the categories of personal information we have collected about you, the sources of that information, and the purposes for which it is being processed.

Rectification. If you believe that the personal information we hold about you is inaccurate, incomplete, or out of date, you have the right to request that we correct or update that information. We encourage you to keep your contact information current so that we can maintain accurate records.

Deletion. In certain circumstances, you may request that we delete the personal information we hold about you. We will evaluate such requests against our legal obligations and legitimate business interests. Where deletion is not possible due to legal retention requirements, we will inform you of the reason and the expected retention period.

Objection and Restriction. You may object to the processing of your personal information in certain circumstances, including where processing is based on our legitimate interests. You may also request that we restrict the processing of your information while we verify its accuracy or consider an objection you have raised.

Opt-Out of Marketing Communications. If you receive promotional or marketing communications from us, you may opt out at any time by using the unsubscribe link provided in each email or by contacting us directly. Even after opting out of marketing messages, you may continue to receive transactional or service-related communications necessary for your engagement with us.

To exercise any of these rights, please contact us using the information provided in the Contact Information section of this policy. We will respond to your request within the timeframe required by applicable law, typically within thirty days. We may need to verify your identity before processing your request to ensure the security of your personal information.

Cookies and Tracking Technologies

Bethune Capital Limited uses cookies and similar tracking technologies on our website to enhance your browsing experience, analyze site traffic, and understand where our visitors come from. This section explains what cookies are, how we use them, and what choices you have regarding their deployment.

What Are Cookies. Cookies are small text files that are placed on your computer or mobile device by websites that you visit. They are widely used to make websites work more efficiently, to remember your preferences, and to provide information to the website operators. Cookies may be session cookies, which expire when you close your browser, or persistent cookies, which remain on your device for a set period or until you delete them.

Types of Cookies We Use. Our website uses essential cookies that are necessary for the website to function properly and cannot be switched off in our systems. These are usually set in response to actions made by you, such as setting your privacy preferences or filling in forms. We also use analytics cookies that help us understand how visitors interact with our website by collecting and reporting information anonymously. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.

Third Party Cookies. Some cookies may be set by third party services that appear on our pages. We use third party analytics tools to understand usage patterns, but we configure these tools to minimize the collection of personally identifiable information. We do not use advertising or targeting cookies on our website, and we do not engage in behavioral advertising or retargeting campaigns.

Managing Cookies. Most web browsers allow you to control cookies through their settings preferences. You can typically configure your browser to block all cookies, delete existing cookies, or alert you when a cookie is being set. However, if you choose to block cookies, some features of our website may not function as intended. For more information about managing cookies, you may consult the help documentation for your specific browser or visit websites that provide independent guidance on cookie management.

Third Party Services

Our website and service delivery may include links to third party websites, platforms, and services that are not owned or controlled by Bethune Capital Limited. This section describes our relationship with third party services and your responsibilities when interacting with them.

External Links. Our website may contain links to external websites that we believe may be of interest to our visitors. These links are provided for convenience and informational purposes only. Bethune Capital Limited has no control over and assumes no responsibility for the content, privacy policies, or practices of any third party websites or services. We encourage you to review the privacy policies of every website you visit.

Integrated Services. In delivering our Computer Systems Design and Related Services, we may recommend, implement, or integrate third party software platforms, cloud services, and infrastructure components on behalf of our clients. The privacy and data handling practices of those third party services are governed by their respective terms and policies, not by this Privacy Policy. We assist our clients in evaluating the privacy implications of such integrations as part of our advisory services.

Payment Processing. For clients who engage our paid services, payment transactions are processed through secure, PCI-compliant third party payment processors. We do not collect or store full payment card details on our own systems. The payment processor collects and processes your payment information in accordance with its own privacy policy and terms of service.

Analytics Providers. We use third party analytics services to understand website usage patterns. These services may collect information such as your IP address, browser type, referring pages, and time spent on pages. We have configured our analytics implementations to respect privacy by using IP anonymization where available and by disabling data sharing features that would allow the analytics provider to use our data for their own purposes.

International Data Transfers

Bethune Capital Limited is headquartered in Hong Kong, and our primary operations and data processing activities occur in Hong Kong. However, as a provider of Computer Systems Design and Related Services to clients around the world, your personal information may be transferred to and processed in countries other than your country of residence.

Transfer Mechanisms. When we transfer personal information across international borders, we implement appropriate safeguards to ensure that your data remains protected in accordance with this Privacy Policy and applicable data protection laws. These safeguards may include standard contractual clauses approved by relevant regulatory authorities, adherence to recognized data protection frameworks, and contractual commitments from any third party recipients regarding the handling of personal data.

Data Hosting Infrastructure. Our website and business systems may be hosted on cloud infrastructure located in data centers across multiple geographic regions. We select hosting providers and data center locations based on a combination of performance, reliability, and compliance requirements. Where client engagements involve data subject to specific jurisdictional requirements, we work with clients to establish appropriate data residency and processing arrangements.

Your Consent. By using our website and providing your information to us, you acknowledge and consent to the transfer of your information to, and its processing in, countries that may have data protection laws that differ from those in your country of residence. You may withdraw this consent at any time by contacting us, although doing so may affect our ability to provide services to you.

Privacy for Children

Our website and services are not directed to, and we do not knowingly collect personal information from, children under the age of thirteen, or under the relevant age of digital consent in applicable jurisdictions. Consistent with the Childrens Online Privacy Protection Act and similar international regulations, we take specific measures to avoid the collection of information from minors.

If we become aware that a child under the applicable age threshold has provided us with personal information without verifiable parental consent, we will take prompt steps to delete that information from our records. If you are a parent or guardian and believe that your child has provided personal information to Bethune Capital Limited, please contact us immediately using the contact details provided in this policy so that we can take appropriate action.

We encourage parents and guardians to take an active role in supervising their childrens online activities and to educate them about the importance of protecting personal information online. Our website is designed for a professional audience and the subject matter relates to business technology services that are not targeted at or intended for children.

Changes to This Privacy Policy

Bethune Capital Limited reserves the right to update, modify, or replace this Privacy Policy at any time at our sole discretion. As our business evolves, as technology changes, and as legal requirements are updated, we may need to revise our privacy practices and the terms of this policy accordingly.

Notification of Changes. When we make material changes to this Privacy Policy, we will post a prominent notice on our website and update the Last Updated date at the top of this page. For changes that materially affect the way we use or disclose personal information that we have previously collected, we will make reasonable efforts to provide additional notice, such as by sending an email to the address we have on file for you or by displaying a notification banner on our website.

Review Responsibility. You are encouraged to review this Privacy Policy periodically to stay informed about our information practices. Your continued use of our website or services after any modification to this Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised policy, you should discontinue the use of our website and services and contact us to discuss any concerns.

Historical Versions. Upon request, we can provide copies of previous versions of this Privacy Policy for your reference. Archived policies are maintained as part of our compliance documentation and are available to regulators, auditors, and individuals with a legitimate interest.

California Privacy Rights

This section supplements the information contained in the rest of this Privacy Policy and applies solely to visitors, users, and clients who reside in the State of California. We adopt this section to comply with the California Consumer Privacy Act of 2018 and the California Privacy Rights Act of 2020, and any terms defined in those statutes have the same meaning when used in this section.

Categories of Personal Information Collected. In the preceding twelve months, Bethune Capital Limited has collected the following categories of personal information: identifiers such as name, email address, and IP address; commercial information such as records of services purchased or considered; internet or other electronic network activity information such as browsing history and interaction with our website; and professional or employment-related information that you provide in the course of business interactions with us.

Sources and Purposes. We collect personal information from the sources and for the purposes described in the Information We Collect and Use of Information sections of this policy. We have not sold personal information in the preceding twelve months, and we do not sell personal information as that term is defined under California law. We do not have actual knowledge that we sell or share the personal information of consumers under sixteen years of age.

Your Rights Under California Law. California residents have the right to request that we disclose what personal information we collect, use, disclose, and sell, and to request deletion of their personal information. You also have the right to opt out of the sale or sharing of your personal information, the right to correct inaccurate personal information, and the right to limit the use and disclosure of sensitive personal information. We will not discriminate against you for exercising any of these rights.

Exercising Your Rights. To exercise the rights described above, please submit a verifiable consumer request to us using the contact information provided in this policy. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable request. Your request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

GDPR Compliance

For individuals located in the European Economic Area, the United Kingdom, and Switzerland, this section provides additional information required under the General Data Protection Regulation and its United Kingdom equivalent.

Legal Bases for Processing. Bethune Capital Limited processes personal data on the following legal bases: consent, where you have given clear consent for us to process your personal data for a specific purpose; contractual necessity, where processing is necessary for the performance of a contract with you or to take steps at your request before entering into a contract; legitimate interests, where processing is necessary for our legitimate interests or those of a third party and your interests and fundamental rights do not override those interests; and legal obligation, where we need to comply with a legal or regulatory obligation.

Data Subject Rights Under GDPR. In addition to the rights described elsewhere in this policy, data subjects in the EEA, UK, and Switzerland have the right to lodge a complaint with a supervisory authority in their country of residence, the right to data portability, the right to restrict processing, and the right to object to processing based on legitimate interests or for direct marketing purposes.

Data Protection Officer. Given the nature and scale of our data processing activities, we have determined that a formal Data Protection Officer appointment is not currently required. However, privacy-related inquiries are managed by our leadership team and are given prompt and careful attention. All such inquiries should be directed to the contact information provided in this policy.

International Transfers Under GDPR. Where we transfer personal data from the EEA, UK, or Switzerland to countries that have not been deemed to provide an adequate level of data protection, we implement appropriate safeguards such as standard contractual clauses to ensure the continued protection of your data.

Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our data handling practices, you are encouraged to contact us through any of the following channels. We are committed to addressing privacy inquiries promptly and thoroughly.

Email: dispatch@bethunecap.mom

Phone: +16673967427

Postal Address:
Bethune Capital Limited
Rm 503 5/F
9 Chong Yip Street
Kwun Tong
Hong Kong (HK)

Website: https://www.bethunecap.mom

When contacting us about a privacy matter, please provide sufficient detail to allow us to understand your question or concern fully. We will acknowledge receipt of your communication promptly and aim to provide a substantive response within the applicable legal timeframe, typically within thirty calendar days.

If you are not satisfied with our response, you may have the right to escalate your concern to the relevant data protection authority in your jurisdiction. We encourage you to contact us first so that we have the opportunity to address your concern directly before any external escalation.