Yard Loam · Notice of data practice
What we keep, and for how long.
A short notice in plain words: an enquiry desk keeps enquiries, an invoice keeps a record, and nothing is sold on.
Hong Kong PDPOLast updated 9 September 2026harlowne.com
Who is responsible
XiNUo-D Trading Co., Limited is the data user for this site, harlowne.com. Its registered office is the address in the box at the foot of this page. Write to xinuo-d@outlook.com for anything in this notice: a copy of your data, a correction, a deletion, or a question about a claim. There is no separate privacy department; the same desk answers.
What we collect when you write
When you send an enquiry we keep the fields you fill in: name, email address, telephone or WhatsApp number if you offer one, company name, country, the SKUs and quantities you ask about, and the text of the message. If you go on to ask for a quote we also keep the delivery address and any tax or customs reference you give us. We never ask for card numbers, and we do not want them.
Order and claims correspondence
Correspondence about an order or a claim is retained with that order, not in a separate file. Your emails, WhatsApp messages, photographs of a blunt bevel or a split handle, the invoice, the packing note and the courier tracking record sit together under one order reference. That is deliberate: a fault should be judged on the evidence, and our books should match what was actually packed and sent.
Server logs
The web server writes a line for every request: IP address, browser user-agent, the page requested, the referring page if any, and the time. We use the log to keep the site up, spot scraping and investigate abuse. Log lines are not matched to enquiry records in the ordinary course, and they are deleted on a short cycle.
Cookies and cart state
This site sets a session cookie so a basket survives a page load, and that is the whole job it does. There are no advertising cookies, no remarketing pixels, no social plug-ins and no third-party analytics scripts. Clearing cookies in your browser ends the session and empties the basket. Every page can be read with cookies refused.
Why we hold it
We hold enquiry data to answer you, quote stock and price, arrange packing and shipping, and keep the accounting record Hong Kong law requires. The grounds are the steps needed to make a contract with you, our legitimate interest in running a trading business, and our legal duty to keep books. We do not sell personal data, we do not rent lists, and we do not use your details for advertising.
Who else handles it
Four kinds of provider see data, each only what the task needs. The mailbox provider stores the email. The courier or freight forwarder receives the name, address and telephone needed for delivery. The bank or payment provider sees invoice and settlement details, never card data supplied to us. The hosting provider holds the site and its logs. Each is bound by contract to use the data only for that purpose.
Transfers outside Hong Kong
Some providers run systems outside Hong Kong, so your data may be processed abroad. Where that happens we choose providers with contractual data-protection terms and access controls, and we send only the fields the task needs. A courier abroad sees the delivery address; a mailbox provider abroad holds the message. Nothing else travels.
How long we keep it
Enquiries that do not become an order are deleted or anonymised after 24 months. Order, claim and accounting records are kept for 7 years from the end of the financial year, because that is the retention Hong Kong requires. Server logs are kept for up to 90 days. When a period ends we delete the file or strip the identifying fields, and we do not keep a shadow copy.
Your rights
Under the Personal Data (Privacy) Ordinance you may ask for a copy of the personal data we hold about you, ask us to correct anything wrong, ask us to stop using it for a purpose, or ask for deletion where we have no continuing duty to keep it. Write to xinuo-d@outlook.com and say what you want. We may ask you to prove identity. A correction is free of charge, and we answer as quickly as the law allows.
Children
This is a trade enquiry desk for gardening tools, and the tools are sharp. We do not knowingly collect data from anyone under 18. If a young gardener writes in, we answer the question but we do not open a trade account, and the record does not outlive the enquiry period. If you think a child's details are with us, write and we will delete them.
Complaints and changes
If you are unhappy with how we have handled your data, write to us first and give us a chance to put it right. You may also complain to the Privacy Commissioner for Personal Data, Hong Kong (PCPD). We update this notice when a supplier or the law changes; the date at the top of the page moves with it, and the version published here is the one in force.
The data user
XiNUo-D Trading Co., Limited
ROOM H, 18/F, CENTURY INDUSTRIAL CENTRE, 33-35 AU PUI WAN STREET, FO TAN, SHA TIN, HONG KONG
Last updated 9 September 2026 · XiNUo-D Trading Co., Limited