Privacy Policy
‍GSM Limited
Last updated: 5 September 2026
1. Who we areGSM Limited ("GSM", "we", "us") is a company incorporated in Hong Kong, Business Registration number 71827027. We are a wholesale trader of mobile phones and consumer electronics, selling to businesses worldwide.Our registered address is Flat K16, Block 2, 2/F, Kaiser Estate Phase 2, 47–53 Man Yue Street, Hung Hom, Kowloon, Hong Kong.We are the data user (data controller) responsible for the personal data described in this policy. You can reach us at info@gsmhongkong.com or +852 9481 8345.2. What this policy coversThis policy explains what personal data we collect through www.gsmhongkong.com and in the course of doing business with you, how we use it, who we share it with, and what rights you have.We sell to businesses, not to consumers. Most of the information we hold is business contact information — a person's name, role, company, and how to reach them. Under Hong Kong law and under the laws of most other places, that is still personal data, and this policy applies to it.3. What we collectInformation you give usWhen you complete a form on our website, or contact us by email, telephone or WhatsApp, we collect what you choose to tell us. Typically that is:Your nameYour company nameYour email addressYour telephone or WhatsApp numberYour country or locationThe content of your enquiry or messageInformation we collect when we trade with youIf you place an order with us, we also collect and hold:Company billing and delivery addressesNames and contact details of your staff involved in the order, such as warehouse or receiving contactsBusiness registration, tax and customs identifiers required for export documentation — for example VAT, TIN, IRD, NZBN or customs client codesBank or payment reference details relating to your payments to usOrder history, invoices, packing lists and shipping recordsInformation collected automaticallyOur website is hosted by Webflow. Like most website hosts, Webflow's servers automatically record limited technical information when a page is requested, including IP address, browser type, device type, referring page and the pages viewed. We use this only to keep the site running securely and to understand, in aggregate, how it is used.We do not run advertising pixels, behavioural tracking or third-party analytics on this website. If that changes, we will update this policy before doing so.4. Why we use your personal dataWe use personal data for the following purposes:To respond to your enquiry and to prepare and send price quotationsTo perform our contract with you — processing orders, arranging payment, packing and shipping goodsTo prepare export and customs documentation, including commercial invoices, packing lists and declarations required by carriers and by the customs authorities of the destination countryTo meet our legal and regulatory obligations, including accounting, tax, audit and anti-money-laundering requirementsTo manage our relationship with you, including keeping records of what we have agreed and resolving disputesTo send you price lists, stock availability and other trade communications, where you have agreed to receive them (see section 9)If you are located in the European Economic Area or the United Kingdom, our legal bases for processing are: performance of a contract with you or steps taken at your request before entering into one; compliance with a legal obligation; our legitimate interests in operating and growing a business-to-business trading company; and your consent, where we rely on it for marketing.5. CookiesOur website uses only strictly necessary cookies set by our hosting provider, Webflow. These keep the site functioning, remember your form input while you complete it, and help prevent automated form abuse. They are not used to profile you or to target advertising.We do not use analytics cookies, advertising cookies or social media tracking pixels on this website. You can block or delete cookies through your browser settings, though parts of the site may not work correctly if you block strictly necessary cookies.6. Who we share your personal data withWe do not sell personal data, and we do not share it for anyone else's marketing purposes. We disclose personal data only to the following, and only so far as necessary:Our website host — Webflow, Inc., which hosts our site and stores form submissionsFreight forwarders, couriers and logistics providers who collect, carry and deliver your goodsCustoms authorities and border agencies in Hong Kong and in the destination country, where required for import or export clearanceBanks and payment providers handling payments between usOur accountants, auditors, insurers and professional advisers, under a duty of confidentialityLaw enforcement, regulators or courts, where we are required to do so by law or to establish, exercise or defend legal claimsWhere we communicate with you over WhatsApp, that service is operated by Meta Platforms and the content and metadata of those messages are handled under Meta's own terms and privacy policy.7. Transfers outside Hong KongWe are based in Hong Kong and our records are held here. Because we ship internationally, personal data will necessarily be transferred to the country you are importing into — to your carrier, your broker, and the customs authority of that country. Our website host stores data on servers outside Hong Kong.Where personal data is transferred out of the European Economic Area or the United Kingdom, we rely on appropriate safeguards, including standard contractual clauses where they apply, or on the transfer being necessary for the performance of our contract with you.8. How long we keep itWe keep enquiry correspondence for as long as needed to deal with the enquiry and for a reasonable period afterwards in case you come back to us.We keep transaction records — invoices, packing lists, shipping and payment records — for at least seven years, as required of Hong Kong companies under the Companies Ordinance and the Inland Revenue Ordinance. After that, records are deleted or anonymised unless we are required to retain them for longer.9. Direct marketingWe will only use your personal data to send you price lists, stock updates or other promotional trade communications where you have given us your consent to do so, as required by Part VIA of the Hong Kong Personal Data (Privacy) Ordinance.Before we use your data for direct marketing for the first time, we will tell you what kinds of personal data we intend to use and what classes of goods and services the marketing will relate to, and we will give you a clear way to say no. We will not transfer your personal data to anyone else for their own marketing purposes.You can opt out at any time, at no cost, by emailing info@gsmhongkong.com, by replying "STOP" to a WhatsApp or email message from us, or by using the unsubscribe link in any email. We will stop as soon as we receive your request.10. How we protect your personal dataWe take reasonably practicable steps to protect personal data against unauthorised or accidental access, loss or use. These include restricting access to those in our business who need it, using access-controlled systems and business accounts rather than personal ones for company communications, and requiring confidentiality from the service providers we use.No system is completely secure. If a data breach occurs that is likely to result in serious harm, we will act promptly to contain it and will notify affected parties and the relevant authorities where required.11. Your rightsEveryoneUnder the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486), you have the right to:Ask whether we hold personal data about you, and to be given a copy of it (a data access request)Ask us to correct personal data about you that is inaccurate (a data correction request)Ask us to stop using your personal data for direct marketingWe may charge a reasonable fee for complying with a data access request, as permitted by the Ordinance. We will normally respond within 40 days.If you are in the EEA or the UKYou additionally have the right to erasure, to restrict or object to processing, to data portability, and to withdraw consent at any time where we rely on it. Withdrawing consent does not affect the lawfulness of processing carried out before you withdrew it.If you are elsewhereLocal privacy law in your country — for example the New Zealand Privacy Act 2020 or the Australian Privacy Act 1988 — may give you further rights. Contact us and we will deal with your request in accordance with the law that applies to you.How to exercise your rightsEmail info@gsmhongkong.com with the subject line "Privacy request". We may ask you to verify your identity before we act.12. ComplaintsIf you are unhappy with how we have handled your personal data, please contact us first so we can try to put it right.You may also complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong (www.pcpd.org.hk). If you are in the EEA or the UK, you may complain to your local supervisory authority.13. ChildrenOur website and our business are directed at businesses, not at individuals under 18. We do not knowingly collect personal data from children. If you believe we hold data about a child, please contact us and we will delete it.14. Changes to this policyWe may update this policy from time to time. The date at the top shows when it was last changed. If we begin using analytics, advertising pixels or other tracking on our website, we will update this policy before we do so.15. Contact usGSM Limited
Flat K16, Block 2, 2/F, Kaiser Estate Phase 2
47–53 Man Yue Street, Hung Hom
Kowloon, Hong Kong
Business Registration No. 71827027Email: info@gsmhongkong.com
Telephone / WhatsApp: +852 9481 8345
Web: www.gsmhongkong.com