Privacy Policy

1. Overview of This Policy

This privacy policy describes how Pulesi Group Limited collects information when a person visits the website at pulesi.autos, when that person writes to the trading liaison desk, or when that person uses any of the liaison and procurement services described on the site. The purpose of this notice is to explain, in plain language, what data we touch, why we touch it and what rights you hold over it. We work with commercial buyers, sellers, factories and manufacturers, and we respect the personal data of every individual who crosses our operating desk, whether they are an enquiry maker, a client representative or a factory contact.

Trade liaison sits on a trust floor. A buyer shares a product intention, a seller shares a capacity record and both share contact details so that the deal can be advanced. We treat those details as commercially sensitive and personally sensitive at the same time, and we keep them inside our signal room under the same discipline as any other working note. This policy is written to be read and understood rather than buried, and we encourage you to write to us if any part of it is unclear. The developer Pulesi and the wider team at Pulesi Group Limited can be reached at any time through the channels listed at the end of this notice.

2. The Information We Collect

The information that comes into our keeping falls into a small number of clear groups, each described below so that you can see the full picture rather than a vague summary.

• Contact details. When you write to us, we may hold your name, an email address, a telephone number, a company name and your role within that company. These details let us reply to a dispatch and address the right person on the right side of a deal.
• Commercial correspondence. The messages, drawings, specification sheets, price indications and delivery notes that you share in the course of a liaison engagement. This is the working material of the deal itself.
• Technical records. Information such as factory names, production capacity, audit outcome sheets and inspection reports that we gather while verifying a supplier on your behalf.
• Financial gate information. Payment route references, invoice identifiers and escrow milestone notes that we hold so that a settlement can be reconciled. We do not itself store card numbers or hold funds on your behalf.
• Technical device data. When you simply visit the website we may receive limited technical data such as the type of browser, the operating system, the approximate region and the pages read. This data is used to keep the site stable and to understand which pages are of genuine use.
• Communication preference. Whether you choose to receive routine updates, and on which channel, so that we do not contact you more often than you want.

We aim to keep this list modest. If we ever need to collect a category of information that is not described above, we will gather more specific consent before we begin, or apply another lawful ground that is explained in this notice and to you directly.

3. How We Collect the Information

Information reaches us in three ordinary ways. The first is directly from you. This happens when you fill in the contact form on the website, send an email to liaison@pulesi.autos, telephone the desk or hand us a paper brief during a factory visit or a trade fair. In each case you choose what to send, and we keep only what the engagement needs.

The second way is through the automated systems of the website itself. Standard server logs and lightweight analytics may record the technical device data described above whenever any browser loads a page on pulesi.autos. This happens without you typing anything and is used to protect the site and to keep it running smoothly.

The third way is from a party who already works with you. A buyer may introduce us to a seller so that the relay can be opened, or a factory may recommend that we speak with its quality manager. In those cases we receive only the details the introducer chooses to share so that the first contact can be made, and we presume no wider access without your agreement.

4. How We Use the Information

Every piece of data we hold is used for a purpose connected to the liaison desk, and we are careful not to reach beyond that purpose. Your contact details let us answer a dispatch, send progress notes and ask a clarifying question as a deal develops. Commercial correspondence and briefs let us prepare a quotation request, compare offers and carry negotiation notes accurately between the buyer and the seller without distortion.

Audit and inspection records let us verify that a factory can actually deliver what a seller has offered, and let us give you an honest verdict based on evidence rather than on a colourful brochure. The financial gate information lets us structure a safe milestone release and to reconcile the ledger at the end of a deal. We may use a contact email to send a message about a security matter that affects an open engagement, or to ask whether you want to hear about a service that genuinely relates to your present sourcing work.

We do not sell your personal information and we do not rent it out. We do not build advertising profiles from your data and we do not share your details with unrelated third parties to enable them to market to you. If a purpose ever changes or expands, we will tell you before we apply that new use to the data we already hold.

5. The Legal Basis for Processing

Pulesi Group Limited carries the data of people across several regions, and so our processing rests on a set of recognised lawful grounds that hold across borders. Where a person lives in a region governed by the GDPR or a similar modern privacy regime, we rely on the ground known as legitimate interest for much of our routine work: running a liaison desk, replying to an enquiry and preparing the paperwork of a consignment are activities that a reasonable person expects a commercial house to perform.

Where you send us an enquiry and we respond by carrying out steps you requested before a contract exists, we rely on the ground that processing is necessary to act on your request. Where an actual engagement begins, we rely on the ground that processing is necessary to perform the contract into which we have entered with you or with your company. Where we ask your specific permission for a use that falls outside those grounds, such as optional marketing, we rely on your consent and we make it easy for you to withdraw that consent at any time.

6. Cookies and Tracking Technology

This website is designed to be honest about what it places on your device. Some standard websites use a long list of trackers; we prefer a much shorter shelf. We may use a limited number of functional cookies that help the site remember a basic preference you selected, and we may use a single lightweight analytics measurement that counts pages read in aggregate without singling out any individual.

We do not use third party advertising cookies and we do not use invasive cross site trackers that follow you from page to page across the wider internet. Where a browser offers a preference for reduced tracking, we respect the signals that browsers send. The first visit does not depend on your accepting a cookie in order to read the privacy or service pages; the text is always available to you without any permission being granted.

7. When We Share Information

Trade liaison is built on the controlled movement of information, and so sharing happens, but only in a deliberate way and only to the people who need the message. We share your commercial brief and your contact details with a seller or factory when you ask us to open a relay on your behalf. We share a factory verification outcome with you, and we may share your identity with a factory so that the factory knows who is verifying its floor.

We also rely on a small number of trusted service providers, such as the operator of the website hosting, the email service that carries your messages and the provider of the secure file workspace where engagement documents rest. Those providers receive only what they need to perform their specific role and are bound by contract not to use the data for their own purposes. We may disclose specific records where the law compels us to do so, such as a valid court order or a lawful request from a regulator, and we will generally tell you where we are permitted to do so.

8. International Transfers of Data

Our clients, factories and partners are spread across the world, and a single consignment can touch Hong Kong, a manufacturing region and a buyer country in one working week. Because of this we may store or process information in a country different from the one where you live. Where a data protection law attaches conditions to such a cross border transfer, we put safeguards in place to keep the level of protection stable.

Typically those safeguards are standard contractual clauses agreed with the party receiving the data, or a decision by the relevant authority that the destination country provides an adequate level of protection. We keep a record of the transfer safeguards we rely on and we review them as the regulatory picture changes. The aim is that your information does not weaken its protection simply because it crosses a line on the map.

9. How Long We Keep the Data

We do not keep information for a moment longer than the purpose needs, but we also respect the practical realities of trade. A consignment record may need to be available for the length of a warranty, for the time a customs authority can raise a query or for the years a buyer may need to reorder the same product. We balance those needs against the privacy of the people behind the data.

As a guide, contact details of a person who made an enquiry that never grew into an engagement are reviewed and removed within a few months if no further conversation happens. Engagement documents are kept for a sensible statutory and business window after the close of the deal, typically several years, and are then securely deleted or anonymised. Technical log data is kept on a short rolling window measured in weeks. When we delete data we do so in a way that it cannot be reconstructed.

10. How We Protect the Data

Privacy without security is only a promise, and so we back this notice with practical controls. Access to the workspace where engagement documents rest is limited to the members of the team who need it for their current work, each with an individual sign in. Connections that carry your messages to and from the site are protected so that the content travels in a restricted form rather than in open text across the wire.

Our staff follow a simple discipline borrowed from the relay room itself: a piece of information only moves when the route is clear and the endpoint is authorised. Files are held under steady access rules and are removed when their working life ends. No system can be called unhackable, and we respond to any suspected incident promptly, notifying affected people where the law requires it and being open about what happened and what we changed.

11. Your Rights Over Your Data

Depending on where you live, you hold a set of rights over the personal data that relates to you. You may ask for a copy of the information we hold about you, and you may ask us to correct a detail that is wrong or out of date. In many places you may ask us to delete your information where we no longer have a lawful reason to keep it, and you may ask us to limit or pause the way we process your data while a question is resolved.

Where our processing rests on consent you may withdraw that consent freely at any time, and the withdrawal will apply from the moment we receive it without affecting the lawfulness of work done before that moment. You may also ask that your data be moved in a portable format to another service where that is technically straightforward. We respond to every request without unreasonable delay and we never penalise you for choosing to make one. Some rights are limited by law; where we cannot grant a request we will explain the reason in writing.

12. Privacy for Children

This website and its liaison services are directed at adult commercial professionals who are responsible for sourcing and supply decisions. They are not directed at children, and they are not designed to appeal to children. We do not knowingly collect personal information from a child, and we have no reason to hold data belonging to anyone below the age required for lawful consent in their own region.

If you are a parent or a guardian and you believe that a child has supplied personal information to us through this website by mistake, please write to our data team using the details at the end of this notice. We will remove the information as quickly as we reasonably can and we will confirm the removal once it is done. Where a facility is legally required to verify age we keep that safeguard in the working routines of the desk as well.

13. Information Sent Through the Contact Form

When you use the contact form on this website you supply a name, an email address, a subject line and a message. That message may describe a buying intention, a sourcing request or a question about a past consignment. We treat the content of that form exactly as we treat an email: as a genuine communication from you, to be read by the appropriate member of the desk, answered and then filed under the retention rules above.

The form includes a mechanism that can open your own email client to send the note, which respects your choice of how the message travels. Whatever route your message takes, please do not put anything in the form that you would not be comfortable writing on a public postcard. A secure workspace is offered to you once an engagement begins, rather than asking you to trust large attachment files to an ordinary first form.

14. Links to Other Websites

From time to time the pages on this site, or the messages we send you, may point to a resource that lives on another website. That may be a public specification held by a standards body, a carrier tracking page or a factory presentation you asked us to review. When you follow such a link you leave the direct care of this site and enter the rules of that destination.

We are not responsible for the privacy practices of any third party website and we encourage you to read the privacy notice of any site before you decide to share information with it. A link from our desk is a convenience and a direction of travel, never a claim that the destination follows this same policy.

15. Changes to This Policy

Standards, laws and the shape of our services all change over time, and this policy may be revised to stay accurate. When we make a change that alters the way we use your data in a material sense, we will take reasonable steps to bring the revision to your notice, including posting an updated date at the top of this page and, where an engagement is open, telling you directly through the channel we already use.

The version of this policy that applies is the one displayed at the time you use the service. We encourage you to glance at the effective date shown at the top of the page whenever you return, so that you always know which edition is in force. Material changes will not be applied to data we already hold in a way that harms you without a lawful basis for that application.

16. How to Contact Our Data Team

If you have a question about this policy, want to exercise any of the rights described above, or believe that your information has been handled in a way that falls short of this notice, please write to us. Every message is read by a human member of the team and answered without unnecessary delay.

The data controller for the purposes of this policy is Pulesi Group Limited, whose registered office is at Rm 1805-06 18/F Hollywood Plaza, 610 Nathan Road, Mong Kok, Hong Kong (HK). You may reach us by post at that address, by telephone on +12793210936 or by email at liaison@pulesi.autos. If you remain concerned after we have replied, you may also have a right to raise a complaint with your local data protection authority. We would value the chance to put matters right with you first, and we will do our best to do so.