Privacy Policy

Effective date: 3 September 2026

This Privacy Policy explains how TraffHub, the operator of traffhub.io (“TraffHub”, “we”, “us” or “our”), collects, holds, processes, uses and discloses personal data through traffhub.io, related forms, referral channels, chats, messengers and other communications (collectively, the “Website”). It is intended to reflect the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and the Data Protection Principles (“DPPs”).

1. Who controls your personal data

For the purposes of the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (the “PDPO”), TraffHub is the data user in relation to personal data that it controls through the Website and its related communication channels.

You may contact TraffHub using the contact details and communication channels published on the Website. Privacy-related requests should clearly state that they concern personal data access, correction or another privacy matter.

2. Scope of this Policy

This Policy applies to Website visitors, persons who contact us, persons who submit details for a potential B2B/independent contractor engagement, referrers, persons referred to us, representatives of suppliers or business partners, and persons communicating with us through Telegram, social media or other channels linked from the Website.

This Website is not intended for persons under 18. We do not knowingly solicit personal data from children.

3. Personal data we may collect

Identity and contact data: name, surname, email address, telephone number, Telegram username or other messenger details.
Professional and contractor-profile data: CV/resume, portfolio, skills, work history, experience, GEOs, media-buying budgets, performance metrics, availability, preferred cooperation format and other information you choose to submit.
Business data: company or sole-trader details, professional contact details, tax or invoicing data if required for a B2B relationship.
Referral data: referrer identity and contact details, referred person’s name/contact details, relationship to the referrer, referral status and information necessary to determine or pay a referral reward.
Communications data: emails, chat messages, Telegram/social-media communications, interview or call notes, support enquiries and feedback.
Technical and usage data: IP address, device and browser information, language, approximate location derived from IP, pages viewed, timestamps, referring pages, cookie identifiers and security logs.
Compliance and verification data where reasonably required before entering into or performing a B2B relationship, including identification or payment verification information. Please do not provide ID documents or sensitive information unless we specifically request it through an appropriate channel.

Please do not include unnecessary sensitive information in your CV or messages, such as medical details, political or religious views, biometric data, criminal history or other highly sensitive data unless it is strictly necessary and specifically requested by us.

4. How we collect personal data

directly from you through Website forms, email, chat, Telegram, social networks, calls or meetings;
from a referrer who provides your details in connection with the TraffHub referral program;
from publicly available professional sources or business profiles where reasonably relevant to a potential B2B engagement;
automatically through Website logs, cookies and similar technologies;
from service providers or business partners where permitted by law and consistent with the purpose for which the data was originally collected.

5. Why we use personal data

to respond to enquiries and communicate with you;
to assess whether there may be a suitable independent contractor, freelancer or other B2B cooperation opportunity;
to organise calls, interviews, skills assessments and onboarding steps for a potential B2B relationship;
to administer referrals, verify eligibility for referral rewards and make related payments;
to prepare, negotiate, enter into and administer B2B agreements, statements of work, invoices and payments;
to operate, secure, troubleshoot, improve and measure the Website and its communications channels;
to prevent fraud, abuse, security incidents and unlawful activity;
to establish, exercise or defend legal rights and comply with legal, tax, accounting or regulatory obligations;
to send marketing or promotional communications only where the applicable direct-marketing requirements have been satisfied and you have not opted out.

6. Independent contractor / B2B opportunity data

TraffHub does not use the Website to offer employment in Hong Kong. Website opportunities are intended for independent contractor / freelancer cooperation on a B2B basis.

Words such as “vacancy”, “career”, “full-time”, “permanent”, “team member” or “probation” appearing on the Website are descriptive labels only. They do not create an employment relationship, entitlement to employee benefits, payroll status, statutory employment rights, or any promise of engagement.

Submitting a form or completing an interview does not create a contract. Any engagement becomes binding only when the relevant parties execute a separate written B2B or independent contractor agreement and any stated onboarding conditions are completed.

7. Referral data and information about other persons

If you submit another person’s contact details under the referral program, you must have a reasonable basis to believe that the person is open to being contacted by TraffHub and you should inform them that you are sharing their details with us. Do not submit sensitive or excessive information about another person.

When we first contact a referred person, we may explain how we obtained their details and provide or link to the relevant privacy information. We may record referral status and reward eligibility to administer the program and prevent duplicate or fraudulent claims.

8. Cookies and online tracking

We may use strictly necessary, preference, analytics/performance and advertising/measurement cookies or similar technologies. Some identifiers may constitute personal data where they can reasonably be linked to an identifiable individual.

Details are set out in Cookie Policy. Where non-essential cookies collect personal data or track behaviour, we provide appropriate notice and, where required, a choice to accept or reject them.

9. Direct marketing

We will not use personal data for direct marketing in a manner that requires consent under the PDPO unless the required notice has been provided and the required consent or indication of no objection has been obtained. Silence alone is not treated as consent.

You may ask us at any time to stop using your personal data for direct marketing. We will honour valid opt-out requests and may retain a suppression record so that we do not contact you again for that purpose.

10. Who may receive personal data

our personnel and authorised contractors who need the information for the purposes described in this Policy;
cloud hosting, website development, cybersecurity, analytics, CRM, email, messaging, communications, file-storage, recruitment/workflow and other technology service providers;
payment providers, accountants, auditors, tax advisers and banks in connection with B2B payments or referral rewards;
professional advisers, insurers, investigators and dispute-resolution providers;
public authorities, regulators, law-enforcement bodies or courts where disclosure is required or permitted by law;
an actual or proposed purchaser, investor, financing party, successor or group company in connection with a corporate transaction, subject to appropriate confidentiality and data-protection measures.

We do not sell personal data as a standalone commercial product.

11. Transfers and processing outside Hong Kong

Because TraffHub operates internationally and uses third-party technology, personal data may be accessed, hosted or processed outside Hong Kong, including in countries where our teams, contractors or service providers operate. We take practicable steps to use appropriate contractual, organisational and technical safeguards designed to maintain protection consistent with the PDPO and the purposes disclosed in this Policy.

12. Retention

We keep personal data only for as long as reasonably necessary for the purpose for which it was collected, subject to legal, accounting, dispute and security needs.

Potential B2B contractor profiles and related selection records: normally up to 24 months after the last material interaction or decision, unless a longer period is agreed or reasonably required.
Referral contact and status data: normally up to 24 months for referral administration; payment, invoice and accounting records relating to a paid reward may be kept for at least 7 years where required for Hong Kong business/tax record keeping.
General enquiries and chat records: normally up to 24 months after the last interaction, unless needed for an ongoing relationship, dispute or security purpose.
Website security and technical logs: generally up to 12 months unless a longer period is necessary to investigate abuse or an incident.
Marketing consent and opt-out records: for as long as reasonably necessary to evidence and respect your preferences.

We may anonymise information so that it can no longer reasonably identify you, in which case we may retain and use the anonymised information for analytics and business improvement.

13. Security

We take practicable steps designed to protect personal data against unauthorised or accidental access, processing, erasure, loss or use. Measures may include role-based access, authentication controls, encryption where appropriate, logging, backups, confidentiality obligations, security review and contractual controls over service providers.

No internet transmission or storage system is completely secure. You should use reasonable care when sending information to us and should not send passwords, payment credentials or sensitive personal data through ordinary chat unless specifically requested through a secure process.

14. AI-assisted and automated tools

TraffHub may use automated or AI-assisted tools to support administrative tasks, organise information, summarise communications, assist analytics, detect abuse, or draft responses. Such tools may process information you provide to the extent necessary for those purposes and subject to appropriate access and confidentiality controls.

Unless separately disclosed, we do not intend to make decisions with legal or similarly significant effects on an individual solely by automated means. Important B2B engagement decisions are intended to involve human review.

15. Your rights and choices

Access: you may request confirmation of whether we hold your personal data and request a copy in accordance with the PDPO.
Correction: you may request correction of personal data that is inaccurate.
Marketing opt-out: you may withdraw or change your direct-marketing preference at any time.
Deletion request: you may ask us to delete information that is no longer needed. We will consider the request subject to the PDPO and any legal or legitimate retention requirement.
Cookie choices: you may manage non-essential cookies through the available cookie settings and/or your browser settings.

A valid data access request under the PDPO is generally handled within the statutory timeframe. We may request information reasonably necessary to verify identity and may charge a non-excessive fee where permitted by law.

16. Third-party sites and social platforms

The Website may link to Telegram, Instagram, LinkedIn, advertising platforms or other third-party services. Those services are controlled by their own operators and their privacy practices apply independently. We are not responsible for the privacy or security practices of third-party services that we do not control.

17. Changes to this Policy

We may update this Policy to reflect changes in law, technology or our practices. The latest version will be posted on the Website with an updated effective date. Material changes may be highlighted through the Website or another appropriate channel.

18. Contact and complaints

For privacy questions, access/correction requests or complaints, contact TraffHub using the contact details published on the Website and identify the request as a privacy or personal-data matter.

You may also contact the Office of the Privacy Commissioner for Personal Data, Hong Kong if you believe your rights under the PDPO have been infringed.

19. Mandatory local law

This Policy is drafted primarily under Hong Kong law. If mandatory data-protection law in another jurisdiction applies to a particular processing activity, nothing in this Policy is intended to waive rights or obligations that cannot lawfully be excluded.