Privacy Policy for Manuloop

Manuloop ("we", "us", or "our") operates the website www.manuloop.com (the "Website"). This Privacy Policy explains what personal data we collect, why we collect it, the legal basis for processing it, how long we keep it, and the rights you have over it. It is written to comply with the EU General Data Protection Regulation (GDPR) and applicable data protection law.

By using the Website, you acknowledge that you have read this Privacy Policy.

1. Data controller

The data controller responsible for your personal data is:

TSA Partners Limited - Unit 2904-05, 29/F, Universal Trade Centre, No. 3 Arbuthnot Road, Central, Hong Kong

Contact: contact@manuloop.com

If you have any questions about this policy or how we handle your data, contact us at contact@manuloop.com.

2. What data we collect

We only collect data that is relevant to a business-to-business advisory and sourcing service. Specifically:

Data you provide directly (e.g. via our contact form or by emailing us):

• First and last name
• Business email address
• Company name
• Telephone number (if you provide it)
• The content of any message you send us

Data collected automatically when you browse the Website:

• IP address
• Browser type and version
• Pages visited, date and time of visit, and time spent on pages
• Approximate geographic location (derived from IP)
• Referral source

Automatically collected data is gathered through cookies and analytics tools (see Section 6).

We do not collect payment card data, precise geolocation, or any special-category data through this Website.

3. Why we process your data and our legal basis

Under the GDPR, we must have a lawful basis for each processing activity:

PurposeLegal basisResponding to enquiries you send us (contact form, email)Performance of a contract / steps prior to entering a contract (Art. 6(1)(b)), or our legitimate interest in answering business enquiries (Art. 6(1)(f))Sending you commercial communications or a newsletterYour consent (Art. 6(1)(a)), which you can withdraw at any timeMeasuring and improving Website performance (analytics)Your consent, given through our cookie banner (Art. 6(1)(a))Ensuring the security and proper functioning of the WebsiteOur legitimate interest (Art. 6(1)(f))Complying with legal obligationsCompliance with a legal obligation (Art. 6(1)(c))

You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

4. How long we keep your data

We retain personal data only as long as necessary for the purpose for which it was collected:

• Enquiry and contact data: kept for the duration of our exchange and up to 3 years after the last contact, in line with commercial prospecting practice.
• Newsletter / marketing data: kept until you unsubscribe, and then removed within a reasonable period.
• Analytics / usage data: retained for a limited period as configured in our analytics tool, then aggregated or deleted.

Data may be kept longer where required to comply with a legal obligation or to establish, exercise or defend legal claims.

5. International data transfers

We operate as a sourcing advisor between Asia (primarily China and Vietnam) and Western markets (Europe, the Americas). As a result, your personal data may be transferred to, stored in, or accessed from countries outside the European Economic Area (EEA), including countries that have not been recognised by the European Commission as providing an adequate level of data protection.

Where such transfers occur, we put appropriate safeguards in place, including the European Commission's Standard Contractual Clauses (SCCs), to ensure your data receives a level of protection consistent with this policy and with the GDPR. You may request more information about these safeguards by contacting us at contact@manuloop.com.

6. Cookies and analytics

We use cookies and similar technologies to operate the Website, remember your preferences, and understand how the Website is used. When you first visit, our consent banner lets you accept or refuse non-essential cookies. You can change your choice at any time via the cookie settings link on the Website.

Types of cookies we use:

• Functional cookies: strictly necessary for the Website to operate.
• Statistics cookies: used only with your consent, to measure Website usage.

Third-party services that may set cookies or process data:

Google Analytics — a web analytics service provided by Google. It helps us understand how visitors use the Website. Analytics cookies are only loaded after you consent. IP addresses are anonymized. You can learn more at Google's privacy policy: https://policies.google.com/privacy. You can also install the Google Analytics Opt-out Browser Add-on.

LinkedIn — our Website displays LinkedIn content or share functionality. Interacting with it may allow LinkedIn to set cookies. Your interactions are governed by LinkedIn's own privacy policy: https://www.linkedin.com/legal/privacy-policy.

Hosting (Hostinger) — the Website is hosted by our hosting provider, which processes technical data (such as server logs) on our behalf as a data processor.

[If you later add tools such as HubSpot, a chat widget, or advertising pixels, add them here and update your cookie banner.]

7. Who we share data with

We do not sell your personal data. We may share it only with:

• Service providers (data processors) acting on our behalf — for example our hosting provider and analytics provider — who are bound to process data only on our instructions.

• Authorities or third parties where disclosure is required to comply with a legal obligation, protect our rights, prevent wrongdoing, or protect the safety of users.

8. Your rights

Subject to applicable law, you have the right to:

• Access the personal data we hold about you and receive a copy of it
• Rectify inaccurate or incomplete data
• Erase your data ("right to be forgotten")
• Restrict processing in certain circumstances
• Object to processing based on our legitimate interests, and to object to direct marketing at any time
• Data portability — receive the data you provided in a structured, commonly used, machine-readable format
• Withdraw consent at any time, where processing is based on consent
• Lodge a complaint with a data protection supervisory authority

To exercise any of these rights, contact us at contact@manuloop.com. We may ask you to verify your identity before responding. We will respond within the timeframe required by law (generally one month).

If you are located in the EU and believe we have not handled your data lawfully, you have the right to complain to your national data protection authority (in France, the Commission Nationale de l'Informatique et des Libertés — CNIL, www.cnil.fr).

9. Security

We use appropriate technical and organizational measures to protect your personal data against unauthorised access, alteration, disclosure or destruction, including encryption in transit (SSL/TLS). However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

10. Children's privacy

The Website is a business-to-business service and is not directed to children. We do not knowingly collect personal data from anyone under the age of 15. If you believe a child has provided us with personal data, please contact us and we will delete it.

11. Links to other sites

The Website may contain links to third-party sites we do not operate. We are not responsible for the content or privacy practices of those sites, and we encourage you to review their privacy policies.

12. Changes to this policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. Where changes are significant, we may notify you by email or a prominent notice on the Website. We encourage you to review this page periodically.

13. Contact

For any question regarding this Privacy Policy or your personal data:

• Email: contact@manuloop.com