Privacy Policy

This policy applies to all visitors to this website and describes how Havrion Capital, acting as the personal information handler, processes personal information collected in the course of operating the site; for background on the company itself, see Company Overview.

We collect three categories of information, each tied to the site's actual functions. The first is what is submitted voluntarily through the contact form — name, organization, email, inquiry category, subject and message — used to respond to a specific inquiry or application. The second is standard technical log data generated automatically on each visit: access time, page requested, referring page, general device and browser information, and processed network address data, used to keep the site running and secure.

The third is browser storage: a language preference kept in session storage, valid only for the current visit and cleared once it ends, with Chinese as the default on every new visit; and a cookie-preference record kept in local storage until changed or cleared. Both stay on the local device and are never uploaded — see the Cookie Policy. This site carries no advertising, sells no personal information, embeds no third-party trackers, and does not collect sensitive information such as health status, nor direct any collection at minors.

Personal information is processed under the Personal Information Protection Law of the People's Republic of China, relying principally on: necessity to respond to an inquiry or application the visitor initiated; necessity to keep the website running and secure; and, where applicable, the explicit consent given by submitting a form. Submitting the contact form is treated as consent to the processing described here. Where consent is the basis, it may be withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

We do not sell personal information or use it for any commercial purpose beyond what this policy describes. Sharing is limited to service providers that help operate the website or process form content, scoped to what is necessary and bound by confidentiality and security obligations, and to competent authorities where required by law or necessary to protect legitimate rights or respond to a security incident. Outside these circumstances, information is not provided to other third parties.

Contact-form information is kept only until the relevant inquiry or application is resolved, plus a reasonable compliance period, then deleted or anonymized; technical logs are retained for a standard operating cycle before being cleared. The language preference clears automatically once a visit ends; the cookie-preference record persists until changed or cleared. We apply measures proportionate to the information involved, including access controls, encryption in transit and monitoring for security events, to reasonably guard against disclosure, alteration or misuse — no technical measure guarantees absolute security, and these arrangements are reviewed on an ongoing basis.

This website is directed primarily at users within mainland China, and information is, as a rule, stored and processed there. Where a transfer outside China becomes necessary — for instance through a service provider with cross-border processing capability — it proceeds only after the compliance measures required under the Personal Information Protection Law for exporting personal information have been put in place.

This policy may be updated to reflect changes in our operations or in applicable law, with any updated version posted here noting its effective date. The current version took effect on 15 January 2026; we encourage periodic review of this page to stay informed of its current terms.