Privacy policy

1. Scope of this policy

This privacy policy describes how Marshall Relay Limited (referred to in this document as "Marshall Relay", "the company", "we", "our", or "us") handles personal information that we receive through our corporate website at marshallbe.online and through direct correspondence with the company.

This policy applies only to the corporate website and to communications addressed to the company. It does not apply to any of our consumer software products. Each of our products has its own product-specific privacy policy, which is presented to end users in the relevant app store listing and within the application itself.

2. Data controller

For the purposes of applicable data protection laws, the data controller is:

Marshall Relay Limited
A private company limited by shares incorporated in the Hong Kong Special Administrative Region
Company number: 80211853
Registered office: Unit 2904–05, 29/F, Universal Trade Centre, 3 Arbuthnot Road, Central, Hong Kong
Contact: [email protected]

3. Information we collect

We collect a limited amount of information through this website, falling into the following categories:

Information you provide directly

• Contact information. When you write to us at any of our published email addresses, we receive the email address you write from, your name (if you choose to provide it), and the contents of your message.

Information collected automatically

• Technical and usage information. When you visit our website, we and our analytics provider may collect standard log information such as your IP address, browser type and version, operating system, referring URL, pages viewed, and the date and time of your visit.
• Cookies and similar technologies. See section 7 below.

We do not knowingly collect any special categories of personal data (for example, data revealing racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) through this website.

4. How we use information

We use the information described above for the following purposes:

• To respond to enquiries and provide the information you have requested;
• To operate, maintain, and improve our website;
• To understand how visitors use our website in aggregate;
• To detect, prevent, and respond to security incidents, fraud, and other unlawful activity;
• To comply with legal, regulatory, and accounting obligations applicable to the company.

We do not use information collected through this website for advertising, profiling, or automated decision-making.

5. Legal basis for processing

Where the General Data Protection Regulation (GDPR) or the United Kingdom GDPR applies, we rely on the following legal bases:

• Legitimate interests — for the operation, security, and improvement of our website, and to respond to your communications;
• Consent — for any non-essential cookies and analytics, where required by applicable law;
• Legal obligation — where we are required by law to retain or disclose information.

6. Sharing with third parties

We do not sell, rent, or trade personal information. We share information only with the following limited categories of recipients, and only to the extent necessary:

• Service providers. Reputable commercial vendors who provide hosting, analytics, email delivery, and similar infrastructure to support the operation of this website. These providers act on our instructions under written terms.
• Professional advisers. Our corporate secretary, accountants, auditors, and legal counsel, where this is necessary for the lawful operation of the company.
• Authorities. Government authorities, regulators, courts, and law enforcement, where we are legally required to disclose information, or where disclosure is necessary to protect our rights or the safety of others.

We do not transfer personal information to any third party for its own marketing purposes.

7. Cookies and analytics

This website uses a small number of cookies and similar technologies. We use them only for the following purposes:

• Strictly necessary cookies required for the website to function correctly;
• Analytics cookies, used to understand how visitors find and use our website. We currently use Google Analytics, a service provided by Google LLC, configured with IP anonymisation where supported.

You can control cookies through your browser settings. Disabling cookies may affect the functionality of certain parts of the website. You can learn more about Google Analytics and your choices at policies.google.com/privacy.

8. Data retention

We retain personal information only for as long as is necessary for the purposes set out in this policy, or for longer where we are required to do so by applicable law (for example, for tax, accounting, or audit purposes).

• Email correspondence: retained for the duration of the relationship and for a reasonable period thereafter, generally not exceeding seven years;
• Server logs: retained for a limited period for security and operational purposes, then deleted or anonymised;
• Analytics data: retained in accordance with the configuration of our analytics provider.

9. International data transfers

Marshall Relay Limited is established in Hong Kong. Some of our service providers (including hosting and analytics providers) may process information in other jurisdictions, including the United States and the European Economic Area. Where required, we put in place appropriate safeguards (such as standard contractual clauses) for international transfers of personal data.

10. Your rights

Subject to applicable law and to verification of your identity, you may have the following rights with respect to your personal information:

• The right to access the personal information we hold about you;
• The right to request correction of inaccurate or incomplete information;
• The right to request deletion of your personal information, subject to legal exceptions;
• The right to object to, or request restriction of, certain processing;
• The right to data portability, where applicable;
• The right to withdraw consent, where processing is based on consent;
• The right to lodge a complaint with a competent data protection authority.

To exercise any of these rights, please contact us using the details in section 14.

11. Security

We implement reasonable technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security; however, we work to ensure that our practices reflect generally accepted industry standards.

12. Children's privacy

Our website is intended for a general adult audience. We do not knowingly collect personal information from children under the age of 13 (or the equivalent minimum age in your jurisdiction). If you believe that a child has provided us with personal information, please contact us so that we can take appropriate steps.

13. Changes to this policy

We may update this policy from time to time to reflect changes in our practices, our service providers, or applicable law. The "effective" and "last updated" dates at the top of this page indicate when this policy was last revised. Where changes are material, we will provide additional notice on the website prior to the changes taking effect.

14. Contact us