TKEM Trade Limited

Privacy Policy

Last updated: 30 October 2026

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Contents

  1. Introduction and Who We Are
  2. Scope of This Policy
  3. Information We Collect
  4. Where Information Comes From
  5. How We Use Information
  6. Lawful Bases for Processing
  7. Consignment and Counter Records
  8. Voyage and Handover Information
  9. Sharing With Others
  10. Service Providers and Processors
  11. International Transfers
  12. How Long We Keep Information
  13. How We Protect Information
  14. Your Rights and Choices
  15. Newsletters and Counter Notes
  16. Cookies and Local Storage
  17. Privacy for Children
  18. Changes to This Policy
  19. Contacting the House

Introduction and Who We Are

This Privacy Policy explains how TKEM Trade Limited collects, uses, stores and shares information about the people who work with our trading house. This policy was written and is maintained by TKEM Trade, the developer name used on this website, and that same team keeps the counter pages and the published records of the house. Where this policy says the house, the Company or we, it means TKEM Trade Limited, a company registered in Hong Kong with its trading counter at Rm 1-3 20/F STRAND 50, 50 BONHAM STRAND, Hong Kong (HK).

The house keeps harbour consignment schedules, counter trade ledgers, junk voyage plans, wharf audit records, balance review pages and sampan handover slips. Each of those records can contain details about a client, a boat keeper, a carrier, a receiving party or a visitor who has written to the counter. We treat those details with the same care that a clerk gives a written line at the steelyard: we read them, we write them plainly and we keep them only as long as the record needs them.

We wrote this policy in plain English so that a client can understand it without legal training. If any part of the policy is unclear, the clerk at the counter will explain it in person or by email. You can reach the house at scheduling@tkem-trade.com or on +19289627365, and you can write to Rm 1-3 20/F STRAND 50, 50 BONHAM STRAND, Hong Kong (HK).

In short: the house collects the information it needs to run its desks, keeps it in secure hands, shares it only with people who help us run the desks and with parties you have asked us to involve, and deletes it when the counter no longer needs it.

Scope of This Policy

This policy covers information collected through the website at tkem-trade.com, through the contact form on the contact desk page, through email and telephone conversations with the counter, and through the paper and electronic records that the six desks keep in the ordinary course of trade. It applies to clients, prospective clients, boat keepers, carriers, receiving parties, auditors, visitors to the counter and anyone else who writes to the house.

The policy does not cover information that a third party collects on its own account, such as a bank that holds an account for a client or a carrier that runs its own booking system. When the house shares information with such a party, that party applies its own privacy rules, and the house cannot promise how those rules will read. We encourage clients to read the privacy notices of any bank, carrier or courier they use alongside the house.

Where a client uses our pages to reach another business, the policy of that business will govern the information it collects. The counter pages at this website belong to the house alone, and the policy you are reading governs the information that the house itself collects and controls.

Information We Collect

The house collects only what a working counter needs. The main categories are set out below, and each category is tied to a desk that uses it. We do not collect information that the house cannot link to a desk and a purpose, and we do not gather extra details simply because a form makes it easy to ask.

Identity and contact details

We collect your name, the name of your organisation, your email address, your telephone number and, where a consignment needs a delivery point, a receiving address. We may also keep a note of the language you prefer for counter notes and the hours when a clerk can reach you by telephone.

Trade and consignment details

For a consignment we record the marks on the crates, the tonnage, the berth, the arrival notice, the bill of lading reference, the receiving party and the hour by which the load must move. These details are collected so that the Consignment Desk can draft a schedule that matches the documents you have signed.

Counter trade ledger details

The Counter Trade Rounds desk records the entries read during a round, the bench where each entry sat, the day before comparison and any correction agreed during the round. A ledger entry can include a client name and a cargo reference, so it is treated as client information even though it reads like an internal note.

Voyage and handover details

The Junk Voyage Weeks desk keeps the voyage book for each boat, which includes the cargo carried, the hours on the water and any repairs noted by the boat keeper. The Sampan Handover Evenings desk keeps a slip for each handover that lists the parcels passed, the boat, the receiving party and the hour the lantern was dimmed.

Audit and review details

Wharf Audit Days produce a summary that lists the dockets read, the cargo matched, the cargo held and the dockets that need a second read. A Balance Review Session produces a signed closing page and a note of any open point. Both documents are kept with the counter record because they show how a figure was settled.

Correspondence and communications

We keep the notes, emails, telephone messages and meeting summaries that pass between you and the counter. A short note that records what was agreed is often more useful than a long message, so the house tends to keep a brief written line and the time it was agreed.

Technical information

When you visit the website, our hosting provider records limited technical information such as the pages viewed, the time of the visit and the general region from which the request came. We use this information to keep the counter pages working and to understand which pages a visitor reads first. We do not use technical information to build a profile of a visitor, and we do not sell it.

Payment and billing details

Where a desk issues an invoice, we keep the billing name, the billing address, the invoice number and the payment status. The house does not store full card numbers on its own systems, and card payments are handled by a payment provider that applies its own security standards.

Where Information Comes From

Most of the information we hold comes directly from you: through the contact form, by email, on the telephone or at the counter. Some information comes from the documents you hand to a clerk, such as an arrival notice, a bill of lading or a signed written order. Some information comes from parties you have asked us to speak with, such as a carrier, a customs agent or a receiving party at the far end of a voyage.

A small amount of information comes from the equipment that serves the website. Our hosting provider logs the pages requested and the time of each request, and those logs help us find a broken page or a slow hour. We do not add information from unrelated sources, and we do not buy contact lists to add to the counter record.

Where a client gives us information about another person, for example the name of a receiving party, the client confirms that the other person knows the information has been passed to the house for the purpose of the consignment. The house records the client as the source of that information so that a question about it can always be traced back.

How We Use Information

The house uses information to run its six desks, to answer a client, to keep a written record and to satisfy the law. The main uses are set out below, and each use is tied to the desk that needs it. We do not use client information for a purpose that a client would not expect from a trading house.

  • To draft a consignment schedule, weigh it against the written order and send it to the client for agreement.
  • To carry counter trade rounds, read the ledger aloud and correct any line that does not balance.
  • To plan a junk voyage week, set the crew rota and record the return tally.
  • To run a wharf audit day, match the dockets against the quay record and issue a written summary.
  • To hold a balance review session and keep the signed closing page.
  • To record a sampan handover evening and file the slip with the balance page.
  • To answer a note sent through the contact form, by email or on the telephone.
  • To issue invoices, record payment status and keep accounting records.
  • To keep the website working, understand which pages are read and improve the counter pages.
  • To meet a legal, tax or regulatory duty that applies to a Hong Kong trading house.

We also use information to protect the house and its clients, for example to check that a cargo matches the documents that accompany it and to prevent a fraudulent handover at the jetty. This use is limited to what a reasonable clerk would check before releasing a load.

Lawful Bases for Processing

Where the law requires a lawful basis for processing, the house relies on one of the bases set out below. The basis depends on the desk and the purpose, and a single record can rest on more than one basis at different points in its life.

Performance of a contract

Most of the information a desk holds is needed to perform the trade that a client has asked the house to carry out. A consignment schedule, a voyage week or a balance review cannot be completed without the names, the cargo details and the receiving party.

Legitimate interests

The house has a legitimate interest in running its desks safely, in keeping accurate records and in answering clients promptly. Where we rely on this basis, we weigh the interest against the rights of the person concerned and we limit the use to what the interest really needs.

Legal obligation

Some records must be kept because Hong Kong law, tax rules or accounting standards require it. When we keep a record for this reason, we keep only the part the law requires and we delete it when the required period ends.

Consent

Where the house sends a counter note or a newsletter, we ask for consent first and we make it simple to withdraw. Consent is never bundled into a consignment contract, and a client can trade with the house without receiving any marketing message.

Consignment and Counter Records

The Consignment Desk keeps a schedule for every consignment, and that schedule is the central record for the work that follows. The schedule names the client, the cargo, the berth and the receiving party, and it is written twice so that the owner and the carrier read the same figure. The house keeps the schedule with the arrival notice and the written order so that a later question can be answered from the same set of papers.

Counter Trade Rounds produce a closing note for each round. The note names the day, the bench and the number of entries read, and it records any correction that was agreed. The closing note is kept because it shows how the ledger was checked, and it is useful when a client asks why a figure changed between one day and the next.

A client can ask for a copy of the schedule or the closing note that relates to their consignment. The clerk will provide a copy by email or at the counter after confirming that the person asking is the client or an authorised representative. Copies are not released to a third party without the client written agreement, unless the law requires the house to release them.

Voyage and Handover Information

The Junk Voyage Weeks desk keeps a voyage book for each boat in the fleet. The book records the cargo carried, the hours on the water and any repairs noted by the boat keeper. Because a voyage book follows a boat over many weeks, it can show a pattern of trade, and the house treats the book as confidential business information as well as a record of client details.

A sampan handover evening produces a slip that lists the parcels passed, the boat, the receiving party and the hour the lantern was dimmed. The slip is filed with the balance review page so that the whole day reads as one thread from arrival to water. Where a handover involves a receiving party who has not dealt with the house before, the house collects only the details needed to make the handover and to confirm receipt.

Boat keepers and crew who work with the house are told what the voyage book contains and who can read it. The house does not share a voyage book with a third party except where the third party is helping to run the voyage, such as a repair yard or a provisioning agent, and then only the pages that the third party needs.

Sharing With Others

The house shares information only when a desk needs help to finish its work, when you have asked us to involve another party, or when the law requires it. The categories of recipient are set out below. We do not sell client information to anyone, and we do not trade it for advertising.

  • Carriers, boat keepers and crew who carry a consignment or a voyage on behalf of the house.
  • Receiving parties at the far end of a consignment, where a handover requires their name and address.
  • Customs agents and port authorities, where a clearance or a quay record requires the details.
  • Auditors and accountants who check the counter record on behalf of the house.
  • Banks and payment providers that process an invoice or a card payment.
  • Technology providers that host the website, deliver email or keep the counter pages working.
  • Professional advisers, such as a lawyer, where the house needs advice on a specific matter.
  • A public authority, where a valid legal request or a court order requires disclosure.

When the house shares information with a carrier or a receiving party, it shares only the part that the handover needs. A carrier does not need to see a full balance review page, and a receiving party does not need to see a voyage book. The clerk shares the smallest useful part and records what was shared and why.

Service Providers and Processors

The house uses a small number of service providers to run the counter pages and to keep its records in order. Each provider acts on the written instructions of the house, and each provider is bound by a contract that requires it to protect the information it handles and to use it only for the service it supplies.

Our website hosting provider keeps the pages online and records limited technical logs. Our email provider delivers and stores the notes that pass between the counter and a client. Our accounting provider keeps the invoice record that the law requires. Where a provider is replaced, the house checks that the new provider offers the same protection before information is moved, and it deletes the information from the old provider when the move is complete.

The house does not allow a provider to use client information for its own marketing. If a provider needs to use a sample of information to fix a fault, the house asks for the sample to be as small as possible and for it to be deleted once the fault is fixed.

International Transfers

The house keeps its counter at Rm 1-3 20/F STRAND 50, 50 BONHAM STRAND, Hong Kong (HK), but a consignment or a voyage can involve a party in another region. When information has to move across a border, the house takes steps to keep the same protection in place that it would apply at the counter.

Where the receiving region has privacy rules that the house considers adequate, the house may rely on those rules. Where the rules are different, the house uses a written contract or another approved safeguard so that the receiving party is bound to protect the information. The house does not send client information to a region simply because it is cheaper to store it there.

A client can ask the clerk for a summary of the safeguards used for a particular transfer. The summary is written in plain English and names the region and the kind of safeguard that applies, without disclosing a contract that the house is not free to share.

How Long We Keep Information

The house keeps a record only as long as a desk needs it. The periods below are the ordinary rules, and a clerk may keep a record longer where a dispute, an audit or a legal duty requires it. When a period ends, the record is deleted or destroyed in a way that prevents it from being read again.

  • Consignment schedules and closing notes: kept for the accounting period that the law requires, then deleted.
  • Counter trade round notes: kept for the current trading year and the following year.
  • Voyage books: kept for the life of the boat and for a further period set by the house insurance terms.
  • Handover slips and balance review pages: kept with the consignment record for the same accounting period.
  • Contact form notes and emails: kept for as long as the enquiry is live and for a short period afterwards.
  • Technical logs from the website: kept for a short period, usually no more than a few months, and then deleted.
  • Invoice and payment records: kept for the period required by Hong Kong tax law.

Where a client asks the house to delete information that it is not required to keep, the house will delete it and confirm the deletion in writing. Where the house must keep a record for a legal reason, the clerk will explain the reason and the date on which the record will be deleted.

How We Protect Information

The house protects information with a mix of written rules, limited access and careful habits at the counter. A clerk can read the records that a desk needs and no more, and access to the full counter record is limited to the people who run the house. Passwords are long and are changed on a regular schedule, and a device that holds counter records is locked when it is not in use.

Paper records are kept in a locked cabinet at Strand 50, and a record that leaves the cabinet is signed out and signed back in. Electronic records are kept on systems that are protected by encryption in transit and at rest, and a backup is kept so that a record can be restored if a device fails. The house tests its backup from time to time so that it knows the restore will work when it is needed.

No system is perfect, and the house cannot promise that a breach will never happen. If a breach occurs that is likely to affect a client, the house will tell the affected clients without undue delay and will tell the regulator where the law requires it. The notice will describe what happened, what the house has done and what a client can do to reduce the risk.

Your Rights and Choices

You have rights over the information the house holds about you. The house honours those rights for every client and for every person who writes to the counter. The main rights are set out below, and a request can be made by email to scheduling@tkem-trade.com, by telephone on +19289627365 or in person at the counter.

  • Access: you can ask for a copy of the information the house holds about you and for an explanation of how it is used.
  • Correction: you can ask the house to correct a detail that is wrong or out of date.
  • Deletion: you can ask the house to delete information that it is not required to keep.
  • Restriction: you can ask the house to limit how it uses your information while a question is being resolved.
  • Objection: you can object to a use that rests on the legitimate interests of the house.
  • Portability: you can ask for the information you gave to the house in a common electronic format.
  • Withdrawal of consent: where a use rests on consent, you can withdraw it at any time.

The clerk will confirm a request within a short period and will answer it within the time the law allows. The house may ask for proof of identity before releasing a record, so that a record is not handed to the wrong person. A request that is clearly unfounded or excessive may be refused, and the clerk will explain the reason.

Newsletters and Counter Notes

From time to time the house sends a short counter note that describes the wharf audit window, an upcoming voyage week or a change to the business hours. These notes are sent only to clients who have asked for them, and every note carries a simple way to stop receiving them.

The house does not buy a mailing list and does not add a client to a marketing list because that client has traded with the house. A client who wants to receive counter notes can ask the clerk, and a client who wants to stop can reply to any note with a short request to stop. The house will honour the request before the next note is sent.

Marketing messages never carry a confidential counter record. A counter note describes the house in general terms and never names a client, a cargo or a balance without the written agreement of the client concerned.

Cookies and Local Storage

The counter pages use only a small amount of local storage. The mobile berth planks menu remembers whether it is open during a visit, and the pages may remember a preference such as a reading size. These details are kept on your own device and are not sent to the house as a profile.

Our hosting provider may set a technical cookie that helps the server deliver a page and keep the service secure. That cookie does not identify you to the house, and it is not used for advertising. The house does not use advertising cookies, tracking pixels or cross-site profiling.

You can clear local storage and cookies through the settings of your browser. Clearing them will not stop you from reading the counter pages, and it will only reset a small preference such as whether the mobile menu was open. A browser that blocks all cookies can still read every page.

Privacy for Children

The counter pages are written for adults who trade, ship or work at a wharf. The house does not knowingly collect information from a child, and it does not direct a counter note to a child. Where a child appears on a voyage record as a crew family member, the house keeps only the detail that the voyage needs and deletes it when the voyage closes.

If a parent or guardian believes that a child has sent information to the house, the parent or guardian can contact the counter and the clerk will delete the information unless the house is required to keep it. The house will confirm the deletion in writing once it is done.

Changes to This Policy

The house reviews this policy from time to time and updates it when a desk changes, when a new service provider is added or when the law changes. The date at the top of the page shows when the current version was published, and a material change will be described in a short note at the top of the policy for a period after it takes effect.

Where a change affects how the house uses information that it already holds, the house will tell the affected clients before the new use begins and will give them a chance to object. A client who does not agree with a new use can ask the house to stop using the information for that purpose, and the clerk will record the request.

The current version of the policy is always the one published on this page. A printed copy can be requested at the counter, and the clerk will provide one without charge.

Contacting the House

If you have a question about this policy, a request about your information or a concern about how the house has handled a record, please write to the counter. The house answers every privacy request in plain English and records the request so that it can be followed up if it is not answered in time.

TKEM Trade Limited
Rm 1-3 20/F STRAND 50, 50 BONHAM STRAND, Hong Kong (HK)

Email: scheduling@tkem-trade.com
Phone: +19289627365

If you are not satisfied with the answer the house provides, you can ask for the matter to be reviewed by the person who runs the counter. You can also complain to the privacy regulator in Hong Kong. The house will cooperate with a regulator that investigates a complaint about the counter record.

This policy is published by TKEM Trade, the developer name used on this website, on behalf of TKEM Trade Limited. The house keeps the wharf wet, the beam level and the junk sailing, and it keeps client information in the same careful hands.

TKEM Trade Limited — Rm 1-3 20/F STRAND 50, 50 BONHAM STRAND, Hong Kong (HK)

Email scheduling@tkem-trade.com · Phone +19289627365

© 2026 TKEM Trade Limited. All rights reserved.

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