Introduction

Zenveris Limited ("we", "our", "us") is a company registered in Hong Kong. We act as the data user in respect of personal data processed in connection with our website and services.

We comply with the Personal Data (Privacy) Ordinance (Chapter 486 of the Laws of Hong Kong) ("PDPO") and observe the six Data Protection Principles set out in Schedule 1 of the PDPO. By using our website or contacting us, you acknowledge the practices described below.

Information we collect

Information you provide directly

• Identity & contact — name, email, telephone, postal address.
• Professional context — organisation, role, sector.
• Enquiry content — the subject matter of any message you send.
• Correspondence history — records of communications with us.

Information collected automatically

• Technical data — IP address, browser, device, operating system.
• Usage data — pages visited, time spent, referrer URL.
• Cookies — as described in Section 07.

How we use it

We process your information for the following purposes, in accordance with the Data Protection Principles of the PDPO:

• Responding to enquiries — necessary for our legitimate business interests.
• Service delivery — performance of our contract with you.
• Legal compliance — compliance with legal and regulatory obligations.
• Website improvement — legitimate business purposes, in aggregated form.
• Direct marketing — only with your prescribed consent under section 35 of the PDPO, freely withdrawable at any time.

Sharing

We do not sell, rent, or share your personal data for commercial purposes. We share it only with:

• Service providers — hosting, email, and analytics partners under contract.
• Professional advisers — legal, accounting, audit; under confidentiality.
• Legal authorities — where required by law or court order.
• Successors in business — in the event of a merger, sale, or restructuring, with notice.

Storage & retention

Personal data is stored on secure infrastructure located in Hong Kong and the wider Asia-Pacific region. We retain data only as long as necessary:

• General enquiry records — three (3) years from last contact.
• Service contract records — seven (7) years following completion.
• Website analytics — twenty-six (26) months.
• Marketing consent records — until consent is withdrawn plus one (1) year.

Your rights

Under the PDPO you may exercise the following rights in relation to your personal data:

• Access — request a copy of your personal data we hold (Data Access Request, section 18 of the PDPO).
• Correction — request correction of inaccurate or incomplete data (section 22 of the PDPO).
• Use limitation — request that we cease using your data for purposes other than those originally collected.
• Objection to direct marketing — opt out of direct marketing at any time, free of charge (section 35G of the PDPO).
• Information about practices — request information about the kind of personal data held and our data privacy practices.

To exercise these rights, please write to privacy@zenveris.com. We will respond within forty (40) days as required by the PDPO. You may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD) at pcpd.org.hk.

Cookies

We use a minimal set of cookies and similar technologies:

• Essential — required for basic site function.
• Analytics — to understand visitor patterns in aggregate.
• Preference — to remember settings across visits.

Your browser allows you to manage cookie acceptance. Disabling certain cookies may affect functionality.

Security

We apply appropriate technical and organisational measures, including encryption in transit, access controls, regular review of supplier security, and staff training. No internet transmission is fully secure; we treat protection of your data as a serious operational discipline.

Children

Our services are not directed at individuals under eighteen (18). We do not knowingly collect personal data from minors. If you believe we have inadvertently done so, please contact us so we can delete it.

Changes to this policy

We may update this policy to reflect changes in our practices, services, or legal requirements. Material changes will be highlighted on this page with an updated effective date. Continued use of our services after changes are posted constitutes acceptance.

Contact us

For privacy-related questions or to exercise your rights:

Introduction

These Terms govern your use of the Zenveris Limited website and the provision of services we offer. Zenveris Limited is registered in the Hong Kong Special Administrative Region.

For specific service engagements, a separate Statement of Work or Service Agreement applies and, in case of conflict, takes precedence.

Our services

Zenveris Limited provides:

• Research & development — telecommunications and information technology research.
• Technical & scientific consulting — advisory, architecture, integration.
• Equipment supply — purchase, sale, import, export, and distribution of telecommunications equipment, software, and related products.

Acceptable use

You may use our website for lawful purposes only. You may not:

• Use the site for any unlawful, fraudulent, or harmful purpose.
• Transmit unsolicited advertising or promotional material.
• Attempt unauthorised access to any part of our systems.
• Introduce viruses, malware, or other harmful technology.
• Scrape, harvest, or extract data without prior written consent.

Intellectual property

All website content — text, graphics, logos, images, software — is owned by Zenveris Limited or its licensors and is protected by Hong Kong and international intellectual property law.

You may view and print pages for personal, non-commercial use, retaining all copyright notices. Other use requires our written consent.

Intellectual property created in the course of a service engagement is governed by the applicable Statement of Work; in its absence, ownership remains with Zenveris Limited.

Liability

To the fullest extent permitted by law:

• Our website is provided "as is" without warranties of any kind.
• We do not warrant the site will be uninterrupted, error-free, or secure.
• We are not liable for indirect, incidental, special, consequential, or punitive damages.
• Our total aggregate liability shall not exceed the amounts paid (if any) for accessing the site.

Nothing limits our liability for death or personal injury from negligence, fraud, or any matter that cannot be excluded by law.

Commercial terms

For the purchase, sale, or distribution of telecommunications equipment and related products supplied by Zenveris Limited:

• Orders are subject to acceptance and the terms of the relevant commercial agreement.
• Prices exclude VAT and applicable taxes unless otherwise stated.
• Payment terms are as specified in the relevant invoice or agreement.
• Risk and title pass as specified in the relevant agreement.
• Import/export is subject to applicable customs and international commerce regulations; you are responsible for compliance in your jurisdiction.

Confidentiality

Both parties may receive confidential information. Each party will:

• Keep such information strictly confidential.
• Not disclose to third parties without consent.
• Use it only for the purposes of the engagement.
• Apply at least the same care as it does to its own confidential information.

These obligations survive termination of any agreement for five (5) years.

Termination

We may terminate or suspend access to the website without notice for conduct that violates these Terms or that we judge harmful to other users, ourselves, or third parties.

Service engagements terminate as set out in the relevant Statement of Work, including any notice provisions and termination-for-cause rights.

Governing law & disputes

These Terms are governed by the laws of the Hong Kong Special Administrative Region. Disputes will first be addressed through good-faith negotiation. Failing resolution within thirty (30) days, the courts of the Hong Kong Special Administrative Region have exclusive jurisdiction.

Either party may seek urgent injunctive relief from a court of competent jurisdiction.

Contact

Questions about these Terms:

Company information

The following details are provided for transparency and to support corporate due diligence, KYB, and onboarding processes by financial institutions and counterparties:

• Legal name — Zenveris Limited
• Type — Private Limited Company
• Registered in — Hong Kong Special Administrative Region
• Registered office — Hong Kong
• Industry classification — Telecommunications & Information Technology
• Compliance contact — compliance@zenveris.com

Full registered-address details and supporting incorporation documentation are available to verified counterparties on request.

Business activity

Zenveris Limited engages exclusively in the following lawful business activities:

• Research, development & innovation in the field of telecommunications and information technologies, including signal processing, wireless protocols, network architecture, and emerging communication standards.
• Technical and scientific consulting services, including independent advisory on technology selection, network design, systems integration, and standards-body engagement.
• Commercial activities involving the purchase, sale, import, export, and distribution of goods, products, software, and services within the telecommunications and related technology sectors.

All commercial activity relates strictly to telecommunications equipment, software licences, technical services, and related physical goods.

Non-financial scope

For the avoidance of doubt, Zenveris Limited does not carry out, offer, or facilitate any of the following activities:

• Investment management, advisory, or any form of investment-related service
• Securities dealing, market-making, or capital-markets services
• Foreign-exchange or currency-related services
• Crypto-asset services, custody, or exchange
• Payment services, e-money issuance, or money remittance
• Lending, credit provision, or guarantees
• Insurance or pension services
• Crowdfunding or peer-to-peer financing

We make no representations regarding investment performance, returns, profits, or any financial outcome whatsoever. Any reference to commercial volume or activity on this website refers solely to the supply of telecommunications equipment and related goods or services.

Anti-money laundering policy

Although Zenveris Limited is not a regulated financial institution, we voluntarily maintain controls aligned with the principles of the Hong Kong Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), the Drug Trafficking (Recovery of Proceeds) Ordinance (Cap. 405), the Organized and Serious Crimes Ordinance (Cap. 455), the United Nations (Anti-Terrorism Measures) Ordinance (Cap. 575), and applicable international standards including the Financial Action Task Force (FATF) Recommendations.

Our internal AML programme includes:

• A documented AML policy reviewed annually by senior management
• Risk-based assessment of every supplier, customer, and counterparty
• Identification and verification of beneficial owners where applicable
• Screening against international sanctions and watchlists
• Monitoring of unusual or out-of-pattern transactions
• Internal escalation routes for suspicious activity

Counter-terrorist financing

We apply zero-tolerance to any activity connected to terrorism financing or to entities or individuals listed on applicable terrorism-finance lists. Counterparty checks include screening against the United Nations Security Council Consolidated List (implemented in Hong Kong via the United Nations Sanctions Ordinance, Cap. 537), the EU Consolidated List, and the U.S. OFAC Specially Designated Nationals (SDN) list, as relevant to the transaction.

Sanctions screening

Zenveris Limited will not engage in transactions that are prohibited under applicable sanctions regimes, including but not limited to those administered by:

• The United Nations Security Council, implemented in Hong Kong via the United Nations Sanctions Ordinance (Cap. 537)
• The Council of the European Union
• The Office of Foreign Assets Control (OFAC), United States Department of the Treasury
• Other sanctions regimes as required by applicable law

All counterparties are screened at onboarding and re-screened periodically. Equipment shipments are reviewed against export-control rules including the Hong Kong Import and Export (Strategic Commodities) Regulations (Cap. 60G), administered by the Hong Kong Customs and Excise Department, and the EU Dual-Use Regulation where applicable.

Customer due diligence

Before entering into a commercial relationship, we apply risk-based due diligence including:

• Verification of legal entity, registration details, and corporate structure
• Identification of ultimate beneficial owners (UBO) where applicable
• Verification of authorised signatories and points of contact
• Understanding the purpose and intended nature of the business relationship
• Source-of-funds checks for material transactions, where appropriate
• Enhanced due diligence (EDD) for higher-risk jurisdictions or counterparties

Record keeping

Records relating to counterparty identification, transactions, and due-diligence enquiries are retained for a minimum period of five (5) years after the end of the business relationship, in line with applicable regulatory expectations. Records are stored on secure systems with restricted access and are made available to competent authorities on lawful request.

Reporting & governance

Suspicious activity is escalated internally to a designated senior officer responsible for compliance matters. Where appropriate and required, suspicious transaction reports are filed with the Hong Kong Joint Financial Intelligence Unit (JFIU), operated jointly by the Hong Kong Police Force and the Hong Kong Customs and Excise Department. Senior management reviews the effectiveness of AML and compliance controls at least once per year, supported by independent review where appropriate.

Training

All employees and engaged contractors complete compliance training appropriate to their role, including induction training and periodic refreshers covering AML, sanctions, export controls, and the recognition of suspicious activity. Training records are maintained as part of our compliance documentation.

Compliance contact

For compliance, due-diligence, KYB, or onboarding enquiries from financial institutions and counterparties, please write to our compliance team:

We will respond to verified compliance enquiries within ten (10) business days.