Privacy Policy

Last updated: 22.07.2026

1. Controller

The controller responsible for data processing on this website is:
Custos Trading Limited
8/F, China Hong Kong Tower, 8–12 Hennessy Road, Wan Chai, Hong Kong
Email: info@custos-trading.com
Represented by: Erkin Umur

2. General

We take the protection of your personal data seriously and process it only in accordance with the General Data Protection Regulation (GDPR) and applicable data protection law. This policy explains what data we process, for what purposes and on what legal basis, and sets out your rights.

3. Data we process when you visit this website

When you access our website, your browser automatically transmits certain data to our hosting provider’s server, which is stored temporarily in server log files: IP address, date and time of access, browser type and version, operating system, referrer URL, and requested page.
Purpose: to deliver the website, ensure stability and security.
Legal basis: Art. 6(1)(f) GDPR (legitimate interest in a secure, functional website).

4. Contacting us

If you contact us by email or via a contact form, we process the data you provide (e.g. name, company, email address, message content) to handle your enquiry.
Purpose: to respond to and process your enquiry, and to take steps prior to entering into a business relationship.
Legal basis: Art. 6(1)(b) GDPR (pre-contractual measures) and Art. 6(1)(f) GDPR (legitimate interest in business communication).

5. Hosting

This website is hosted by [Hosting-Anbieter, Anschrift]. The provider processes the data described in section 3 on our behalf as a processor under a data processing agreement (Art. 28 GDPR).

6. Cookies and similar technologies

Our website uses cookies and comparable technologies. Cookies that are strictly necessary for the operation of the website are set on the basis of Art. 6(1)(f) GDPR and § 25(2) TDDDG. Any non-essential cookies or third-party services are only used with your prior consent under § 25(1) TDDDG and Art. 6(1)(a) GDPR. You can withdraw your consent at any time with effect for the future via the cookie settings on this website.

7. Web analytics

We use [Analytics-Dienst, z. B. Google Analytics, Anbieter: Google Ireland Ltd.] to analyse how visitors use our website, on the basis of your consent (Art. 6(1)(a) GDPR, § 25(1) TDDDG). This service uses cookies and collects information such as your (shortened) IP address, pages visited, time and duration of visits, and approximate location.
This analytics service may transfer data to a third country ([z. B. USA]). Where an EU adequacy decision does not apply, appropriate safeguards under Art. 46 GDPR (in particular EU Standard Contractual Clauses) are in place.
You can withdraw your consent at any time with effect for the future via the cookie settings. [Ggf. IP-Anonymisierung / Opt-out-Details ergänzen, sobald der konkrete Dienst feststeht.]

8. External services (future)

We may introduce additional third-party services (e.g. a translation plugin). Where these process personal data or set non-essential cookies, they will only be used with your prior consent and this policy will be updated accordingly.

9. Transfers to third countries

As our company is based in Hong Kong, personal data may be transferred to and processed in Hong Kong, a country outside the EU/EEA for which no EU adequacy decision exists. Where this occurs, we ensure appropriate safeguards in accordance with Art. 46 GDPR (in particular EU Standard Contractual Clauses).

10. Retention

We store personal data only for as long as necessary for the purposes described above or as required by statutory retention obligations. Once the purpose ceases and no retention obligation applies, the data is deleted.

11. Your rights

You have the right to: access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18), data portability (Art. 20), and to object to processing based on legitimate interest (Art. 21). Where processing is based on consent, you may withdraw it at any time with effect for the future (Art. 7(3)). To exercise these rights, contact us at info@custos-trading.com.

12. Right to lodge a complaint

You have the right to lodge a complaint with a supervisory authority, in particular in the EU member state of your residence, place of work or the place of the alleged infringement.

13. Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes in our processing or legal requirements. The current version published on this website applies.