Kiwi Design and Engineering Limited

1. Who We Are

Kiwi Design and Engineering Limited is a company registered in Hong Kong. The company operates a convoy planning practice under the developer name Sea Alliance, drafting pilot rotations, mooring plans, berth windows, tide reviews, crew change schedules and safety drill calendars for clients in the maritime and logistics sectors. For the purposes of applicable data protection law, Kiwi Design and Engineering Limited is the controller of the personal information described in this policy.

The registered place of business and the chart room from which the practice operates is Rm H 8/F King Win Fty Bldg, 65-67 King Yip St, Kwun Tong, Hong Kong - 999077, Hong Kong (HK). Our website is https://www.seaalliance.lol. Our contact email address is info@seaalliance.lol and our contact telephone number is +13866393989.

Where a client, a vessel operator or a terminal engages the practice, the company may act as a processor of information that belongs to that client. In such cases the client remains the controller and the terms of the service agreement govern the handling of the information. This policy describes the company role as controller of the information it gathers directly through this website and through the ordinary operation of the chart room.

2. Information We Collect

We collect only the information that is necessary to plan a convoy, to answer an enquiry and to run the website in a safe and reliable manner. The categories of information we may hold are set out below.

Information you give to us

• Your name, job title and the organisation you represent.
• Your email address, telephone number and, where relevant, your postal address.
• The contents of any message you send through the contact form, by email or by telephone.
• Vessel details, route information and scheduling constraints that you share so that we can prepare a plan.
• Any other information you choose to provide in the course of a planning conversation.

Information gathered automatically

• Your internet protocol address, browser type, device type and operating system.
• The pages you visit on this site and the time you spend on each page.
• The site that referred you to us and the search terms that led you here, where the browser provides them.
• Standard server log information used to keep the site available and secure.

We do not ask for sensitive personal information such as health records, biometric data or information about political or religious beliefs. If such information reaches us because it was included in a message, we will delete it unless we are required to keep it by law or unless the information is genuinely necessary for a planning matter that you have asked us to handle.

3. How We Collect Information

Most of the information we hold comes directly from you. You give it to us when you complete the contact form, write to the chart room by email, call the desk, meet a planner in person or send documents relating to a convoy. The information arrives with your knowledge, and you decide how much of it to share.

A smaller amount of information is collected automatically as you browse the site. Standard web servers record the requests they receive, and this record is used to diagnose faults, to defend against abuse and to understand in broad terms how visitors reach the site. We do not attempt to identify individual visitors from these logs, and we do not combine them with the information you give us unless there is a clear need to do so and a lawful reason to proceed.

We may also receive information from a client when that client introduces us to a contact at a vessel operator, a terminal or an agency. In that case we will treat the information in the same careful way that we treat information you give us directly, and we will tell you where the information came from if you ask.

4. Why We Use Your Information

We use personal information for a small number of clear purposes. Each purpose below is tied to the work of the practice, and we do not use information for unrelated purposes without telling you first.

• To answer your enquiry and to correspond with you about a potential or current convoy plan.
• To prepare, review and maintain the plans that the six desks of the practice produce.
• To keep records that a professional planning practice is expected to keep, including correspondence about a plan and the changes made to it.
• To operate, secure and improve this website and to keep it free from abuse.
• To comply with legal obligations that apply to the company in Hong Kong and in any other place where it is required to do so.
• To protect the rights and interests of the company, our clients and the people who work with us.

Where a purpose requires your consent, we will ask for it in a clear and separate way and we will record that you gave it. You are never forced to give consent as a condition of using the site, and you can withdraw consent at any time by writing to info@seaalliance.lol.

5. Our Legal Bases for Processing

When data protection law requires us to identify a legal basis for the way we handle information, we rely on the following grounds. We choose the ground that fits the particular purpose and we review that choice when the purpose changes.

Performance of a contract

Where you or your organisation have engaged the practice, we process the information that is necessary to prepare and deliver the plan, to invoice for the work and to correspond about changes. Without this information we could not carry out the work you have asked for.

Legitimate interests

We have a legitimate interest in running a professional planning practice, in answering enquiries promptly, in keeping the website safe and in protecting the company from fraud or misuse. Where we rely on this ground we weigh our interest against your rights and we put safeguards in place so that your information is not used in a way you would not reasonably expect.

Consent

Where we wish to send you planning updates or seasonal notes, we ask for your consent first. You may withdraw that consent at any time and the withdrawal will not affect the lawfulness of anything we did before it.

Legal obligation

Some information must be kept or disclosed because the law requires it. Where this applies, we limit the processing to what the law demands and we tell you about it where we are allowed to do so.

6. Cookies and Similar Technologies

This website is deliberately light. It does not run advertising networks, it does not load tracking pixels from social platforms and it does not build a profile of your interests across other sites. Where a small cookie is set, it is used only to remember a basic preference or to keep a session working, and it carries no advertising purpose.

You can control cookies through the settings of your browser. Most browsers allow you to block third party cookies, to clear cookies when the browser closes or to warn you before a cookie is stored. Blocking a strictly necessary cookie may stop a feature of the site from working, but the planning information and the contact details on these pages will remain available to you in every case.

If we add an analytics tool in the future, we will describe it here, we will use it only to understand aggregate traffic and we will offer a way to opt out. We will not introduce a tool that sells your information to a data broker, and we will not use a cookie to follow you around the internet.

7. How We Share Information

We do not sell personal information and we do not trade it with advertisers. We share information only where there is a clear reason to do so and only with parties who are bound to handle it responsibly.

• Service providers who host the website, manage email or provide technical support, and who act on our instructions under a written agreement.
• Professional advisers such as accountants, auditors and legal counsel, where their advice is needed for the operation of the company.
• Clients and their named contacts, where sharing is necessary to prepare a convoy plan and you would reasonably expect the exchange.
• Authorities and regulators, where disclosure is required by law or is necessary to respond to a lawful request.
• A successor organisation, where the company is reorganised, merged or transferred and the information is needed to continue the practice.

Every provider we use is chosen with care and is required to keep your information confidential. We do not allow a provider to use your information for its own marketing, and we end our relationship with a provider that fails to meet the standard we set. Where a provider processes information outside Hong Kong, we apply the safeguards described in the next section.

8. International Transfers

The chart room is in Hong Kong, and the practice plans convoys that move across many jurisdictions. Some of our service providers may store information on servers located in another country. When that happens, we take steps to ensure the information continues to receive protection that is consistent with this policy.

Depending on the destination, those steps may include an agreement using standard contractual terms, a check on the security controls of the provider, a review of the legal environment in the destination country and a limit on the categories of information that may be transferred. We keep a record of the transfers we make and we review the arrangements at least once a year.

We never transfer information to a destination if we cannot put a reasonable safeguard in place. If you want to know more about how a particular transfer is protected, you may write to info@seaalliance.lol and we will explain the safeguard that applies.

9. How Long We Keep Information

We keep personal information only for as long as we need it. Retention periods are set by the purpose of the processing, by the terms of a service agreement and by the record keeping duties that apply to a planning practice.

• Enquiries that do not lead to a planning engagement are usually kept for twelve months and then removed.
• Correspondence and plans that relate to a live convoy are kept for the length of the engagement and for six years afterwards, so that the record is available if a question arises.
• Basic accounting and tax records are kept for the period required by Hong Kong law.
• Server logs are kept for a short period, normally ninety days, unless a security incident requires a longer record.

When a retention period ends we delete the information or make it anonymous so that it can no longer be linked to a person. Where information is held in a backup, we remove it as soon as the backup cycle allows and we make sure it is not used for any other purpose in the meantime.

10. How We Protect Information

We treat the security of planning information as part of the work itself. The measures we use are chosen to fit the size of the practice and the sensitivity of the information, and they are reviewed when the practice changes.

• Access to planning records is limited to the planners and staff who need it for their work.
• Accounts are protected with strong passwords and multi factor authentication where it is available.
• Data in transit between your browser and this site is protected by transport encryption.
• Devices used in the chart room are kept up to date and are protected against unauthorised use.
• Staff receive periodic reminders about phishing, password hygiene and the handling of client documents.

No method of transmission or storage is completely secure, and we cannot promise that an incident will never occur. What we can promise is that we take the risk seriously, that we limit the information we hold, and that we respond quickly and honestly if something goes wrong. The next section describes the response we have planned.

11. Your Privacy Rights

Depending on the law that applies to you, you may have a set of rights over the information we hold about you. We honour these rights in every case where the law allows, and we do not charge a fee for a reasonable request.

Right of access

You may ask whether we hold information about you and request a copy of it, together with a description of what we use it for.

Right to correction

You may ask us to correct information that is inaccurate or incomplete. Where we have shared the information with another party, we will tell that party about the correction where it is reasonable to do so.

Right to deletion

You may ask us to delete information that we no longer need, that you have withdrawn consent for or that we have processed unlawfully. There are some cases where the law requires us to keep a record, and in those cases we will explain the reason.

Right to restriction

You may ask us to pause the use of your information while a question about its accuracy or lawfulness is resolved. During that pause we will keep the information safe but we will not use it for planning.

Right to object

You may object to processing that we carry out on the basis of a legitimate interest. We will stop unless we can show a compelling reason that overrides your objection.

Right to portability

Where the law provides for it, you may ask for a copy of the information you gave us in a structured and commonly used electronic format.

To exercise any of these rights, write to info@seaalliance.lol and describe what you would like us to do. We may need to confirm your identity before we act, and we will respond within the period set by the applicable law, normally one month from the date we receive the request.

12. Marketing and Preferences

We do not send marketing messages to people who have not asked for them. If you ask to receive seasonal notes or planning updates, we will use the email address you provide for that purpose only, and every message will include a way to stop receiving them.

If you have an active planning engagement, we may send you practical messages about that engagement, such as a change to a berth window or a revised tide review. These messages are part of the service rather than marketing, and they will stop when the engagement ends unless you ask to keep receiving them.

You can change your preferences at any time by writing to info@seaalliance.lol. We will apply the change within a reasonable time and we will keep a small record of the request so that we do not repeat the error.

13. Privacy for Children

This website and the planning practice are intended for businesses and professionals. We do not knowingly collect personal information from children under the age of sixteen. The contact forms and the enquiry channels are not designed for use by children and we ask that a child does not use them.

If you are a parent or guardian and you believe that a child has sent us personal information, please write to info@seaalliance.lol and we will delete the information from our records as quickly as we reasonably can. We will not ask the child for more information than is needed to identify the record and remove it.

Where a planning engagement involves a vessel that carries younger family members, we ask the operator to handle their information and we limit our own record to the operational facts that a plan requires, such as the number of persons aboard and their role during a crew change.

14. Third Party Websites

This site may contain a link to a website operated by another organisation, for example a terminal, a port authority or a maritime directory. We provide such links because they may be useful to a reader, but we do not control the content of another site and we are not responsible for the way it handles personal information.

When you follow a link away from this site, we encourage you to read the privacy notice of the site you reach. The practices described in this policy apply only to pages that are operated by Kiwi Design and Engineering Limited under the Sea Alliance practice.

If you believe that a site we link to has changed in a way that makes the link inappropriate, please let us know at info@seaalliance.lol and we will review the link.

15. Automated Decision Making

We do not make decisions about you by purely automated means where those decisions would have a legal or similarly significant effect. A convoy plan is prepared by a person at the chart room, and the judgement about whether a window can be held is a human judgement.

We may use simple software to sort enquiries, to check a form for obvious errors or to remind a planner that a deadline is near. These tools support the work rather than replace it, and they do not decide whether to accept an engagement or how to treat a person.

If we ever introduce a tool that profiles a person in a way that affects them significantly, we will describe it in this policy, explain the logic in plain terms and offer a way to ask for a human review.

16. Data Breach Response

We have a short and clear response plan for a data breach. When an incident is suspected, the planner on duty isolates the affected system, preserves the evidence and notifies the responsible officer of the company without delay.

The company then assesses the risk to the people whose information may be affected, taking account of the type of information, the likelihood of harm and the steps already taken to contain the incident. Where the law requires it, we notify the relevant supervisory authority within the period it sets. Where a high risk to individuals is present, we notify the affected people directly and explain what happened, what we have done and what they can do to protect themselves.

After the immediate response, we record the lessons from the incident and we make the changes that are needed to reduce the chance of a repeat. We do not hide an incident, and we do not discourage a person from reporting a concern about how their information has been handled.

17. Changes to This Policy

The practice grows and the law changes, so this policy will be reviewed from time to time. When a change is material, we will publish the new version on this page, update the effective date and, where we hold a valid email address and the change is significant, send a short notice to the people it affects.

A change to the policy does not reduce the protection that applies to information we collected before the change unless the law allows it and we tell you clearly. We encourage you to return to this page occasionally so that you know how your information is handled.

18. Complaints and Regulatory Contact

If you are unhappy with the way we have handled your information, please tell us first. Write to info@seaalliance.lol with a short description of the concern and the outcome you are seeking. We will review the matter, respond within a reasonable time and explain what we have found.

If you remain unsatisfied, you may complain to the privacy regulator in your jurisdiction. In Hong Kong, the relevant authority is the Office of the Privacy Commissioner for Personal Data. We will cooperate fully with a regulator that investigates a complaint about the practice.

Raising a concern will never affect the quality of service you receive from the practice, and we will not treat a person differently because they have exercised a privacy right.

19. How to Contact Us

For any question about this policy, a request to exercise a right or a concern about the handling of information, please use the details below. We aim to acknowledge every message within two working days.

This policy was last updated on 1 January 2026 and applies to the website at https://www.seaalliance.lol and to the information held by the chart room in the course of the convoy planning practice of Sea Alliance.