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PRIVACY POLICY

Last updated: 01 June 2025

1. General provisions

This Privacy Policy ("Policy") is published by APPTERNET CORPORATION LIMITED (registration No. 2625180, office 35, 20 Granville Rd, Hong Kong; hereinafter "Operator," "we," "us," "our").

The Policy is prepared in accordance with the laws of the Hong Kong Special Administrative Region, namely the Personal Data (Privacy) Ordinance, Cap. 486 ("PDPO"), and applies to any personal data we collect and process through the website https://consul.online ("Site") and related communication channels.

Important territorial notice

The Site is not intended for use by persons physically located in the Russian Federation. Access from IP addresses belonging to Russian telecom operators is technically blocked. By using the Site, you confirm that you are not located in the Russian Federation and are not its resident.

Citizens of the Russian Federation who permanently reside outside Russia may use the Site in compliance with this Policy and the laws of their country of residence.

Our primary goal is to respect and protect everyone's right to privacy when processing personal data.

2. Terms and definitions
logo"Personal data" – any information relating directly or indirectly to an identified or identifiable natural person ("data subject").
logo"Processing" – any operation with personal data, automated or otherwise (collection, recording, systematisation, storage, alteration, retrieval, transfer, deletion, etc.).
logo"User" / "you" – a natural or legal person who visits the Site, registers, requests services or otherwise interacts with us.
logo"Automatic data" – information automatically transmitted by the User's device when accessing the Site (IP address, cookies, browser details, referrer, timestamp, etc.).
logo"Consular portal" – the online portal of the consular authorities of the country where the User wishes to obtain a service (appointment booking, document submission, etc.), determined by the chosen jurisdiction and not limited to any single state.
3. Data we process

We collect only the data necessary to provide the requested service, which may include:

logoFull name;
logoContact details (phone, e-mail);
logoPassport or other ID document;
logoDate and place of birth, nationality;
logoResidential address;
logoMarital status;
logoEmployment and/or education details;
logoFinancial information confirming payment of consular fees;
logoAutomatic data collected via cookies and analytics tools.

We may also process similar information about minor children or a spouse if such details are contained in the submitted documents.

We do not collect or store personal data of persons located in the Russian Federation; any such data will be deleted upon discovery.

4. Purposes of processing

Personal data are processed solely for one or more of the following purposes:

logoRegistration, authentication and maintenance of the User's account on the Site;
logoPreparation of draft documents and forms for submission through the relevant Consular portal;
logoBooking consular or notarial appointments at the User's request;
logoProvision of consulting services related to consular-legal procedures;
logoInforming the User about order status, payments and service updates;
logoImproving the Site based on aggregated anonymised analytics data.

We do not use your data for unsolicited marketing, profiling or automated decision-making.

5. Legal bases for processing

Processing is carried out on one or more of the following bases:

logoPerformance of a contract with the data subject;
logoConsent voluntarily provided by the data subject;
logoCompliance with a legal obligation incumbent on the Operator;
logoLegitimate interests of the Operator that do not override the fundamental rights and freedoms of the data subject.

A data subject may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Data security

We employ administrative, technical and physical safeguards commensurate with processing risks, including transport encryption (TLS 1.2 +), access controls, firewalls, and regular audits and tests.

Personal data are stored no longer than three (3) months after full provision of the service unless a longer period is required by law or agreed with the User.

7. Data transfer
7.1 Local storage

Primary servers are located in the European Economic Area and/or Hong Kong.

7.2 Cross-border transfer

When transferring personal data outside Hong Kong, we ensure that the receiving jurisdiction provides a level of protection comparable to the PDPO or obtain your explicit written consent.

8. Data-subject rights

Under applicable law you have the right to:

logoRequest access to your personal data;
logoRectify inaccurate or incomplete data;
logoRequest deletion of data when storage is no longer necessary ("right to be forgotten");
logoRestrict or object to processing in certain cases;
logoReceive data in a structured, machine-readable format (data portability);
logoWithdraw consent at any time.
9. Exercising your rights

To exercise these rights, send a request via the form at https://consul.online/. We will respond within 30 calendar days after verifying your identity.

10. International requests & regulators

Supervisory authorities outside Hong Kong that believe our processing falls under their jurisdiction may contact us via the Site's form. We assess such requests individually.

11. Policy changes

We may update this Policy from time to time. The current version is always available at https://consul.online/privacy-policy and supersedes previous versions. Material changes will be announced via the Site or, where possible, by e-mail.

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