Privacy policy

1.1Who is responsible for this policy

This Policy explains how Tajir Global Limited, registered in Hong Kong at Bayfield Building, 99 Hennessy Rd, Wan Chai, Hong Kong, handles personal data of Utajir visitors, subscribers, their representatives and people contacting us. Privacy contact: contact@utajir.com. Utajir and Thrive Connector are brands used by the same company; the connector name does not indicate a transfer to another company of that name.

1.2What the policy covers

This Policy covers our sites, applications and connector services referring to it, according to the interaction and function used. The Utajir services described here are ready; public registration and support have not yet opened. A function’s readiness does not mean it is enabled in your account or its data is being collected now. Function-specific practices apply when that function is enabled and used, with required notices and safeguards in place before new collection. Merchant and Agency sites and external services have their own responsible parties’ notices; below we explain our role when processing on their behalf.

2.1Managing our relationship with you

We determine the purposes and means of handling contact, subscription, billing, support and security data for our direct relationship, with the duties of the responsible entity under applicable law, including Hong Kong's data-user concept. Being a processor for some services does not make every processing activity one conducted on a customer's behalf.

2.2Merchant and Agency client data

When a merchant manages contacts, orders or learners on the platform, it usually determines processing purposes and we process data under its instructions and the DPA. An Agency may process for its client, making us a subprocessor, or determine an independent purpose for which it is responsible. Data-subject requests go to the party determining the purpose, with our assistance within our role; an Agency label or account ownership does not confer absolute rights over everyone's data.

3.1Account and relationship data

Depending on your interaction, data includes your name, contact details, represented organization, account identifier, role and permissions, Order and invoice details, payment status and necessary support correspondence and attachments. We do not request full card details in support messages or content fields. If recorded calls or support-session recording are offered, recording and its purpose are explained beforehand and required permission is obtained.

3.2Technical and optional-feature data

Data needed to operate a function may include network address, browser and device information, request times, errors, and records of access and significant actions. Enabled integrations may involve account identifiers, permissions and connection tokens; AI features involve the inputs and outputs you choose to use. This description does not authorize recording the content of every action or collecting unnecessary data, and describing technical data does not introduce an advertising-tracking purpose.

4.1Information you provide and use generates

We receive information you supply when contacting us, registering, managing a subscription or seeking assistance, and information necessarily generated by service operation. The current site stores language and theme preferences on your device as explained in the Cookies Policy. Collection forms must distinguish required from optional information and explain the effect of withholding it.

4.2Invitations and connected parties

An administrator may provide invitation and permission details, an integration provider may send data for the authorized function, or a participant may record a referral under an actual program. We explain the source and purpose where required for data obtained from others. Public availability is not permission for unrestricted collection or marketing, and this Policy does not cover purchasing contact databases or enriching your data from external sources for our marketing.

5.1Information at collection

When collecting data from you, we identify the responsible party, purposes, recipient categories, whether supply is obligatory or voluntary and the consequences of withholding it, with a route for access and correction. A notice appears near collection with a link to details; this information is not merely buried in lengthy terms, nor is site use treated as consent to every purpose.

5.2Function-specific disclosure

If a function requires additional data, different sharing or a consequential automated decision, we present the specific information before activation, including required consent, withdrawal and its effects. An Agency's client notice must reflect its own collection and platform processing on its behalf, without substituting Utajir's identity for the seller's.

6.1Service delivery and account administration

Account and authorization data supports authorized functions, user administration, subscriptions, invoicing and support. Orders, messages and connector information within a customer account are used to carry out the function it instructed. These purposes do not authorize selling its contact database or using its contents for our own campaigns.

6.2Protection, improvement and communication

Necessary records help detect misuse, verify access authority, correct faults, protect rights and meet legal obligations. Service measurement and improvement are confined to lawful disclosed data and purposes, with minimization and aggregation where appropriate. Necessary service messages are separate from optional marketing, and a new purpose requires assessment, disclosure and required acceptance or consent before it begins.

7.1Basis by purpose and applicable law

Where law requires a processing basis, we use contractual necessity to establish an individual’s subscription and supply their contracted service; legal obligation for required accounting records and binding demands; legitimate interests for managing relationships with company representatives, protecting systems and preventing fraud after balancing individual rights; and consent for marketing, storage or optional purposes where required. An employee’s data is not automatically processed under their employer’s contract because the employee is not its party. Customer-account content is processed under customer instructions and the DPA, rather than for our independent purposes.

7.2Purpose limits and consent withdrawal

In Hong Kong we observe fair, necessary collection and use limited to the original or a directly related purpose, obtaining required consent for unrelated new purposes and direct marketing. Where we rely on consent, withdraw it at contact@utajir.com or through the method shown for the function. Withdrawal affects future processing without invalidating lawful prior processing. We do not silently switch bases to continue a purpose you refused.

8.1Providers and account administrators

Necessary data is made available to providers operating the relevant function, such as hosting, storage or message delivery when used, under appropriate contracts and permissions. Providers processing customer data on our behalf are identified in the Subprocessor Register and the annex associated with your subscription before that processing; this Policy does not authorize access by an undisclosed provider. Your administrator or authorized Agency may see information within its permissions. Common corporate ownership does not automatically grant access to data.

8.2Advisers, legal requests and business transfers

We may disclose necessary information to a confidentiality-bound adviser, in response to a valid legal request after review, or to protect lawful rights within the law. A business transfer requires assessment of data-transfer necessity, safeguards, notices and any required choice or consent; a possible company sale does not authorize every use of all data. Disclosures are minimized and their reasons recorded, with notice where legally permitted.

9.1Connection data and identity

When an integration is enabled, authorization identifies the intended account, permissions, function and data sent or imported. Execution may require an access token and account identifiers, contacts, appointments or messages according to the approved scope; one connection does not authorize every future feature. Thrive Connector identity, its company relationship and policy links must match the provider's authorization screen.

9.2Restricted data and disconnection

Data from Google and other restricted services remains subject to the disclosed purpose and applicable provider policy; it is not used for advertising or general-model training where Limited Use rules prohibit this. General consent does not override those restrictions. You may revoke authorization with the provider or available connection controls; subsequent access stops within the revocation scope, while imported data and provider copies require separate deletion handling under their purpose and law.

9.3Data by connected service

Meta, WhatsApp and Telegram functions may transmit account identifiers, messages, attachments and delivery data within permission; Google, Microsoft and Zoom functions use account, calendar, meeting or other function-specific content. Displaying payment balances or status and sending provider instructions remains subject to the Payments section and does not authorize access to your entire bank account. Each provider performs its role under its notice and contract; we remain responsible for our collection, use, integration security and providers processing on our behalf.

10.1Utajir subscription payment data

To administer Utajir subscription charges, we process the invoice holder’s identity, address and tax information where needed, amount, currency, payment status and references, and limited method information made available by the collection flow. That flow identifies the collector before you enter payment credentials. We do not request full card numbers or security codes in content fields or support attachments. This collection is separate from your sales funds handled by your payment provider.

10.2Merchant payment data

When connecting your account with Ravinto, an independent payment service that is ready for use, you create the payment account, link your bank account and provide verification data directly to the payment provider. The integration exchanges data needed for authorized functions, such as provider-account and transaction identifiers, amount, currency, payment status, balance, withdrawal and refund requests, and information needed to respond to disputes. Displaying that information or submitting a request through Utajir does not mean Utajir owns the payment account or holds its funds. The provider controls acceptance, verification, settlement, reserves, withdrawals, refunds and disputes under its contract and notice; we remain responsible for data processed to operate our integration. Provider, data and permission details are presented before connection.

11.1What an AI feature sends

An AI feature's function determines required inputs and what is sent to its provider, such as text to draft or information for an authorized task, and retained outputs or execution records. Activation is not permission to send your entire customer database. Provider, purpose, retention and any human-access information must be available before uses requiring it; avoid unnecessary or restricted inputs.

Designated functions use OpenAI API. We do not authorize general-model training on customer content through this integration. The provider may retain abuse-monitoring records or state for particular functions according to the API and settings; we therefore do not describe the service as having zero retention or no human access. The function notice and associated schedule identify transmitted data, retention period or criteria and deletion procedure before use. Provider information: https://developers.openai.com/api/docs/guides/your-data .

11.2Training and consequential decisions

The service-delivery licence does not include training general or shared models on customer content. We do not authorize that use through the subscription or acceptance of the Terms. Any separate optional arrangement begins only after specific disclosure, a lawful basis and separate consent where required, and cannot override a source-data prohibition. Before offering automated decisions with legal or similarly significant effects, we provide required information on their general logic, effects, safeguards and applicable human-intervention and challenge rights; this Policy does not give general permission for those decisions.

12.1Marketing communication choices

Before direct marketing, we explain the data types, subjects, channels and purpose and obtain legally required permission, including applicable Hong Kong requirements. You may stop marketing through the message's method or privacy channel without an opt-out fee. Necessary service messages such as security alerts or invoices may continue without marketing inserted to bypass your choice. Sharing for another party's marketing requires its own disclosure and basis.

12.2Tracking and advertising

The Cookies Policy explains device technologies and available choices. The service contract does not authorize sale of customer-account data or sharing it for cross-context behavioral advertising. Before any optional processing constituting statutory sale, sharing or targeted advertising, its data categories, recipients, purpose and opt-out rights are disclosed and binding privacy signals are honored where applicable. That processing does not begin under cover of subscription acceptance.

13.1Where processing takes place

Processing locations depend on systems, providers and enabled functions, including storage, backups, remote access and support. Hong Kong incorporation does not mean data remains there. Customer-data processing countries are identified in the provider register and service annex before that processing begins. Request details of the relevant route at contact@utajir.com. We promise data residency in a region only if expressly specified in an Order, with its stated storage and access boundaries.

13.2Transfer safeguards

Where a transfer requires special safeguards, the appropriate lawful route is established, such as adequacy or effective contractual clauses with required transfer assessment and supplementary measures. Acceptance of the Terms is not a general substitute. You may request information about the applicable safeguard or a copy with limited redactions for secrets or others' data; onward transfers remain subject to required protection.

14.1Retention criteria

We retain account-administration data during the relationship and delete or de-identify what is no longer needed after closure under the service-exit schedule. Necessary invoices and accounting records are kept for 7 years from transaction completion where Hong Kong law requires, or longer for a specific applicable duty. Ordinary support correspondence is kept for up to 24 months after case closure, and routine operational and security logs for up to 90 days from recording, unless an incident or existing dispute requires a particular subset. Agreement-acceptance evidence is kept as needed to establish the relationship and defend claims within the applicable limitation period. A minimal marketing suppression record remains while needed to prevent renewed contact. Possible usefulness does not justify open-ended retention; exceptions are reviewed when their reason ends.

14.2Deletion and exceptions

At service end, account-data retrieval is available for 30 days under the Terms and DPA. We delete active copies within 30 days after that window ends or a valid deletion request that does not conflict with another protected right. Isolated backups expire within 90 days of active-copy deletion; they are not returned to ordinary use, and deletion instructions are reapplied on restoration. A specific legal duty or existing dispute may delay deletion only of the necessary subset, with restricted use and reviewed justification. A shorter legally required period or valid processing instruction applies where required. Removing a name alone is not anonymization where a person remains reasonably identifiable.

15.1Measures and data sensitivity

We take technical and organizational measures appropriate to processing risks and data nature under the DPA and security annex. The Security page explains service boundaries and commitments; it is not certification or a guarantee against intrusion. Do not enter sensitive or sector-regulated data unless the function and agreed arrangements expressly support it, and minimize data shared in support and optional features.

15.2Incidents and notification

For a personal data breach, we assess impact, contain it, cooperate with relevant parties and notify authorities or individuals when law or contract requires. As processor, we notify the customer without undue delay under the DPA so it can perform its role; necessary initial information does not wait for a completed investigation. An access problem is not automatically a breach, and one deadline does not apply to all laws and roles.

16.1Subscription eligibility

Subscribers and account administrators must be at least 18 or the age of majority where they reside, whichever is higher, and have the required capacity. This applies to subscriptions and administration; it does not mean every buyer or learner served by our customers is an adult. If we learn of an ineligible account, we verify only as necessary, restrict impermissible processing and arrange deletion or other required action without excessive collection.

16.2Minors on customer sites

A store, course or membership operator determines its audience and meets age-appropriate notice, parental permission and other minors’ data requirements where applicable. We process on its behalf under lawful instructions while retaining our direct duties. A primarily child-directed service or sensitive categories of children’s data require prior written agreement on support and safeguards; technical ability to create a course does not establish suitability for that purpose.

17.1Rights under applicable law

Hong Kong rights include access to and correction of your data subject to statutory conditions. Where other laws apply, rights may include deletion, restriction, portability, objection, consent withdrawal and opting out of sale, sharing or targeted advertising. Not every right is absolute or available to every person in every context; we explain applicable rights and justified exceptions and do not penalize exercise of a legally protected right.

17.2Verification, deadlines and complaints

We may request only information necessary to verify identity or representative authority. Hong Kong access and correction requests generally follow a forty-day period subject to statutory rules and exceptions. Under the EU GDPR, response is within one month, with a justified extension of two further months and notice within the first month. California-law requests to know, delete or correct have a forty-five-day period with a lawful extension and notice; that period does not automatically apply to sale opt-outs. Any legally permitted fee is explained beforehand. You may complain to Hong Kong's Privacy Commissioner or the relevant authority without first exhausting our process.

Where UK law applies, we acknowledge a data-protection complaint within 30 days, investigate and communicate the outcome without undue delay, preserving your right to complain to the ICO. Where California law applies, requests to opt out of sale or sharing or limit sensitive-data use are actioned within no more than 15 business days, with binding opt-out signals honored as required; these choices are not subjected to data-copy identity-verification procedures. Any applicable shorter periods and rules follow the request type and your location.

18.1Contact and requests

For access, correction, deletion, objection or privacy enquiries, email contact@utajir.com or write to Tajir Global Limited at Bayfield Building, 99 Hennessy Rd, Wan Chai, Hong Kong. Identify the site or account and request without initially sending a password or full identity document. Requests & Reports explains handling of merchant or Agency data. Where a service or market requires a local representative or data protection officer, their details are supplied in the specific notice before the processing requiring that appointment operates.

18.2Changes and local supplements

We identify each effective version and material changes, notify affected persons where required and obtain new consent where a purpose change requires it. Updating policy text does not authorize previously unlawful processing. Local disclosures are added after market and applicability assessment, including required category and rights tables; citing a law does not declare it globally applicable.