Privacy Policy
Last updated: 14 August 2026
This Privacy Policy explains how Berardo Limited, a private company limited by shares incorporated in Hong Kong (Company / Business Registration No. 81030046), registered office Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong, trading as Clarity Support Agency (“we”, “us”, “our”), collects and uses personal data.
We are the data controller for the personal data described in Part A. In Part B we explain the separate situation in which we act as a data processor for our clients.
Contact for privacy matters: claritysupp0rtagency@gmail.com
Part A — When we act as controller
This part applies to visitors to claritysupportagency.com, people who book a strategy call, prospective and existing clients, their staff, our applicants and our personnel.
1. Personal data we collect
You give us directly:
Contact and identification data — name, business email address, telephone number, company name, role, country.
Booking data — the information you enter when scheduling a strategy call through Calendly, including your selected time, time zone and any answers to booking questions.
Client and onboarding data — business details, billing address, bank or payment reference details, tax identification numbers, the name and contact details of your nominated representatives, and the documents we need for identity and business verification.
Communications — the content of emails, messages, call notes and any files you send us.
Applicant data — where you apply to work with us, your CV, work history, references and interview notes.
We collect automatically when you use the website:
Technical and usage data — IP address, browser type and version, device type, operating system, referring page, pages viewed, time on page and approximate location derived from IP address.
Cookie data — as described in section 11 of this Privacy Policy.
We may receive from third parties:
publicly available business information (for example, a company registry, a company website, or a business social profile) used to verify a prospective client;
information from our service providers listed in section 6.
We do not knowingly collect personal data from anyone under 18, and our services are not directed at children. If you believe a child has provided us with personal data, contact us and we will delete it.
2. Why we use it, and our lawful basis
Where the EU or UK GDPR applies, we rely on the following bases.
Where we rely on legitimate interests, we have assessed that our interest in running and protecting a lawful business does not override your rights and freedoms. You may ask us for details of that assessment.
Where we rely on consent — for example for non-essential cookies or, in some jurisdictions, for marketing emails — you may withdraw it at any time without affecting processing carried out before withdrawal.
Under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486), we collect personal data only for lawful purposes directly related to our business, collect no more than is necessary, and use it only for the purpose for which it was collected or a directly related purpose, unless you consent otherwise.
Purpose
Personal data
Lawful basis
Responding to enquiries and scheduling strategy calls
Contact, booking, communications
Legitimate interests (responding to a business enquiry); steps prior to entering a contract
Preparing proposals and negotiating engagements
Contact, client, communications
Steps prior to entering a contract; legitimate interests
Delivering our services and managing the client relationship
Contact, client, communications
Performance of a contract; legitimate interests where the client is a company
Invoicing, collecting payment and keeping accounting records
Client, billing, communications
Performance of a contract; legal obligation (Hong Kong tax and company law)
Client due diligence, sanctions and fraud screening
Client, identification
Legal obligation; legitimate interests (preventing fraud and financial crime)
Operating, securing and improving the website
Technical, usage, cookie
Legitimate interests (security and improving our service); consent where required for non-essential cookies
Direct marketing of our services to business contacts
Contact
Legitimate interests; consent where required by local law
Recruitment
Applicant
Steps prior to entering a contract; legitimate interests
Establishing, exercising or defending legal claims
Any of the above
Legitimate interests; legal obligation
3. Marketing
We may send you information about our services by email where you are an existing or prospective business client. Every marketing email contains an unsubscribe link, and you can opt out at any time by writing to claritysupp0rtagency@gmail.com. Opting out of marketing does not stop service and administrative messages relating to a live engagement.
Under section 35 of the Personal Data (Privacy) Ordinance, we will not use your personal data in direct marketing without having taken the steps that Ordinance requires, and we will stop on request at no charge.
4. Retention
We keep personal data only as long as we need it.
Where we are required to keep data to defend a legal claim, we retain it until that claim is resolved or time-barred.
Category
Retention period
Enquiries that do not become clients
24 months from last contact
Client contract, engagement and correspondence records
7 years from the end of the engagement
Invoices, accounting and tax records
7 years, as required by Hong Kong law
Client due diligence records
7 years from the end of the business relationship
Website analytics and server logs
Up to 26 months
Unsuccessful job applicants
12 months, unless you ask us to keep your details longer
Data processed on behalf of a client (see Part B)
As instructed by that client, and deleted or returned at the end of the engagement
5. Who we share it with
We share personal data only where necessary, and only with:
We do not sell personal data, and we do not share it with third parties for their own marketing purposes.
Our personnel and contracted support agents, bound by confidentiality obligations and trained on data protection;
Service providers acting on our instructions (section 6);
Professional advisers — accountants, auditors, lawyers, our Hong Kong company secretary — where required;
Banks and payment providers, to receive payment and to satisfy their onboarding and compliance checks;
Regulators, tax authorities, law enforcement and courts, where required by law or to establish or defend a legal claim;
An acquirer, if our business or its assets are sold, merged or reorganised, subject to equivalent protections.
6. Service providers we use
Where a client asks us to work inside their own systems — for example their helpdesk, e-commerce platform or communication tools — those systems are controlled by the client, and the client’s own privacy notice and provider terms govern them.
This list may change. We keep an up-to-date record and will provide it on request.
Provider
Purpose
Location
Framer B.V.
Website hosting and publishing
Netherlands / EU
Calendly LLC
Strategy call scheduling
United States
Google LLC (Google Workspace / Gmail)
Email and document storage
United States / EU
Slack Technologies (Salesforce, Inc.)
Client communication, where used
United States
Payment and banking providers
Receiving and reconciling payment
Varies
7. International transfers
We are established in Hong Kong and our personnel work remotely from several countries, including the Philippines and Portugal. Personal data we hold is therefore transferred outside the European Economic Area and the United Kingdom.
Hong Kong and the Philippines have not been the subject of an adequacy decision by the European Commission. Where we transfer personal data originating in the EEA or the UK, we do so on the basis of appropriate safeguards under Chapter V of the GDPR — principally the European Commission’s Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914), together with the UK International Data Transfer Addendum where the UK GDPR applies, supplemented by the technical and organisational measures described in section 8 and, where necessary, a transfer impact assessment.
You may request a copy of the safeguards we rely on by writing to claritysupp0rtagency@gmail.com.
8. How we protect personal data
We maintain technical and organisational measures appropriate to the risk, including:
No system is completely secure, and we cannot guarantee absolute security, but we take these obligations seriously.
access on a need-to-know basis, with individual named accounts and no shared credentials;
mandatory multi-factor authentication on email, storage and any system holding personal data;
encryption in transit (TLS) and encryption at rest on the platforms we use;
written confidentiality and data protection obligations in every personnel and contractor agreement;
data protection and phishing awareness training before an agent is given access to a client system;
prompt revocation of access when a person leaves or an engagement ends;
an internal procedure for identifying, assessing and reporting personal data breaches, including notification to the relevant supervisory authority within 72 hours where the GDPR requires it, and notification to affected clients without undue delay.
9. Your rights
Where the EU or UK GDPR applies to our processing, you have the right to:
Under the Hong Kong Personal Data (Privacy) Ordinance you have the right to request access to and correction of your personal data, and to be informed whether we hold data about you.
To exercise any right, write to claritysupp0rtagency@gmail.com. We will respond within one month, or within 40 days where the Ordinance applies. We may need to verify your identity first, and we will tell you if we need an extension because a request is complex.
Exercising your rights is free of charge, unless a request is manifestly unfounded or excessive.
access the personal data we hold about you and receive a copy;
rectify inaccurate or incomplete data;
erase your data where one of the grounds in Article 17 applies;
restrict processing in the circumstances set out in Article 18;
data portability — receive data you gave us in a structured, commonly used, machine-readable format, and have it transmitted to another controller where technically feasible;
object to processing based on legitimate interests, and to object at any time to direct marketing, which we will always honour;
withdraw consent where we rely on it;
not be subject to a decision based solely on automated processing producing legal or similarly significant effects — we do not carry out such automated decision-making or profiling.
10. Complaints
If you are unhappy with how we have handled your personal data, please tell us first at claritysupp0rtagency@gmail.com and we will try to put it right.
You also have the right to complain to a supervisory authority:
in the EEA, to the data protection authority of the country where you live, work, or where the alleged infringement took place. In Portugal, this is the Comissão Nacional de Proteção de Dados (CNPD), www.cnpd.pt;
in the UK, to the Information Commissioner’s Office, www.ico.org.uk;
in Hong Kong, to the Office of the Privacy Commissioner for Personal Data, www.pcpd.org.hk.
11. Cookies
What cookies are
A cookie is a small text file placed on your device when you visit a website. Cookies let a site remember your actions and preferences, keep it running securely, and help the operator understand how it is used.
We also use similar technologies — local storage, session storage and pixels — and in this policy we refer to all of them as “cookies”.
The cookies we use
We keep cookie use on this site to a minimum. We do not run advertising networks and we do not use cookies to build advertising profiles or to track you across other websites.
Strictly necessary cookies
These are required for the website to function and to stay secure. They cannot be switched off through our site, and no consent is required for them under Article 5(3) of the ePrivacy Directive.
Page delivery, load balancing and site security
Framer B.V. (our website platform)
Session
Remembering your cookie consent choice
Our website
Up to 12 months
Protecting forms and scheduling against abuse and bots
Framer B.V. / Calendly LLC
Session
Analytics cookies
If enabled, these help us understand which pages are visited and how the site performs, so we can improve it. The information is aggregated and we do not use it to identify you personally.
Where we use a measurement tool that does not set cookies and does not process personal data in an identifiable form, no consent is required. Where it does, we ask for consent first.
Third-party cookies from embedded services
When you use the Calendly scheduling embed or follow a link to book a strategy call, Calendly LLC sets its own cookies to operate the booking and to prevent abuse. Those cookies are controlled by Calendly, not by us, and are governed by Calendly’s own privacy and cookie notices at calendly.com/legal.
If our site embeds content from other providers in future — for example a video player or a chat widget — those providers may set their own cookies, and we will update this policy accordingly.
Page view and traffic measurement
Framer Analytics (privacy-friendly, cookieless where available)
Up to 12 months
Your choices
Consent banner. Where we use non-essential cookies, we ask for your consent through a banner before setting them. You can accept, reject, or change your choice at any time. Rejecting non-essential cookies does not stop you using the site.
Browser settings. You can block or delete cookies through your browser at any time. Instructions are available in the help pages of your browser:
Blocking strictly necessary cookies may cause parts of the site to stop working.
Do Not Track. There is currently no consistent industry standard for responding to Do Not Track browser signals, so our site does not respond to them. We do not track you across other websites in any event.
Google Chrome — Settings, then Privacy and security, then Third-party cookies
Apple Safari — Settings, then Privacy
Mozilla Firefox — Settings, then Privacy & Security
Microsoft Edge — Settings, then Cookies and site permissions
Legal basis
Where the ePrivacy Directive and the GDPR apply, we place strictly necessary cookies on the basis of Article 5(3) of the ePrivacy Directive, and any other cookie only with your consent, which you may withdraw at any time. Personal data derived from cookies is processed as described in our Privacy Policy. We may update this section to reflect changes to the technologies we use or to the law.
Part B — When we act as processor for a client
When we deliver customer support services, we handle personal data belonging to our client’s own customers — for example a shopper’s name, email address, delivery address, order number and the content of their support messages.
In that situation:
If you are a customer of one of our clients and you want to access, correct or delete your personal data, please contact the store or business you bought from — they are the controller and they hold the decision. If you contact us directly, we will pass your request to the relevant client without undue delay, and we will not act on it ourselves unless that client instructs us to.
our client is the data controller. They decide why and how that data is used, and their privacy notice governs it;
we are the data processor. We act only on the client’s documented instructions;
the relationship is governed by the data protection and processor terms in our Terms of Service, which set out the nature and purpose of the processing, our security obligations, our use of sub-processors, and how we assist with data subject requests and breach notification. A full standalone Data Processing Agreement is available on request.
we do not use that data for our own purposes, do not sell it, and do not use it to train any product of ours.
Changes to this policy
We may update this Privacy Policy from time to time. The current version is always available at claritysupportagency.com and is identified by the “Last updated” date at the top. Where a change materially affects you, we will take reasonable steps to notify you.
Contact
Berardo Limited (trading as Clarity Support Agency)
Suite C, Level 7, World Trust Tower, 50 Stanley Street, Central, Hong Kong
Company / Business Registration No. 81030046
Email: claritysupp0rtagency@gmail.com