POS-D International Limited is committed to protecting your privacy. This Privacy Policy applies to information and data that POS-D International Limited collects as a controller, including information collected on our websites ( or through other channels, as described below. This Privacy Policy describes the processes we use to collect, receive, use, store, share, transfer and process your personal information. It also describes the choices you have regarding the use, your rights of access and correction of your personal data. If you do not agree with the data practices described in this Privacy and Cookie Policy, you should not use this website.

Last modified: 23 October 2020


Controller - who is the data controller?

Identity: POS-D International Limited
Registered Office: Unit 2611 26/F Prosperity Millennia Plaza, 663 King's Road. North Point, Hong Kong
Company Identification Number: 2525314
Email: [email protected]

Purposes - for what purposes do we process your data?

In compliance with the provisions of the General Data Protection Regulation, we inform you that we will process the data you provide us with in order to:

  • Manage the contracting of services that you carry out through the Platform, as well as the corresponding invoicing and delivery.
  • Periodically send communications about services, events and news related to the activities carried out by POS-D International Limited, by any means (telephone, mail or email), unless otherwise indicated or the user opposes or revokes their consent.
  • To send commercial and/or promotional information related to the contracted services sector and added value for end users, unless otherwise indicated or unless the user opposes or revokes their consent.
  • To comply with legally established obligations, as well as to verify compliance with contractual obligations, including fraud prevention.
  • Transfer of data to agencies and authorities, provided that they are required in accordance with legal and regulatory provisions.

Categories of data - What data do we process?

Derived from the above purposes, POS-D International Limited handles the following categories of data:

  • Identifying data
  • Electronic communications metadata
  • Commercial information data. In the event that the user provides data of third parties, he/she declares that he/she has their consent and undertakes to provide them with the information contained in this clause, exempting POS-D International Limited from any liability in this regard.
  • However, POS-D International Limited may carry out verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with data protection regulations.
Legitimation - what is the legitimacy for the processing of your data?

The processing of data for the purpose of sending periodic newsletters (newslettering) on services, events and news related to our professional activity is based on the consent of the data subject, expressly requested to carry out such processing, in accordance with the regulations in force.
Furthermore, the legitimacy for the processing of data related to offers or collaborations is based on the consent of the user who sends his data, which he may withdraw at any time, although this may affect the possible smooth communication and obstruction of processes he wishes to carry out.
Finally, the data may be used to comply with legal obligations applicable to POS-D International Limited.

Data Retention Period - How long will we keep your data?

POS-D International Limited will retain your personal data only for as long as is necessary for the purposes for which it was collected and until you revoke your consent. Subsequently, if necessary, it will keep the information blocked for the legally established periods.

To which recipients will your data be communicated?

Your data may be accessed by those providers who provide services to POS-D International Limited, such as hosting services, marketing tools and content systems or other professionals, when such communication is required by law, or for the execution of the contracted services.

POS-D International Limited, has entered into appropriate contracts with each of the suppliers that provide services to POS-D International Limited, in order to ensure that such suppliers will process your data in accordance with the provisions of the legislation in force.

They may also be transferred to the State Security Forces and Corps in cases where there is a legal obligation.

Banks and financial institutions, for the payment of services.
Public administrations with competence in the sectors of activity, when so established by current legislation.

Information Security - What security measures do we implement to protect your data?

In order to protect the different types of data reflected in this privacy policy, we will implement the necessary technical security measures to prevent their loss, manipulation, dissemination or alteration.

  • Encryption of communications between the user's device and POS-D International Limited servers.
  • Encryption of information on POS-D International Limited's own servers.
  • Other measures to prevent access to user data by third parties.
  • In those cases where POS-D International Limited has service providers for the maintenance of the platform that are located outside the European Union, these international transfers have been regulated in accordance with POS-D International Limited's commitment to the protection, integrity and security of users' personal data.
Rights - What are your rights when you provide us with your data and how can you exercise them?

You have the right to obtain confirmation as to whether or not POS-D International Limited is processing your personal data.
You also have the right to access your personal data, as well as the right to request the rectification of inaccurate data or, where appropriate, to request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

In certain circumstances, you may request the limitation of the processing of your data, in which case we will only keep them for the exercise or defence of claims.
In certain circumstances and on grounds relating to your particular situation, you may object to the processing of your data. POS-D International Limited will stop processing the data, except for compelling legitimate reasons, or the exercise or defence of possible claims.

You may also exercise your right to data portability, as well as withdraw the consents provided at any time, without affecting the lawfulness of the processing based on the consent prior to its withdrawal.

If you wish to exercise any of your rights, please contact [email protected]

Lastly, we inform you that you may address any claim arising from the processing of your personal data to the Spanish Data Protection Agency and other competent public bodies.

Modification of the privacy policy

POS-D International Limited may modify this Privacy Policy at any time, and successive versions will be published on the Website. In any case, POS-D International Limited will communicate with prior notice the modifications to this policy that affect users so that they can accept them.


This website uses third-party and own cookies to ensure you have a better browsing experience, to share content on social networks and so that we can obtain user statistics.

You can prevent the downloading of cookies through your browser settings, preventing cookies from being stored on your device.

As the owner of this website, I would like to inform you that we do not use any personal information from cookies, we only use general statistics of visits that do not involve any personal information.

It is very important that you read this cookie policy and understand that, if you continue browsing, we will consider that you accept its use.

According to the terms included in article 22.2 of Law 34/2002 on Information Society Services and Electronic Commerce, if you continue browsing, you will be giving your consent to the use of the aforementioned mechanisms.

Responsible Entity

The entity responsible for the collection, processing and use of your personal data within the meaning of the Personal Data Protection Act is, owned by POS-D International Limited - Unit 2611 26/F Prosperity Millennia Plaza, 663 King's Road. North Point, Hong Kong.

What are cookies?

Cookies are a set of data that a server places on a user's browser to collect standard Internet log information and visitor behaviour information on a website. In other words, they are small text files that are stored on the computer's hard drive and are used to identify the user when he/she logs on to the website again. Their purpose is to record the user's visit and to store certain information. Their use is common and frequent on the web as they allow pages to function more efficiently and achieve greater personalisation and analysis of user behaviour.

What types of cookies are there?

The cookies used on our website are session and third-party cookies, and allow us to store and access information relating to language, the type of browser used, and other general characteristics predefined by the user, as well as to monitor and analyse the activity carried out, in order to introduce improvements and provide our services in a more efficient and personalised manner.

Cookies, depending on their permanence, can be divided into session or permanent cookies. Those that expire when the user closes the browser. Those that expire depending on when the purpose for which they are used is fulfilled (for example, for the user to remain identified in POS-D International Limited services) or when they are manually deleted.








From Third Parties (Google Analytics)

2 years

Used to distinguish users and sessions.



From Third Parties (Google Analytics)

30 minutes

Used to determine new sessions or visits



From Third Parties (Google Analytics)

Al finalizar la sesión

Configured for use with Urchin



From Third Parties (Google Analytics)

6 months

Stores the origin or campaign that explains how the user arrived at the site


Additionally, depending on their purpose, cookies can be classified as follows:

Performance cookies

This type of Cookie remembers your preferences for the tools found in the services, so you do not have to reconfigure the service each time you visit. By way of example, this type of cookie includes: Volume settings for video or sound players. Video streaming speeds that are compatible with your browser. Items stored in the "shopping cart" in e-commerce services such as shops.

Geo-location cookies

These cookies are used to find out which country you are in when you request a service. This cookie is completely anonymous, and is only used to help target content to your location.

Registration cookies

Registration cookies are generated once the user has registered or subsequently logged in, and are used to identify you to the services for the following purposes:

To keep the user identified so that, if you close a service, the browser or the computer and at another time or another day re-enter that service, you will continue to be identified, thus facilitating your browsing without having to identify yourself again. This functionality can be deleted if the user clicks on the [close session] functionality, so that this cookie is deleted and the next time the user enters the service he/she will have to log in to be identified.

Check if the user is authorised to access certain services, for example, to participate in a competition.

Additionally, some services may use connectors with social networks such as Facebook or Twitter. When the user registers for a service with credentials from a social network, he/she authorises the social network to store a persistent Cookie that remembers his/her identity and grants access to the services until it expires. The user can delete this Cookie and revoke access to services through social networks by updating their preferences on the specific social network.

Analytical Cookies

Each time a user visits a service, an analytics cookie is generated on the user's computer by a third-party tool. This cookie, which is only generated during the visit, will be used during future visits to POS-D International Limited services to anonymously identify the visitor. The main objectives pursued are:

To allow the anonymous identification of browsing users through the cookie (identifies browsers and devices, not people) and therefore the approximate counting of the number of visitors and their trend over time.
Identify anonymously the most visited content and therefore more attractive to users Know if the user is accessing is new or repeat visit.

Important: Unless the user decides to register for a POS-D International Limited service, the cookie will never be associated with any personal data that can identify the user. These cookies will only be used for statistical purposes to help optimise the user experience on the site.

Advertising cookies

This type of cookie allows us to expand the information of the advertisements shown to each anonymous user in the POS-D International Limited services. Among other things, they store the duration or frequency of display of advertising positions, interaction with them, or browsing patterns and/or user behaviour, as they help to create a profile of advertising interest. In this way, they make it possible to offer advertising related to the user's interests.

Third-party advertising cookies

In addition to the advertising managed by the POS-D International Limited websites in their services, the POS-D International Limited websites offer their advertisers the option of serving ads through third parties ("Ad-Servers"). In this way, these third parties can store cookies sent by POS-D International Limited services from users' browsers, as well as access the data stored in them.

The companies that generate these cookies have their own privacy policies. POS-D International Limited websites currently use the Doubleclick platform (Google) to manage these services.

How can I disable cookies in my browser?

Different browsers can be configured to warn the user of the reception of cookies and, if desired, prevent their installation on the computer. Likewise, the user can check in their browser which cookies they have installed and their expiry date, and can delete them.

For further information, please consult the instructions and manuals of your browser:

For more information about cookie management in Google Chrome:

For more information on managing cookies in Internet Explorer:

For more information on managing cookies in Mozilla Firefox:

For more information on managing cookies in Safari:

For more information about managing cookies in Opera:

If you wish to stop being tracked by Google Analytics visit:

To learn more about cookies

You can learn more about online behavioural advertising and online privacy at the following link:

Google Analytics data protection:

How Google Analytics uses cookies:

Updates and changes to the privacy/cookie policy

POS-D International Limited's websites may change this Cookie Policy in accordance with legislative or regulatory requirements, or in order to adapt this policy to the instructions issued by the Hong Kong Data Protection Agency, so users are advised to visit it periodically.

When significant changes are made to this Cookie Policy, these will be communicated to users either through the website or via email to registered users.