Legal
Privacy Policy
Effective date: 22 October 2026. This policy explains how EVER EXUBERANT LIMITED collects, uses, stores and protects personal data in the course of coordinating community swap events and supporting market traders.
1. Who we are
This website and the services described on it are operated by EVER EXUBERANT LIMITED, a company registered in Hong Kong with its office at Rm 1001 10/F NEW MANDARIN PLZ TWR B, 14 SCIENCE MUSEUM RD, Hong Kong (HK). The team behind this policy is led by the developer Ever Exuberant, who is responsible for the day to day handling of personal data across our market coordination work.
EVER EXUBERANT LIMITED provides sourcing and resale coordination for community swap events and market traders. Our services include stall allocations, morning load-in coordination, vendor table hire, seasonal market days, goods sourcing and trader support. Each of these services involves some contact with people, and therefore some handling of personal data. We take that responsibility seriously and aim to collect only what is needed to run a safe and orderly market morning.
For the purposes of applicable data protection law, EVER EXUBERANT LIMITED is the data user and controller of the personal data described in this policy. Questions about this policy, or about the way we handle personal data, should be sent to care@everexuberant.hair or raised by telephone on +13269991947.
2. Scope of this policy
This policy applies to personal data that we collect through this website, through enquiry forms, by email, by telephone, in person at a market field, and through the operational records we keep for organisers, traders and suppliers. It covers data about stall holders, prospective traders, event organisers, suppliers, visitors who contact us and any other person whose information reaches us in the ordinary course of business.
The policy does not apply to websites operated by other organisations, even where a link to them appears on our pages. It also does not cover information that has been fully anonymised so that no individual can be identified from it, or information that is already lawfully available in the public domain without breach of any duty of confidence.
Where an event organiser shares trader information with us for the purpose of running a market day, that organiser may also have duties under applicable law. We encourage organisers to provide their own privacy notice to traders and to make clear which information is passed to us for allocation, load-in and support purposes.
3. Data we collect
We collect a limited range of personal data. For traders and applicants, this typically includes name, trading name, contact email, telephone number, postal address where a hire agreement requires it, pitch preferences, the type of goods sold and any equipment required. For organisers, it includes name, role, organisation, contact details and site information. For suppliers, it includes contact details and commercial correspondence.
We may also collect payment related information where a fee is payable for table hire or a sourcing service. Payment details are handled through the agreed method with the relevant party, and we do not store full card numbers in our own systems. We record the amount, the date, the reference and the status of each transaction so that accounts can be reconciled.
In some cases we collect operational notes. These might include a trader preference for a shaded pitch, an access need, a note that a vehicle will arrive late, or a request that a particular neighbour not be placed beside a stall. Such notes are treated as personal data because they relate to an identifiable individual.
- Identity details such as name and trading name.
- Contact details such as email address, telephone number and postal address.
- Booking details such as pitch requests, table sizes and event dates.
- Commercial details such as goods categories and hire references.
- Support records such as call notes and actions taken on a market day.
- Website data such as the pages visited and the browser used, where available from server logs.
We do not seek sensitive personal data such as health information, political opinions or religious beliefs. If a trader volunteers an access need so that we can place a pitch sensibly, we record only the minimum detail required to act on that need and we do not share that detail beyond the coordinator on duty.
4. How we collect data
Most of the data we hold arrives directly from the person concerned. A trader fills in an enquiry form, sends an email, calls the support line or speaks with our coordinator at the field. An organiser may share a booking sheet with us in a spreadsheet or a document. A supplier may send a quotation by email. Each of these routes creates a record that we keep for the reasons described in this policy.
We also receive data indirectly. An event organiser might send us a list of confirmed traders, including names and contact details, so that allocations can be prepared. A partner might introduce a new trader by email. In such cases we ask the sender to confirm that the individuals concerned expect their details to be shared for the purpose of the market, and we use the data only for that purpose.
Finally, some data is generated automatically when a visitor uses our website. Standard server logs may record the internet protocol address, the browser type, the pages requested and the time of access. We use these logs for security, troubleshooting and aggregate reporting, and we do not attempt to identify individual visitors from them except where a security incident requires investigation.
5. Why we use personal data
We use personal data to provide the services that clients and traders ask for. That includes preparing allocation maps, sending arrival windows, arranging table hire, planning seasonal calendars, responding to sourcing requests and answering support calls. Without a name and a contact method we cannot confirm a booking, and without a pitch record we cannot place a trader correctly on the morning.
We also use personal data to keep our operations safe and orderly. This includes checking that equipment has been returned, resolving a dispute between neighbouring stalls, confirming that a vehicle is authorised to enter a loading lane and following up on an accident or near miss. In these situations the data helps us act fairly and quickly.
Other uses include keeping financial records, responding to legal requests, improving our planning tools and communicating changes to a market day. When we send a message about a change, we send it only to the people affected and we keep the content focused on the practical details they need.
We do not sell personal data. We do not rent trader lists to advertisers. We do not use personal data for automated decision making that produces legal effects, and we do not build profiles of traders for unrelated marketing purposes.
6. Legal basis for processing
We process personal data where it is necessary to perform a contract with the person concerned or to take steps at that person request before entering a contract. For example, arranging a table hire or confirming a stall allocation is a contractual activity, and the related records are processed on that basis.
We also process data where we have a legitimate interest in running a safe and effective market. This covers operational records, support call logs, security monitoring and the general administration of our business. When we rely on this basis we consider whether the interest is proportionate and whether the individual would reasonably expect the processing to occur.
Some processing is necessary to comply with a legal obligation, such as keeping financial and tax records for the required period or responding to a lawful request from a public authority. Where we rely on consent, for example for an optional newsletter, the person can withdraw that consent at any time without affecting the lawfulness of earlier processing.
7. Stall and allocation records
Stall allocation is one of our core services, and it depends on accurate records. We keep a pitch map for each event that shows the position of every stall, the trader assigned to it and any special notes such as access needs or a request for a corner pitch. The map is shared with the organiser and with the coordinator on duty, and a simplified version may be shared with traders so that they know where to report.
These records are kept for the duration of the event and for a reasonable period afterwards so that we can answer questions about placement, resolve disputes and improve future plans. We limit access to the coordinator team and to the organiser who commissioned the work. When a new season begins we review older maps and remove details that are no longer needed.
8. Table hire and equipment records
When a trader hires a table or a covered display unit, we record the name, the contact method, the equipment type, the hire date and the return condition. A signed or acknowledged hire note confirms that the item was received and sets out the expectation for its return. These records allow us to track equipment across a busy season and to resolve any question about damage fairly.
Equipment records are kept for as long as the hire relationship continues and for a short period afterwards to cover late returns, deposits and accounting. We do not record payment card details in these records. If a deposit is held, we note the amount and the release date but not the underlying payment credentials.
9. Goods sourcing desk data
The goods sourcing desk helps traders find stock, packaging and display pieces. To do this we need to understand the trader requirements, which may include budget, storage space, goods category and the likely customer. We record these requirements alongside the supplier options we suggest and the outcome of each enquiry.
Information shared with a supplier is limited to what is needed to obtain a quotation or a sample. We do not pass a trader full customer list or unrelated personal details to a supplier. If a trader asks us to arrange a direct introduction, we confirm the contact details to be shared before doing so.
10. Trader support line records
The trader support line is answered during market hours and for a short window after closing. Each call is logged with the date, the pitch number, a short summary of the issue and the action taken. We keep these notes so that recurring problems at a particular location can be identified and fixed, and so that a trader who calls twice about the same matter does not have to repeat the whole story.
Call logs are kept for a limited period and reviewed during allocation planning. Audio recordings are not made unless a specific legal or safety reason requires them, and if a recording is ever made the caller is told at the start of the call. Access to call logs is restricted to the support team and to the coordinator responsible for the event.
12. International transfers
Our office is in Hong Kong and most of our records are held there. Some service providers, such as email hosts or cloud storage platforms, may process data in other jurisdictions. Where this happens we take reasonable steps to ensure that the transfer is protected by appropriate safeguards, such as contractual terms that require a comparable level of protection.
If you would like to know more about the safeguards used for a particular transfer, you can contact us at care@everexuberant.hair and we will explain the arrangement in plain terms. We review our providers from time to time and prefer those that offer clear data protection commitments and transparent locations for data storage.
13. Retention of data
We keep personal data only for as long as it is needed for the purpose for which it was collected or for a related legal requirement. Enquiry records are typically kept for two years so that a returning trader does not have to start from scratch. Allocation maps and support logs are kept for the duration of a season and reviewed afterwards. Financial records are kept for the period required by tax and accounting rules.
When a record is no longer needed we delete it or anonymise it so that it can no longer be linked to an individual. Where a record must be kept for a legal reason we restrict access to it and use it only for that reason. If you ask us to delete data and no legal obligation requires us to keep it, we will do so within a reasonable period and confirm the action in writing.
14. How we protect data
We use a combination of organisational and technical measures to protect personal data. Access is limited to team members who need the information for their work, and accounts are protected by strong passwords. Devices are kept updated, and records are stored in systems that support secure access. Paper records, where they are used at a field, are kept in a locked box and returned to the office for secure storage.
We train coordinators to handle data carefully at the field, where noise and crowds can make it easy to overhear a conversation or leave a sheet on a table. Allocation sheets are collected at the end of the day, and support notes are recorded on a protected device rather than on loose paper. If a security incident occurs, we investigate promptly, take steps to reduce the impact and notify affected individuals and authorities where the law requires it.
16. Marketing communications
We send service messages about bookings, market dates and changes to a plan because those messages are part of the work. We may also send an occasional note about upcoming seasonal market days or new sourcing options. Such notes are sent only where there is a lawful basis to do so, and every note includes a simple way to opt out.
If you opt out of marketing messages you will still receive the operational messages needed to run a market day you are part of, such as an arrival window or a weather change. Opting out does not affect your ability to use our services and does not lead to any disadvantage in future allocations.
17. Your privacy rights
Subject to applicable law, you have the right to ask for access to the personal data we hold about you. You can also ask us to correct information that is inaccurate, to delete information that is no longer needed, or to restrict the way we use it. Where we process data on the basis of consent, you can withdraw that consent at any time.
You also have the right to object to processing based on legitimate interests, and to ask for a copy of certain data in a portable format. To exercise any of these rights, write to care@everexuberant.hair with enough detail for us to identify the records concerned. We may ask for proof of identity to protect the data from unauthorised access, and we will respond within the period required by applicable law.
If your request concerns data that we hold on behalf of an event organiser, we may refer you to that organiser where they are the responsible party for the processing in question. We will tell you clearly if we do this and explain why.
18. Privacy for Children
Our services are intended for adults who organise events, trade at markets or supply goods. We do not knowingly collect personal data from children. If a family attends a market and a child appears in a photograph taken for promotional purposes, we seek permission from a parent or guardian before using the image, and we remove an image promptly if a parent or guardian asks us to do so.
If you believe that we have inadvertently collected data about a child, please contact us at care@everexuberant.hair. We will check the record and delete it unless we are required to keep it for a legal reason. We keep this position under review and update our practice if the nature of our events changes.
19. Third party links
Our pages may link to websites run by other organisations, such as a venue, a supplier or a public authority. We do not control those websites and we are not responsible for their privacy practices. We encourage visitors to read the privacy notice of any site they visit before providing personal data.
Links are provided for convenience and do not imply an endorsement of the content or the practices of the linked site. If a link appears to be broken or to point to unexpected content, let us know so that we can review it.
20. Changes to this policy
We review this policy from time to time to reflect changes in our services, our systems or the law. When a change is material we will update the effective date at the top of the page and, where appropriate, tell active clients and traders by email. The current version always applies to the website and to our services from the date shown.
We encourage you to return to this page occasionally to check for updates. If you continue to use our services after a revised policy takes effect, you are treated as having seen the revised version. If you do not agree with a change, you can contact us to discuss your options before continuing with a booking.
21. Complaints
If you are unhappy with the way we have handled personal data, please contact us first at care@everexuberant.hair or on +13269991947. We will investigate the matter, speak with the team involved and respond with what we have found and what we propose to do. Many concerns can be resolved quickly once the facts are clear.
If you remain dissatisfied after our response, you may have the right to complain to the relevant privacy regulator in your jurisdiction. We will cooperate fully with any such process. We keep a record of complaints and their outcomes so that recurring issues can be addressed in our training and procedures.
22. How to contact us
You can reach EVER EXUBERANT LIMITED by email at care@everexuberant.hair or by telephone on +13269991947. Our office is at Rm 1001 10/F NEW MANDARIN PLZ TWR B, 14 SCIENCE MUSEUM RD, Hong Kong (HK). Please include your name, the event or service concerned and a clear description of your request so that we can route it to the right person.
For data protection questions, the subject line Privacy request is the quickest way to reach the right team. We aim to acknowledge every request within a few working days and to provide a full response within the period required by law. If we need more information to identify the records, we will ask for it promptly rather than leave the request open.
This policy is provided for transparency and does not create rights beyond those available under applicable law. It should be read together with our Terms of Service, which govern the use of this website and the services we provide.