Welcome to the CoSecHK (港秘書) system. These Terms of Use govern your access to and use of the CoSecHK platform and services provided by Cloudsoft Technology Limited (hereinafter referred to as "the Company", "we", "us", or "our"). By accessing or using CoSecHK, you agree to be bound by these Terms of Use. If you do not agree to these terms, please do not use our services.
CoSecHK is a subscription-based SaaS platform designed primarily for Hong Kong Trust and Company Service Provider (TCSP) license holders and company secretarial service providers. The System provides the following core functionalities:
All cloud storage actions (including creating, uploading, editing, moving, copying, downloading, and deleting files or folders) are executed only when initiated or scheduled by you or your authorized users, and are limited to the scopes and directories you designate during the integration setup.
CoSecHK is a software tool. The Company is not a Trust or Company Service Provider, and does not provide legal, company secretarial, accounting, or regulatory-filing services. You remain solely responsible for all professional, statutory, and regulatory obligations applicable to your business.
To use CoSecHK, you must:
You agree to immediately notify us of any unauthorized use of your account or any other breach of security.
As a User of CoSecHK, you agree to:
By connecting a third-party storage account, you confirm that doing so does not violate your contractual or confidentiality obligations and that you remain solely responsible for the content you choose to synchronize.
The System provides templates and tools for generating various documents, reports, and forms. You acknowledge and agree that:
The System may provide features that enable you to prepare and/or submit forms, documents, and Client Data to the Hong Kong Companies Registry (the "Companies Registry") electronically through TPSI or other official electronic filing channels (collectively, "Electronic Filing Features"). You acknowledge and agree that:
Nothing in these Terms of Use constitutes legal advice. You should obtain independent professional advice regarding your filing obligations and the content of any submission.
The System may provide optional features that allow you to search, view, cache, and generate reference summaries of company information obtained through third-party commercial data services (the "Third-Party Company Reference Features"). These Features are not an official search, certificate, filing extract, or publication issued by any government authority.
Intended users. The Third-Party Company Reference Features are intended for professional use by Hong Kong Trust or Company Service Provider (TCSP) licence holders, law firms, and other similarly regulated professional service providers in connection with their legitimate client work. By using these Features, you represent and warrant that you (or the organisation you act for) fall within this intended user category.
Permitted purpose. You may use the Third-Party Company Reference Features solely for your own clients' due diligence, know-your-client (KYC) / customer due diligence (CDD), anti-money laundering (AML) compliance, or other legitimate professional purposes related to services you provide. You must not use the Features for bulk harvesting, data scraping beyond the System's ordinary interface, resale, public redistribution, or any unlawful purpose.
By accessing or using the Third-Party Company Reference Features, you acknowledge and agree that:
Use of the Third-Party Company Reference Features may be subject to separate token or usage fees. Acceptance of the on-screen acknowledgement (where presented) before first use forms part of these Terms of Use. Further details on processing of related personal data are set out in our Privacy Policy.
The System may provide optional features that allow you to upload images or files of identity documents, address proofs, and similar materials so that third-party artificial intelligence (AI) models can assist in extracting structured information into CoSecHK forms (the "AI Document Import Features").
By enabling, acknowledging, or using the AI Document Import Features, you acknowledge and agree that:
Further details on how related personal data are processed are set out in our Privacy Policy.
We are committed to protecting your data and Client Data in accordance with applicable laws and regulations. We implement reasonable technical and organisational measures designed to protect them, which may include:
No method of transmission or storage is completely secure. We do not guarantee that unauthorized access, loss, or alteration of data will never occur. Our backups are intended for operational recovery and are not a substitute for your own records; you should keep independent copies of Client Data that you consider important.
Data user and data processor. In respect of personal data contained in Client Data — including identity-document numbers, passport numbers, residential addresses, dates of birth, and similar particulars of your clients or of other individuals — which you collect for your own professional engagements and which you input, upload, or otherwise instruct the Company to hold or process through the System ("Client Personal Data"), you are the data user and the Company is the data processor, within the meaning of section 2(1) of the Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO"). You control the purposes for which Client Personal Data is collected and used. The Company processes Client Personal Data only on your instructions, including instructions given by your use of the System, for the purpose of providing, maintaining, securing, and backing up the Services, and not for any of the Company's own purposes, except where a law in force in Hong Kong requires the Company to do otherwise.
The preceding paragraph does not apply to personal data of which the Company itself controls the collection and use, including account, billing, and support contact details, and limited technical and security logs of use of the Services. For that personal data the Company is the data user. Nothing in these Terms appoints the Company as your legal adviser, company secretary, trust or company service provider, or filing agent, or transfers to the Company your duties under the PDPO, the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615), or any professional rule.
You remain solely responsible, as data user, for compliance with the PDPO in respect of Client Personal Data. That responsibility includes Data Protection Principle 1 (purpose and manner of collection), Data Protection Principle 2 (accuracy and duration of retention), Data Protection Principle 3 (use, which under the PDPO includes disclosure and transfer), Data Protection Principle 4 (security of personal data), and Data Protection Principle 6 (access and correction). You warrant that you have given every notice, and have obtained every prescribed consent, that the PDPO requires before Client Personal Data is collected, held, processed, or used through the System, or is disclosed to any person.
The following undertakings are the contractual means contemplated by Data Protection Principle 2(3) and Data Protection Principle 4(2) in Schedule 1 to the PDPO. In respect of Client Personal Data, the Company shall:
Off-site backups. The Company's current off-site repository for operational database backups is a private object-storage bucket in the Hong Kong Special Administrative Region. As at the date of these Terms, that repository is provided by Alibaba Cloud Object Storage Service in its Hong Kong region, which the Company engages as a further data processor for storage of those backup objects only. A backup object uploaded to that repository is encrypted by the Company before upload, using AES-256-GCM or another authenticated encryption algorithm of no lesser strength, and is therefore not stored there as a plaintext database dump. The Company keeps the keys for that encryption separately from the backup objects. This paragraph describes those off-site backup copies only. It is not a statement that every system used to operate the Services, or every further data processor used for a feature you choose to enable, is located in Hong Kong. Backup copies, if any, that were made to an earlier repository are outside this paragraph, and are to be removed once the Company is satisfied that they are not the only copy required for operational recovery. If the region in which the current off-site backup repository is located changes, the Company will amend this section.
You must comply with the PDPO as in force from time to time, including any restriction on the transfer of personal data out of Hong Kong if and when such a restriction is in operation. Backups made by the Company are for operational recovery. They do not satisfy your own duty to keep records, including any record-keeping duty that applies to you under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615).
Transmission to your own clients. You may, for the purposes of the professional services you provide, transmit to your own client a document generated from Client Data, a copy of a file, or a link. As between you and the Company:
Where the System generates a link for the purpose of your sending one particular file to your own client (a "Client Share Link"), that link is not a permanent public web address. It remains valid only until the expiry time stated when it is generated, and that expiry time shall be no later than seven (7) days after generation. You may revoke it before expiry. It relates only to that one file. After expiry or revocation, the System is not obliged to honour it. An address displayed in the System so that you yourself can open a file is not, merely because it is displayed, a Client Share Link. You shall not describe such an address as a permanent public address or as a Client Share Link. If you nevertheless transmit it, the allocation of responsibility in this section applies in full.
Nothing in this section excludes or limits any liability that cannot lawfully be excluded or limited under Hong Kong law.
When you enable a cloud storage integration, we store only the minimum metadata and access tokens necessary to perform the requested actions, using industry-standard encryption to protect them. Google Drive integration allows you to create, view, and manage files in folders you designate within your Google Drive, and we never take ownership of those files.
If you authorize CoSecHK to access your Google services, we will use the data received from Google APIs solely to deliver the requested features, in compliance with the Google API Services User Data Policy (including the Limited Use requirements). We do not sell or use Google user data for advertising, and human access is only allowed when required for security, to comply with the law, or when you provide explicit consent. You may revoke CoSecHK access at any time via https://myaccount.google.com/permissions. Where an operation requires downloading file content for processing, the content is retained only for the duration needed to complete that operation and is then promptly discarded.
We will not intentionally disclose, share, or sell your data or Client Data to third parties, except:
For more information about how we collect, use, and protect your data, please refer to our Privacy Policy.
To the maximum extent permitted by applicable law, the Company shall not be liable for:
In any event, the Company's total liability to you for all claims arising out of or relating to these Terms of Use or the Services shall not exceed the amount paid by you to the Company in the twelve (12) months preceding the event giving rise to the liability.
The Services are provided "as is" and "as available" without warranties of any kind, either express or implied. To the fullest extent permitted by law, the Company disclaims all warranties, including but not limited to:
The Company does not warrant that the Services will meet your requirements or expectations, and you use the Services at your own risk.
You agree to indemnify, defend, and hold harmless the Company, its affiliates, officers, directors, employees, agents, and licensors from and against any claims, liabilities, damages, losses, costs, expenses, or fees (including reasonable attorneys' fees) arising out of or relating to:
The System, including all software, source code, designs, graphics, user interface, and content (excluding Client Data), is owned by the Company and is protected by intellectual property laws. You acknowledge that:
Access to CoSecHK requires a paid subscription. By subscribing to our Services:
The Company reserves the right to:
Upon termination of your subscription, your access to the Services will cease, and we may delete your account and Client Data in accordance with our data retention policies. We recommend that you export your data before termination.
The System may contain links to or integrate with third-party websites, services, or resources. The Company:
Your use of third-party services is governed by their respective terms and conditions and privacy policies.
For integrations such as Google Drive, you acknowledge that:
Both parties acknowledge that during the course of using the Services, they may have access to confidential information. Each party agrees to:
You agree to comply with all applicable laws and regulations in your use of the Services, including but not limited to:
These Terms of Use shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region, without regard to its conflict of law provisions. Any disputes arising out of or relating to these Terms of Use or the Services shall be subject to the exclusive jurisdiction of the courts of Hong Kong.
If any provision of these Terms of Use is found to be invalid, illegal, or unenforceable, the remaining provisions shall continue in full force and effect. The invalid, illegal, or unenforceable provision shall be replaced with a valid provision that most closely reflects the intent of the original provision.
These Terms of Use, together with our Privacy Policy and Refund Policy, constitute the entire agreement between you and the Company regarding the use of the Services and supersede all prior or contemporaneous communications and proposals, whether oral or written, between you and the Company.
These Terms of Use may be provided in more than one language. If there is any inconsistency, conflict, or ambiguity between language versions, the Traditional Chinese version shall prevail.
The Company reserves the right to modify these Terms of Use at any time. We will notify you of any material changes by:
Your continued use of the Services after the effective date of the revised Terms of Use constitutes your acceptance of the changes. If you do not agree to the revised terms, you must discontinue using the Services.
If you have any questions or concerns about these Terms of Use or the Services, please contact us at:
Cloudsoft Technology Limited
Email: [email protected]
Last Updated: October 26, 2026