1. Scope and purpose
This Notice applies when a private enquiry is submitted through a TrustCome-controlled enquiry form, secure portal, authorised email address, private introduction, professional referral, meeting request, telephone contact, correspondence route, or another intake channel that incorporates or refers to this Notice.
It governs preliminary receipt, authentication, organisation, conflict and risk screening, capability assessment, communications, safeguarding, and closure. It applies to the enquirer and to each person or organisation on whose behalf, with whose authority, or about whom the enquiry is made.
This Notice should be read with the Legal Status Notice, the Website Terms of Use, Privacy Notice, and Cookie Notice. A signed engagement instrument, secure-room terms, local notice, or separately executed confidentiality or non-circumvention agreement may impose additional or different terms for a particular matter.
2. What submission does — and does not — do
By submitting or authorising a private enquiry, the enquirer asks TrustCome to receive, record, authenticate, review, communicate about, and assess the submitted information for the purposes described in this Notice.
Submission is a request for preliminary consideration only. It is not an offer by TrustCome, a promise to act, a reservation of capacity, or confirmation that the matter is suitable, lawful, conflict-free, funded, or capable of acceptance.
Submission, acknowledgement, document review, discussion, meeting, or a request for further information does not create a client, adviser, fiduciary, agency, partnership, joint venture, employment, brokerage, trustee, legal, financial, investment, or comparable professional relationship. Such a relationship begins only after required approvals and execution of a definitive written engagement instrument by authorised parties.
Preliminary communications are for intake and assessment and must not be relied upon as legal, tax, regulatory, financial, investment, technical, security, or other professional advice. The enquirer remains responsible for independent advice and all applicable deadlines unless a signed engagement instrument expressly provides otherwise.
3. Information to provide
At first contact, an enquiry should normally identify:
- the enquirer and any represented person or organisation;
- reliable contact details and the capacity in which the enquirer acts;
- a high-level description of the matter and requested outcome;
- principal parties, counterparties, beneficial owners, and relevant jurisdictions, where known;
- the genuine deadline or urgency, without assuming TrustCome is responsible for it;
- known confidentiality, safety, privilege, regulatory, or security concerns; and
- the source of the introduction or referral, where applicable.
The enquirer should provide information that is accurate, current, and not misleading, and should distinguish fact, estimate, allegation, opinion, and potentially privileged material. Material corrections or changes should be communicated promptly.
5. Consent and lawful processing
TrustCome may process enquiry information to administer the submission, verify identity and authority, communicate with the enquirer, evaluate whether a matter may proceed, protect systems and persons, preserve evidence, comply with law, and defend legal or institutional rights.
Consent is not necessarily the sole lawful basis for every activity. Where applicable law requires a separate lawful basis, TrustCome may rely on steps requested before a possible engagement, legitimate institutional interests, legal obligations, security, prevention or detection of wrongdoing, defence of claims, or another basis permitted by law. Consent to enquiry contact does not authorise unrelated marketing.
Where processing relies on consent, the enquirer may withdraw that consent for future activity. Withdrawal does not affect earlier lawful processing and may not require deletion of records that remain necessary for legal duties, conflict protection, security, audit, prevention of wrongdoing, defence of claims, or another lawful purpose.
6. Preliminary checks
TrustCome may conduct checks proportionate to the proposed matter, parties, jurisdictions, sensitivity, and risk. These may include contact and identity verification, authority and ownership checks, conflicts, sanctions, politically exposed person status, adverse information, source of funds or wealth where relevant, professional credentials, security indicators, and capability or capacity assessment.
Checks may use information supplied by the enquirer, public records, registries, professional referees, specialist databases, controlled service providers, advisers, or direct contact with an identified authority. A preliminary conflict or risk check may need to be repeated as the parties, scope, jurisdictions, or circumstances become clearer.
7. Confidential handling
TrustCome will treat an authorised private enquiry as confidential within the framework of this Notice. Access will be limited by role, purpose, risk, and need to know. This controlled handling extends, where appropriate, to the content of the enquiry, the identity of the enquirer, and the fact that an enquiry has been made.
Confidential handling may involve authorised TrustCome personnel, operating offices, controlled technology and service providers, and professional advisers who require access for intake, legal, governance, risk, security, compliance, technical, or operational purposes. Internal or controlled professional access is not public disclosure and remains subject to confidentiality, security, monitoring, and records-management controls.
| Handling level | Indicative information | Minimum approach |
|---|---|---|
| General enquiry | Identity, contact details, high-level matter description, principal parties, and requested outcome. | Standard controlled intake and proportionate verification. |
| Confidential enquiry | Non-public commercial, personal, contractual, or strategic information. | Restricted need-to-know access and controlled communications. |
| Sensitive enquiry | Elevated legal, financial, reputational, safeguarding, or security impact. | Enhanced approval, transmission, access, and retention controls. |
| Highly restricted | Classified, privileged, serious-threat, investigation, identity, banking, or exceptional strategic material. | Do not send at first contact; use a specifically authorised secure environment. |
8. Limits and permitted disclosure
Confidential handling is subject to lawful and necessary exceptions. TrustCome may use or disclose information, to the minimum reasonably necessary, in circumstances including:
- need-to-know review by authorised personnel, advisers, insurers, auditors, security specialists, or controlled providers;
- verification with a registry, bank, professional referee, authority, counterparty, or connected person where lawful and appropriate;
- compliance with law, regulation, court order, compulsory process, professional duty, or a binding request from a competent authority;
- protection of life, safety, security, property, legal rights, professional independence, or institutional integrity;
- prevention, detection, investigation, or reporting of sanctions evasion, money laundering, terrorist financing, corruption, fraud, coercion, abuse, cyberattack, impersonation, market abuse, or serious crime;
- information that was lawfully known without restriction, becomes public without breach, is received lawfully from another source, or is independently developed without use of the enquiry; or
- disclosure clearly authorised by the enquirer or required by a later engagement instrument.
Where legally permitted and reasonably practicable, TrustCome may notify an affected person before compulsory disclosure. TrustCome is not required to challenge a lawful demand, provide notice where prohibited, or incur disproportionate cost or risk. Notice may also be withheld where it could constitute tipping off or prejudice a lawful investigation.
9. Privilege, NCNDA, and non-circumvention
Submission to TrustCome does not automatically create legal professional privilege, attorney-client privilege, litigation privilege, without-prejudice protection, professional secrecy, or an equivalent doctrine. Those protections depend on applicable law, purpose, participants, and the existence of a qualifying professional relationship.
This Notice establishes controlled confidentiality expectations, but it is not a negotiated non-disclosure agreement, NCNDA, non-circumvention agreement, exclusivity arrangement, standstill, no-contact agreement, or restriction on independent activity. No compensation, ownership transfer, non-use obligation, opportunity reservation, or non-circumvention duty arises merely because an unsolicited idea, transaction, introduction, technology, or opportunity is submitted.
Enhanced contractual protection requires a separate authorised instrument. Where appropriate, TrustCome may consider an NCNDA or another confidentiality arrangement through its controlled request and approval process.
10. Secure channels and sensitive material
Public forms and ordinary email are suitable only for a high-level initial enquiry. TrustCome may redirect the enquirer to an encrypted communication method, authenticated portal, controlled data room, in-person review, or another approved channel before receiving sensitive material.
Files and links may be scanned, sandboxed, blocked, quarantined, or deleted for security. Password-protected, executable, unusually large, or unsafe content may be rejected unless an approved process is used. The enquirer is responsible for protecting devices and credentials under their control and for independently verifying TrustCome contact details before following payment, banking, credential-change, or document-transfer instructions.
TrustCome is not an emergency service. A person facing an immediate threat to life, safety, or property should contact the appropriate emergency or public authority rather than relying on a private enquiry submission.
11. Assessment outcomes and closure
TrustCome may request clarification or evidence, propose a secure channel, arrange a preliminary meeting, redirect the enquiry, place it on hold, decline it, or close it. An acknowledgement confirms receipt only and does not establish authenticity, completeness, conflict clearance, acceptance, confidentiality beyond this Notice, or a professional relationship.
TrustCome may decline or close an enquiry because it is outside scope, unavailable, unsuitable, conflicted, prohibited, insufficiently verified, inconsistent with institutional values, unsupported by adequate authority, or inappropriate for another legitimate reason. Detailed reasons may be withheld where explanation could reveal another person’s confidential information, security controls, legal restrictions, conflict information, proprietary methodology, or risk assessments.
The enquirer may ask TrustCome to stop preliminary consideration. TrustCome will cease unnecessary prospective activity but may retain limited records where justified for legal, security, conflict, audit, integrity, and institutional-protection purposes.
12. Records, retention, and international handling
TrustCome may preserve evidence of submission, acknowledgement, choices, identity and authority checks, communications, access, decisions, and closure. Records will be limited and retained according to the nature of the enquiry, legal duties, conflict protection, security, claims, audit needs, and the applicable retention schedule.
Incomplete, abandoned, or declined enquiries may be deleted, anonymised, archived, or reduced to a limited conflict and decision record after the applicable period. Accepted matters may be transferred into the controlled engagement record. Legal holds, incidents, investigations, or mandatory duties may require longer preservation.
Information may be accessed or processed in another jurisdiction where necessary for authorised operations, professional support, secure infrastructure, verification, or legal compliance. TrustCome will apply appropriate contractual, organisational, and technical safeguards and will consider local restrictions affecting privacy, secrecy, privilege, regulated information, and governmental access.
13. Rights, withdrawal, and complaints
Depending on the law that applies, a person may have rights concerning access, correction, deletion, restriction, objection, portability, consent withdrawal, and complaint to a competent authority. Rights may be limited by confidentiality owed to another person, legal privilege, legal duties, conflict protection, security, records integrity, prevention of wrongdoing, and defence of claims.
A request should identify the individual, the relevant enquiry, approximate date, contact route, and the right being exercised. TrustCome may verify identity and authority before responding and may preserve the original submission alongside a correction or clarification where necessary for the evidential record.
A good-faith privacy, security, ethics, or governance concern may be raised without retaliation. This does not prevent proportionate action in response to malicious, knowingly false, abusive, or unlawful conduct. Nothing in this Notice prevents a person from contacting a competent regulator, court, supervisory authority, law-enforcement body, or other lawful forum.
14. Form acknowledgement
A TrustCome private-enquiry form may ask the enquirer to confirm the following before submission:
Submission acknowledgement: I confirm that I am authorised to submit this enquiry and the information provided; I request preliminary TrustCome review and consent to contact about the enquiry; I have read the Privacy Notice and this Private Enquiry Consent & Confidentiality Notice; I understand that submission does not create a professional relationship, legal privilege, an NCNDA, non-circumvention, exclusivity, or acceptance of the matter; and I have not included highly sensitive material that requires a separately confirmed secure channel.
A consent or acknowledgement record may be retained to evidence the request, authority, choices, and version of the notice presented at the time of submission. Optional marketing consent, if ever requested, must be separate from the enquiry acknowledgement.
15. Contact
Questions, corrections, withdrawal requests, confidentiality concerns, privacy requests, or complaints concerning a private enquiry may be sent through the TrustCome Private Enquiry Office.
TrustCome Legal & GovernancePrivate Enquiry Administration
One International Finance Centre
1 Harbour View Street
Central, Hong Kong
Please write “Private Enquiry” in the subject line. Do not attach identity originals, banking records, privileged documents, passwords, security credentials, or highly sensitive matter files until an authorised secure channel has been confirmed.