Privacy Policy

1. Who we are

WealthSmart Tech Commerce Limited 財智通科技商貿有限公司, a company incorporated in Hong Kong under the Companies Ordinance (Cap. 622), company number 78825535, is the data controller for the personal data processed through this store.

Registered office

15/F, Room 1508, Argyle Centre Office Tower Phase 2, 625 Nathan Road, Mong Kok, Hong Kong

Privacy contact

privacy@wealthsmart.hk

EU representative

For enquiries under the GDPR, contact privacy@wealthsmart.hk and mark the message "GDPR enquiry"

Our product and customer service operations are carried out from Baiyun District, Guangzhou, Guangdong Province, China. Where a member of our team handles your enquiry or your order, your data is accessed from that location — this is covered in section 5.

2. What we collect

Information you give us

• Order and delivery details — name, delivery address, email address, telephone number, order contents and order value
• Billing details — billing address and, where required, payment verification information. We do not store full card numbers on our own systems
• Correspondence — the content of emails and messages you send us, including any attachments
• Account details — if you create an account, your email address and order history

Information collected automatically

• Device and usage data — IP address, browser type and version, operating system, screen resolution, referring page, pages viewed and time spent on our site
• Cookie and similar technologies — see our cookie policy
• Server logs — recorded for security and to keep the service available

Information from third parties

• Payment institutions and fraud prevention providers — to verify a payment and assess transaction risk
• Carriers — to deliver your parcel and to support any return or loss enquiry
• Analytics and customer support providers — to understand how the site is used and to answer your messages

3. Why we use it and on what basis

Purpose	Legal basis (GDPR)
Taking, processing and delivering your order	Performance of a contract
Handling returns, refunds and warranty claims	Performance of a contract; legal obligation
Answering your enquiries and providing support	Performance of a contract; legitimate interests
Preventing fraud and securing the site	Legitimate interests; legal obligation
Keeping accounting and tax records	Legal obligation
Sending order updates and service messages	Performance of a contract
Product news and offers, where you have asked for them	Consent, withdrawable at any time
Improving the site and our range	Legitimate interests, using aggregated or anonymised data wherever possible

4. Who we share it with

We share personal data only with the following categories of recipient, and only to the extent needed:

• Payment institutions — to take payment and to settle refunds
• International carriers and logistics partners — to deliver your order and process returns
• Suppliers — where an order is fulfilled from our Guangzhou operation, for the sole purpose of preparing and shipping your items
• Professional advisers — accountants, auditors and legal advisers, under a duty of confidentiality
• Public authorities — where we are legally required to disclose, for example tax or customs records

We do not sell, rent or trade personal data. We do not share data with third-party advertising networks for cross-context behavioural advertising.

5. International transfers

Some of the service providers listed above operate outside Hong Kong and the European Economic Area, including providers in the United States, the European Economic Area, mainland China and Singapore. Where personal data is transferred outside the EEA, we rely on an adequacy decision where one exists, or on Standard Contractual Clauses approved by the European Commission, or on another lawful transfer mechanism. We also apply supplementary measures where appropriate, including access controls and encryption in transit.

Data accessed by our team in Guangzhou from our Hong Kong entity is a transfer between Hong Kong and mainland China. We apply the same access controls, encryption and retention limits described in this policy to that access.

6. How long we keep it

• Order and delivery records — retained for 7 years from the end of the financial year in which the order was placed, to meet Hong Kong tax and accounting record-keeping requirements
• Correspondence — retained for 3 years from the last contact
• Payment verification data — retained only for as long as required to investigate a dispute
• Server and security logs — retained for up to 12 months
• Analytics data — retained for 26 months, then deleted or aggregated beyond identification

7. Your rights

Depending on where you live, you may have the right to ask us to:

• Access — give you a copy of the personal data we hold about you
• Rectification — correct data that is inaccurate or incomplete
• Erasure — delete data we no longer have a lawful reason to keep
• Restriction — limit how we use your data while we consider a request
• Objection — object to processing based on legitimate interests, and to direct marketing at any time
• Portability — receive certain data in a machine-readable format
• Withdraw consent — where our processing relies on consent
• Complain — to your local supervisory authority

We respond to requests within 30 days and we do not charge for them. To make a request, email privacy@wealthsmart.hk. Please include enough information for us to identify your order.

If you are in the European Economic Area, you may complain to the supervisory authority in the country where you live or work, or to the Irish Data Protection Commission as our lead authority. If you are in Hong Kong, you may complain to the Office of the Privacy Commissioner for Hong Kong. If you are in California, you may contact the California Privacy Protection Agency.

8. How we protect it

• This site is served over HTTPS with TLS encryption
• Card details are entered directly with our payment institution and never reach or persist on our own servers
• Administrative access to customer records is limited to staff who need it and is individually authenticated
• We apply the same access controls to records handled by our operations team in Guangzhou
• We review our service providers periodically and require appropriate confidentiality and security commitments

No system is perfectly secure. If a breach affects your personal data, we will notify you and the relevant authority as required by applicable law.

9. Children

This store is not directed at children, and we do not knowingly collect personal data from anyone under 16. If you believe a child has provided us with personal data, contact us and we will delete it.

10. Changes to this policy

We update this policy when our processing changes. The date at the top of the page shows when it was last revised, and material changes will be announced on the site before they take effect.

11. Contact

For any privacy question, or to exercise a right described above, write to privacy@wealthsmart.hk, or by post to:

Data Protection Officer
WealthSmart Tech Commerce Limited
15/F, Room 1508, Argyle Centre Office Tower Phase 2
625 Nathan Road, Mong Kok, Hong Kong

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This policy is published by WealthSmart Tech Commerce Limited, a company incorporated in Hong Kong under the Companies Ordinance (Cap. 622), company number 78825535.