SUNWA MARKETING CO.,LTD. (“the Company”) pledges to adhere strictly to laws and regulations relating to protection of personal information by means of promoting “A Code of Conduct” that the Company has adopted. The Company believes that it is its social responsibility as well as the basis of its business activities to protect personal information of customers, in order that the Company aims to provide a safety and comfortable lifestyle for the customers. The Company hereby adopts and observes its Privacy Policy.

Privacy System

The Company considers personal information of customers to be our important assets. Under the guidance of its officer in charge of protection of personal information, the Company arranges the system for Privacy Policy, and implements the protection of personal information and the training of employees concerning privacy.

Handling of Personal Information

In order to manage personal information appropriately, the Company follows Company rules in gathering, using and entrusting the handling of personal information to third party. Disposal of personal information shall also be carried out appropriately.

Purpose of Use

In order to provide customers with better products and services, the Company makes use of personal information strictly within the terms of agreement obtained when conducting questionnaires, sample distribution, prize competitions, e-mail services, catalog sales, sending marketing emails, conducting statistical analysis as well as conducting various consultations from customers. When gathering information, the purpose of use of such information is as clearly defined as possible and the scope of such information does not go beyond that which is required for the attainment of the purpose. If any necessity arises for the use of personal information beyond its initial purpose of use, the Company informs the customer about this new purpose prior to use and obtains consent of the customer.

Direct Marketing

When any person gives consent to the Company, the Company may use customers’ personal data (including but not limited to phone numbers and email addresses) to send marketing materials and other information by printed or electronic means. If customers no longer want to receive such materials, customers may inform the Company accordingly.

Shared Use

The Company may share the use of the following personal information with its subsidiaries, associated companies and other companies within the same group:

  1. Items of personal data that may be shared: Name, address, telephone number, e-mail address, product purchase history
  2. Purpose: Questionnaire, product monitoring, campaign announcements, dispatch of products/prizes, marketing
  3. Name of person or corporation responsible for the management of personal information: SUNWA MARKETING CO.,LTD.

Disclosure/Supply of Personal Information

The Company will not disclose/supply personal information of customers to third parties without prior consent given by the customer concerned, unless otherwise required by law.


The Company adopts appropriate security measures to protect personal information of customer and prevent illegal access, loss, damage, tampering with or leaking of personal information. With regard access to databases containing personal information, the Company restricts the number of staff with authority of access and takes stringent measures in order to prevent illegitimate use of personal information by Company staff as well as external agents. Should any problems occurs, the Company takes speedy remedial action.

Requests Concerning Personal Information from Customers

Requests from customers to view, correct, delete and take other such action over their own personal information shall be dealt with accordingly by the Company’s support team. In accordance with the Personal Data (Privacy) Ordinance, the Company is entitled to charge a fee which is not excessive for processing any data access requests. However, in order to prevent the leak of personal information to third parties, the request is handled only when the Company can confirm the identity of the customer.

Personal Information of Minors

The Company provides the same protection to personal information of minors as with adults. Provided however that, the consent of parents/guardians may be sought as necessary.


The Company makes a record of the Domain Name Server address of the persons who visit the Company’s website and the pages the persons have visited during their visit to the website. The Company uses this information only to analyse the traffic on its web site for preparing statistics.

Policy Statement

The Company strictly complies with laws and regulations, and other relevant rules to protect personal information, and undertakes a continuous reform of its management system, including policies (including this Privacy Policy), organization, planning, implementation, inspection and review thereof to protect personal information.