Privacy Policy

Excellent Winner (HK) Limited is a business-to-business handbag sourcing company and software provider, based at 28 Stanley Street, Central, Hong Kong. We are the data user under the Personal Data (Privacy) Ordinance (Cap. 486), and the data controller under the UK and EU GDPR, for the data described here.

For anything in this policy, including requests about your data, write to [email protected].

We collect very little, and only where you give it to us or it is unavoidable:

• What you send us. When you use the contact form or email us: your name, company, work email address, the role and topic you select, and whatever you write in your message. Supplying this is voluntary — but we cannot answer an enquiry without at least a name and an email address.
• Technical data. Our hosting provider records standard server information such as IP address, browser type and the pages requested, in order to serve the site and protect it from abuse.
• Your theme preference. If you switch between light and dark mode, that choice is stored in your own browser. It never reaches us and is not personal data.

We do not use analytics, advertising or tracking cookies on this website, and we do not buy personal data or build profiles.

We use what you send us for one purpose: to respond to your enquiry and, if it goes further, to discuss and run a sourcing programme with you.

Where the GDPR applies, our lawful bases are taking steps at your request before entering into a contract, and our legitimate interest in responding to business enquiries and keeping our site secure. Where we rely on legitimate interests, you can object — see your rights.

Your data may be disclosed to the following classes of recipient, and no others:

• Manufacturers and suppliers in our network, where sharing your enquiry is necessary to price, sample or produce what you have asked about. We share only what is needed for that, and we will tell you before we do it if your enquiry identifies you commercially.
• Service providers who host this website, deliver our email and, where relevant, carry freight or perform inspections on our behalf.
• Professional advisers or authorities, where we are required to disclose by law or to establish or defend legal claims.

We do not sell personal data, and we do not share it for anyone else’s marketing.

Sourcing is an international business. To answer an enquiry we may pass your details to suppliers or service providers located outside Hong Kong, including in mainland China, Vietnam, India and Cambodia, and to hosting infrastructure operated globally.

Where the GDPR applies and we transfer your data outside the UK or EEA, we do so on the basis of an adequacy decision where one exists, or otherwise under Standard Contractual Clauses or the UK Addendum, together with any additional safeguards the transfer needs. You can ask us for details of the safeguards used.

We do not use your personal data in direct marketing without your consent. Replying to your enquiry is not marketing. If we ever want to send you anything else — an update, an invitation, a newsletter — we will ask you first, tell you exactly what we intend to send, and give you a way to opt out at any time at no cost.

Enquiries that do not lead anywhere are deleted once they are plainly no longer live. Where an enquiry becomes a commercial relationship, we keep the correspondence and transaction records for as long as that relationship continues, and afterwards for as long as we are required to for tax, accounting and legal-claim purposes.

The site is served over HTTPS. Access to enquiry correspondence is limited to the people at Excellent Winner (HK) Limited who need it to do their job. No method of transmission or storage is completely secure, so we cannot guarantee absolute security, but we take reasonable steps appropriate to the sensitivity of the data — which, for a business enquiry, is low.

Under the Personal Data (Privacy) Ordinance you have the right to ask whether we hold data about you, to request a copy of it, and to request correction of anything inaccurate. We may charge a fee for complying with a data access request, as the Ordinance permits.

Where the GDPR applies, you additionally have rights to erasure, to restrict or object to processing, to data portability, and to withdraw consent where we relied on it.

To exercise any of these, write to [email protected]. If you are unhappy with how we handle it, you may complain to the Office of the Privacy Commissioner for Personal Data, Hong Kong, or to the data protection authority where you live.

If we change this policy we will update the date at the top of this page. Where a change materially affects how we use data you have already given us, we will tell you directly.