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Privacy Policy

Last Updated: May 16, 2026

1. Scope and Introduction

HONG KONG PRIMADAWN GROUP LIMITED ("we," "us," "our," or the "Company"), operating the e-commerce brand Teavra ("Website": teavra.com), registered at RM 1002, 10/F, Easey Commercial Building, 253–261 Hennessy Road, Wan Chai, Hong Kong, is committed to safeguarding the privacy and security of your personal data.

This Privacy Policy governs your interaction with our Website and outlines how we collect, process, store, transfer, and protect your personal data in accordance with applicable global data protection laws, including but not limited to the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) ("PDPO"), the EU General Data Protection Regulation ("GDPR"), and United States state-level privacy frameworks (such as the California Consumer Privacy Act/CPRA).

2. Lawful Bases for Processing (For EU/UK Users)

We only process your personal data when we have a valid legal framework to do so, specifically:

  • Performance of a Contract: To process, fulfill, and deliver your orders.

  • Consent: When you explicitly opt-in to receive our marketing materials.

  • Legitimate Interests: To improve website security, detect fraud, optimize user experience, and manage internal analytics.

  • Legal Obligation: To comply with tax, customs, anti-money laundering, and corporate compliance regulations.

3. Comprehensive Categories of Information We Collect

We collect both information you actively provide to us and information automatically generated by your interaction with the Website.

A. Information Voluntarily Provided by You:

  • Identity & Contact Data: First name, last name, billing address, shipping address, email address, and telephone number.

  • Financial Data: Payment card details, transaction history, and payment gateway authorizations (processed via secure, encrypted third-party environments).

  • Account Data: Username, password, order history, and customer service communication records.

B. Automatically Collected Technical Data:

  • Device & Usage Data: Internet Protocol (IP) address, login data, browser type and version, time zone setting, browser plug-in types, operating system, platform, and geolocation data.

  • Tracking & Cookie Data: Tracking metrics via web beacons, pixels, and localized cookies detailing your navigational behavior across our platform.

4. Mechanisms of Data Collection and Cookies

We deploy cookies, web beacons, and persistent identifiers to augment site functionality.

  • Strictly Necessary Cookies: Required for shopping cart maintenance and secure checkout.

  • Performance & Analytics Cookies: Utilized to map traffic patterns (e.g., Google Analytics) to improve our storefront interface.

  • Targeting/Advertising Cookies: Configured by third-party ad networks to broadcast relevant commercial messaging based on your digital profiles.

  • Opt-Out: You maintain the autonomous right to decline or suppress cookies via your local web browser settings, acknowledging that doing so may impair specific operational aspects of the transaction interface.

5. Intent and Purpose of Data Processing

Your personal data is explicitly allocated to the following operational parameters:

  • Order Execution: Payment verification, inventory routing, customs manifest creation, and logistical delivery.

  • Customer Advocacy: Technical troubleshooting, response management, and return/refund processing.

  • Risk Mitigation & Fraud Prevention: Transaction screening to minimize chargebacks and authenticate valid payment parameters.

  • Targeted Direct Marketing: Transmitting updates on premium tea vintages and promotional materials, strictly contingent on your active, explicit consent (Opt-In).

6. Data Storage, Retention, and the Shopify Infrastructure

Our e-commerce infrastructure is hosted by Shopify Inc. Shopify provides the digital platform executing our transaction pipelines. Your personal data is securely sequestered across Shopify’s decentralized data storage facilities, databases, and generalized applications behind enterprise-grade firewalls.

  • Payment Infrastructure Security: All direct payment mechanisms adhere strictly to the protocols administered by the Payment Card Industry Data Security Standard (PCI-DSS), overseen by the PCI Security Standards Council. Your transaction metrics are fully encrypted via Transport Layer Security (TLS) and AES-256 protocols.

  • Data Retention Policy: We retain personal data only for as long as necessary to fulfill the purposes outlined in this policy, or as mandated by statutory tax laws and financial compliance structures (typically 7 years for corporate and accounting records under Hong Kong Law).

7. Authorized Third-Party Disclosures and Cross-Border Transfers

We do not sell, trade, or rent your personal data. We disclose specific metrics to authorized service providers under stringent data processing agreements:

  • Logistical Partners: Courier networks (e.g., DHL, FedEx, SF Express) for shipping execution.

  • Payment Authorities: Processors (e.g., Stripe, PayPal, Shopify Payments) for credit card clearing.

  • Cross-Border Data Transmissions: As global e-commerce operators, the data we extract may be transferred to, processed, and stored in jurisdictions outside your country of residence (including Hong Kong, Singapore, and the United States). By interacting with this platform, you acknowledge and consent to these cross-border handshakes. We apply appropriate safeguards (such as Standard Contractual Clauses) to ensure your data remains legally protected.

8. Your Global Legal Rights

Depending on your geographic location, you possess comprehensive legal rights over your personal data:

  • Right of Access & Portability: Request a copy of all personal metrics held within our systems.

  • Right to Rectification: Mandate immediate modification of erroneous or incomplete profiles.

  • Right to Erasure ("Right to be Forgotten"): Request the total deletion of your personal history, subject to statutory retention overrides.

  • Right to Restrict or Object to Processing: Halt the deployment of your data for analytical profiles or direct marketing campaigns.

  • Withdrawing Consent: You possess an absolute right to dissolve marketing consent at any time by utilizing the "Unsubscribe" mechanism inside our emails or messaging support directly.

To enforce any of these statutory rights, submit an official petition to: support@teavra.com.

9. Minor Protection Framework

This Website does not intentionally solicit, aggregate, or process data belonging to minors under the age of 18 (or the equivalent legal threshold of majority in your jurisdiction). If it is determined that data from a minor has been recorded without verifiable parental authorization, it will be immediately expunged from our database clusters.

10. Modifications to this Privacy Protocol

We reserve the absolute statutory right to amend this Privacy Policy at any time to reflect changing global regulatory environments. All amendments take effect immediately upon their publication on the Website. Continued usage of the site post-modification constitutes explicit acknowledgment of the updated terms.

11. Governance and Dispute Resolution

This Privacy Policy is governed by, construed, and enforced in accordance with the laws of the Hong Kong Special Administrative Region (HKSAR). Any unresolved disputes stemming from data practices managed under this policy will be submitted to the non-exclusive jurisdiction of the courts of Hong Kong.

12. Corporate Contact Matrix

For legal inquiries, data access requests, or regulatory complaints, please communicate directly with our Privacy Compliance Officer:

HONG KONG PRIMADAWN GROUP LIMITED

Attn: Privacy Compliance Team

RM 1002, 10/F, Easey Commercial Building

253–261 Hennessy Road

Wan Chai, Hong Kong

  • Corporate Phone: +852 6916 2005

  • Direct Support Inbound: support@teavra.com