Privacy Policy

Effective Date:September 1st, 2023

Introduction and Overview

This Privacy Policy (“Policy”) explains how SUMWON Trading DMCC, which does business as “SUMWON”, collects, uses, shares and processes your personal data when you use or access this website (collectively, the “Site”) or use any of our services, including our mobile applications (“Apps”), communication platforms, and any other related services we own (collectively the “Services”). The Policy also describes your rights regarding your personal data and explains how you can contact us to learn more about our data practices or to exercise your rights.  

SUMWON Trading DMCC is responsible for the Site and sells products offered there under license from SUMWON Trading DMCC,Unit No: 3802,Mazaya Business Avenue BB1,Jumeirah Lakes Towers,Dubai,United Arab Emirates, therefore, SUMWON Trading DMCC is responsible for collecting, processing, and protecting your personal data. In this Policy, the terms “SUMWON,” “Company,” “we,” “us,” and “our” refer to SUMWON Trading DMCC.

 

Please read our Terms and Conditions and this Policy before accessing or using our Services. If you cannot agree with this Policy or the Terms and Conditions, please do not visit our Site or use our Services.

Policy Modification:

Sumwon may change this Policy from time to time, to reflect changes in how we process your personal data. If we make changes, we revise effective date or last modified date at the top of this Policy. If we make changes that materially affect your privacy rights, we will attempt to provide advanced notice (including via real- or near real-time disclosures) or otherwise via the Site, or by some other means of contact, so that you have a reasonable opportunity to review the changes before you continue to use the Site,or the Services. 

If you do not agree with the modified Policy, please stop use the Site, or the Services

 

CONTENTS

Click on the links below to go to a specific section of this Policy.

1. How We Collect and Use Your Personal Data >
2. Sharing Your Personal Data >
3. Cookies and Other Tracking Technologies >
4. Security Precautions >
5. Your Rights >
6. Retention >
7. Third-Party Websites >
8. Children >
9. Transfer of Your Personal Data>
10. California Privacy Rights >
11. Nevada Privacy Rights >
12. Contact Us >

 

Your trust in our data practices is a key part of our business, and we’re providing this Policy to transparently explain our data practices to you.  We collect personal data when you use our Site.

Personal data or information is any information that identifies or makes an individual person identifiable. The definition of personal information (used interchangeably in this Privacy Policy with the term “personal data”) depends on where you are a resident. Only the definition that applies to your country or region of residence will apply to you under this Privacy Policy.

Personal Information does not include data that has been effectively irreversibly anonymized or aggregated such that we can no longer reasonably use it to identity or re-identify you.

The chart below details the Personal Data we collect from you, and explains why we collect that data:

Purpose	The Personal Information We Collect
To create an account with us and to manage your account, to provide you our Services;	·Contact information, including email address and password, to register with our Site,or other Services;
To fulfill or process orders;	· Identity and contact information such as name, phone number and shipping address, as well as financial information or payment account information, for delivery, returns, refund, sales tax determinations, and payment operations; · Transaction details, such as return and refund details, gift card number, and order history, in our Services, in order to fulfill basic functions, including processing your payment and return requests, and keeping you informed of the order status and shipping logistics; · Location data at an IP address-based level, to tailor your experience in terms of displaying the appropriate local website, language, or user experience.
To provide customer service and support, or to provide you with service-related communications;	· Your communication history with us via various channels, such as email, phone, social media, mail, instant chat, and our customer service platform, to respond to your requests, as well as to keep you updated about your account and the Services;
To undertake marketing, advertising or other promotional activities;	· Contact information, such as email address, for email marketing purposes; · Non-directly identifiable device identifiers, operating system information, and cookie information, to direct and measure the effectiveness of the advertising we offer; · Data about how you engage with our Site,and other Services, such as browsing behavior, adding items to your shopping cart, saving items in your shopping cart or otherwise, placing an order, and returns for market research, statistical analysis and the display of personalized advertising based on your activity on our site and inferred interests; · Contact and identity information, such as name, email address and phone number, when you voluntarily elect to participate in a competition, market survey, event or other marketing campaigns organized by us via the Site, or the Services; · To share your personal data with third party advertisers. As permitted by applicable law, your information may also be used by Sumwon or the Promotion sponsor for marketing purposes. Your entry into the Promotion may result in the addition of your information to our mailing list as well as to the mailing list of our promotional partners, both as permitted by applicable law. Acceptance of a prize may require you (unless prohibited by law) to allow us to post publicly some of your information via the Site, such as on a winners’ page.
To improve our product or service, or for personalization;	· Your device information, and usage data in our Sitefor system performance analysis, troubleshooting, debugging, security monitoring, and system maintenance, as well as setting default options for you, such as language and currency; · To share your personal data within and across our corporate organization for our business needs and personalization; · Collection of your expressed preferences product reviews “votes” when prompted  so we can better understand your preference between items and to provide preference setting options; · The display of information you choose to post on public areas of the Services, for example a customer review or a photograph of you wearing our products.
To prevent and investigate fraud, security incidents, and other illegal activities;	· Information automatically collected through the Site, or Services, such as browser type, device information, operating system and account setting information for fraud prevention, security monitoring, and detection and credit risk reduction; · Log-in data for information security risk control and fraud reporting; · Billing address to verify payment information.
To comply with legal or compliance requirements;	· When required,  identity information, such as ID- or passport-related information, for customs clearance purposes; · Transaction history and certain personal information about your identity may be collected if needed to handle and resolve questions, legal disputes, for regulatory investigations purpose, information security and to comply with lawful requests from competent law enforcement agencies or courts in compliance with applicable law.
Other Purposes.	We may use your data for any other purpose disclosed to you prior to you first providing us your personal information or which is reasonably necessary to provide the Services or other related products and/or services requested, with your permission or upon your direction.

 

Please note: When communicating with us by email or through forms on our Site,or via the Services, or when you publicly share content through our Services, please do not send us any sensitive information pertaining to yourself or to others.  

We do not collect or store sensitive personal information (as that term is defined in applicable data protection laws). 

 

We may disclose and share your personal information with the parties as described below.

• Within Our Corporate Organization. Sumwon is a member of a group of companies collectively referred to as the “SUMWON.” We may share your personal information with other members of the SUMWON, in order to fulfill our legitimate interests for business maintenance, delivery of the Services, the sale of goods, personalization, and business continuity purposes.
• Service Providers. Sumwon may share your personal information with the following types of third-partyservice providers as set out in the table below:

Supplier/Service Provider/Processor	Services Offered
IT system and software service provider	Website hosting services (including cloud storage), mobile app or software optimization services, customer relationship management software, email service providers, or system maintenance services.
Payment service provider	Third-party payment processing services.
Marketing and advertising services	Assistance in reaching potential new customers across multiple communications channels, or sharing with affiliated companies that promote our products on their websites.
Order fulfillment service provider	Provision of logistics, warehousing and distribution services, return and exchange services, and order status notification services for your purchased items.
Customer service provider	Assistance with customer services and support.
Fraud prevention and information security service provider	Identity verification, fraud prevention, or credit risk reduction services to protect our website and our business.
Other Service providers selected by you	Other third parties

 

Sumwon strive to select and work with third party service providers that share our commitment to privacy, data protection, and user trust. The third parties we work with are only allowed to use your Personal Data for contractually defined purposes that our consistent with this Policy, and then only to the extent necessary to achieve those purposes.  We also insist that any third party processing Personal Data on our behalf has provided sufficient and reasonable security commitments.

• To Maintain Legal and Regulatory Compliance. Sumwon has the right to disclose your  Personal information for compliance with legal obligations or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, regulatory request or any other legal process served on us. We also may disclose your information where we reasonably believe that the disclosure is necessary to enforce our agreements or policies, or if we believe that disclosure will help us protect the rights, property or safety of  Sumwon or our customers.
• Consent.Sumwon may disclose your personal information for any purpose with your valid, documented consent.
• Corporate Transactions. Sumwon may disclose personal information—including account information, Wallet balance or points information—to a buyer, prospective buyer, corporate affiliate, or other successors in the event of a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding in which personal information held by us about our Services users is among the assets transferred. You acknowledge and agree to our assignment or transfer of rights to your personal information.

Please note that we may disclose, without restriction, anonymized information about the users of our Services, if such information that cannot identify any specific individual.

 

We may use cookies, tags, and similar technologies to automatically collect information on our Site,or Services. Cookies are small texts that are placed on your computer by our Site or, in some cases, by third parties. Tags are certain keywords used to describe your interaction with a particular feature on our Sites,or Services. Tags can be placed by us or by third parties. These, and related technologies, help us understand how you use our Sites,and our Services. If required by law, we will request your consent before using cookies or other tracking technologies. Information within this section describes our use of cookies and your ability to control the use of cookies for advertising-related purposes. As described below, we will not use cookies tags, or similar tracking technologies that process your Personal Data, unless they are Strictly Necessary Cookies, or you opt-in, i.e. consent, by using the cookie banner or consent manager found on our Site. You may withdraw your consent or update your preferences at any time by clicking the “Manage Cookies” link within the website footer.

Cookies.We use the following types of cookies, tags, and related technologies on our Site, and Services:

Strictly Necessary Cookies. These cookies are essential because they enable you to use our Services. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Site to work and they therefore cannot be disabled.

Functional Cookies. We use functional cookies to remember your choices so we can tailor our Site’s content to provide you with enhanced features and personalized content. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.

Performance or Analytic Cookies. These cookies collect passive information about how you use our Services, including the pages you visit and the links you click. We use the information collected by such cookies to improve and optimize our Services. We use the information collected by such cookies to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies as set forth below.

Advertising or Targeting Cookies. These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. Our third-party advertising partners may use these cookies to build a profile of your interests and deliver relevant advertising on other sites. You may disable the use of these cookies as set forth below.

Your Choices. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. In addition, most web browsers provide help pages relating to setting cookie preferences. More information may be found for the following browsers here: Google Chrome, Internet Explorer, Mozilla Firefox, Safari (Desktop), Safari (Mobile), Android Browser, Opera Mobile).

Pixel Tags. To measure how well our Services are performing we may use “pixel” tags to measure certain metrics, like conversion, page view, or Site usage patterns derived from information about your computer or mobile devices technical specifications.

Ad Retargeting.We also use retargeting services to advertise on third-party websites to you after following your visit to our Sites. For this purpose, visitors are grouped by certain actions on our Services, e.g., by the duration of a visit. This enables us to understand your preferences and to show you relevant advertising even if you are currently visiting another website.

Software Based Tracking. Parts of our Site may also use small pieces of embedded computer code Java scripts (called “software development kits” or “SDKs”). These SDKs accelerate the refresh speed of certain aspects of our Site, they help us monitor the usage of various online components; they allow portions of websites to be stored or “cached” within your browser to accelerate website performance, and they enable local storage of certain interactive web content files (called “HTML5”) HTML5 on your computer’s or mobile device’s local storage so it remains there whenever you visit the Site.

Do Not Track. Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

Location Information. You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by (a) disabling location services within the device settings, or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.

 

We maintain reasonable physical, electronic, and procedural safeguards designed to guard your personal data from unauthorized processing, use, or disclosure. Our security measures include physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information

The Internet is not a secure environment , and we cannot guarantee that your personal data will be secure. We therefore strongly recommend that you use a secure method and use a complex password to help us ensure the security of your account.  We also strongly advise that you neither share your password with others nor re-use passwords on our Services that you use on other sites, as doing so increases the likelihood of your being the victim of malicious cyber behavior. If you feel that the security of your account or personal data has been compromised, please immediately contact us at data@sumwonstudios.com or as otherwise described in the “Contact Us” section below.

 

To exercise your rights under this Policy and applicable law, you may contact us at data@sumwonstudios.com(see section 12).

5.1 Access, Rectification, and Deletion of your Personal Information

You may have the right under applicable laws to access, rectify, or delete the personal information that we collect. If these rights apply, and you submit a request, we may request data (including personal data and identification) from you to enable us to confirm your identity and determine your right to access such data, as well as to search for and provide you with the personal data we maintain. There are instances where applicable laws or regulatory requirements allow or require us to refuse to provide or delete some or all of the personal information that we maintain.

To exercise your rights, you may make updates within your customer account on the Site, or you may contact us at data@sumwonstudios.com.  We may not accommodate a request to delete or change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. 

5.2 Unsubscribe from Our Marketing Communications

If you no longer wish for us to use your email account to send you marketing emails or non-transactional promotional materials, please directly click on the unsubscribe link at the bottom of any of our email messages to you or contact us at data@sumwonstudios.com.

5.3 Lodging Complaints

If you believe we have infringed or violated your privacy rights, please contact us at data@sumwonstudios.com, so that we may attempt to resolve any issues to your satisfaction. Notwithstanding the approaches of exercising your rights stated above, this is without prejudice to your right to lodge a claim or compliant with your data protection authority.  

 

We will retain your Personal information, , including any correspondence you have with us, only for as long as is necessary for the purposes set out in this Policy, including retaining Personal Data in order to comply with our legal obligations, to resolve disputes, for information security purposes, and to enforce our legal rights, terms, and policies

 

Our Site may contain links to third-party sites. This Policy does not apply to those third-party sites. We recommend that you read the privacy statements of any other sites that you visit as we are not responsible for the privacy practices of those sites.

 

Our Services are not directed to, and we do not knowingly collect personal information from, children under the age of 16 or minors. If you are a minor, please do not attempt to fill out our forms or send any personal information about yourself to us. If a minor has provided us with personal information without parental or guardian consent, the parent or guardian should contact us  immediately to remove the relevant personal information and unsubscribe the minor.

If we become aware that a minor has provided us with personal information, we will take steps to promptly delete such information from our files. As described further in our Terms and Conditions, please do not upload photographs showing other people, in particular if they are minors.

 

 

When you access or use our Services, your personal data may be processed or transferred outside of the country where you reside, including to China, Singapore and/or United States.  Such countries may have data protection laws that are different or less protective than the laws of the country or region in which you reside. For these transfers, we rely on appropriate safeguards as permitted under applicable law and standards, including relying on Standard Contractual Clauses and other appropriate safeguards as permitted under the GDPR for transfers out of the European Union, the European Economic Area, the UK, or Switzerland (if any). If you do not want your information transferred to, processed, accessed, or maintained outside of the United States, you should immediately stop accessing or using the Site.

 

This section applies only to California residents. Pursuant to the California Consumer Privacy Act of 2018, as amended and pursuant to its regulations and successors (together, “CCPA”), below is a summary for the last twelve (12) months of the personal information categories, as identified and defined by the CCPA (see California Civil Code section 1798.140 (o)), that we collect, the reason we collect the personal information, where we obtain the personal information, and the third parties with whom we may share the personal information.

We generally collect the following categories of personal information when you use our Services:

• identifiers such as a name, address, unique personal identifier, email, phone number, your device’s IP address, and non-directly identifiable alphanumerical numbers associated with your devices;
• commercial information such as records of products or services purchased, obtained, or considered by you;
• Internet or other electronic information regarding your browsing activity, length of visit and number of page views, click-stream data, locale preferences, your mobile carrier, date and time stamps associated with transactions, and system configuration information;
• audio recordings of your voice to the extent you call us, as permitted under applicable laws;
• employment-related information; and
• inferences about your preferences, characteristics, behavior and attitudes.

We generally do not collect protected classifications about our users, biometric information, or education-related information. For more information about the personal information we collect and the purposes for which we use it, please refer to section 1 above.

The categories of third parties with whom we may share your personal information are listed above in section 2.

If you are a California resident, you have rights in relation to your personal information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the personal information, your account with us or the security of our network systems. To assert your right to know or your right to delete your personal information, please see the “Contact Us” section below. To confirm your identity, we may ask you to verify personal information we already have on file for you or other documentation that verifies that you are whom you claim to be. If we cannot verify your identity based on the information we have on file, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

• Right Against Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising your right to know, delete or opt-out of sales.
• Right to Know. You have the right to request in writing a list of the information we have collected or disclosed about you, the business purposes involved, and the sources of such information. You have the right to request a copy of the specific personal information we collected about you during the 12 months before your request.
• Right to Delete. You have the right to request that we delete any personal information we have collected from you or maintain about you, subject to certain exceptions.
• Right to Opt-Out of Selling. You have the right to opt-out of having your personal information sold. We do not sell your personal information as that term is generally understood but we recognize that the CCPA defines “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.”  The CCPA broadly defines “personal information” and “selling” such that making available or sharing identifiers linked to you for a benefit may be considered a sale. In the previous 12 months, we were sharing identifiers and inferences about you with our partners, third parties and affiliates in such a way that, under the CCPA, may be defined as selling. Please see the “Cookies and Other Tracking Technologies” section above for a description of opting out of cookies and controlling browser settings, in addition to clicking the “Manage Cookies” link in our website footer to load a consent tool that will allow you to opt-out of the cookies on our Site.
• Use of an Authorized Agent to Submit a Request. Only you or a person you formally authorize to act on your behalf may make a verifiable consumer request related to your personal information as a California consumer.  If you use an authorized agent to submit such a request, we will require written proof that the authorized agent has been authorized to act on your behalf or a copy of the power-of-attorney document granting that right. 

In addition, CA Shine The Light law permits customers who are California residents to request information regarding our disclosure of certain personal information to third parties for their own direct marketing purposes (see California Civil Code section 1798.83 (e)(7) for a list of personal data categories). You can submit a disclosure request using the contact information provided bellow once a year and free of charge. However, we do not share any personal information protected under the Shine The Light law with third parties, other corporate family entities or affiliate businesses for their direct marketing purposes.

 

This section applies only to Nevada residents. Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, if you are a Nevada consumer, please contact us at data@sumwonstudios.com. and inform us that you would like us to provide you notice in the event we should do so in the future, at which point you will have an opportunity to be verified and exercise your opt-out rights under that law. You may contact us as described below. It is your responsibility to keep your notice contact information current.

 

If you have questions or concerns regarding your personal information or any information in this Privacy Policy, please contact us at  data@sumwonstudios.com.