Privacy Notice
[COMPANY NAME] LIMITED, a company incorporated in Hong Kong SAR, with its registered office at [REGISTERED OFFICE ADDRESS], Hong Kong (“we”, “us”, “our”), operates the website wellarayhq.com (the “Site”) and sells Wellaray® food supplements to consumers online. You can reach us at support@wellarayhq.com or +1 (320) 381-0320.
This Privacy Notice explains what personal information we collect when you visit the Site or place an order, how we use it, who we share it with and the choices and rights you have. Effective date: September 17, 2026. [COMPANY NAME] LIMITED is the controller (the data user responsible) for this information.
1. Information we collect
- Information you give us: your name, e-mail address, phone number, delivery and billing address, the products you order, and the content of any message you send to our support address or phone line.
- Payment information: your card, PayPal, Apple Pay or Klarna details are entered on our checkout and processed by our payment processors under their own privacy terms. We receive a payment confirmation, the payment method and, for cards, the last four digits — never the full card number.
- Information collected automatically: your IP address and the approximate location derived from it, device and browser type, language, the pages you view, the link or campaign parameters that brought you to the Site, technical error logs, and identifiers stored in cookies or similar technologies (see section 6).
2. How we use it
- to process and deliver your order, take payment, prevent fraud and handle returns and refunds;
- to send you order confirmations, dispatch and tracking e-mails and to answer your questions;
- if you agreed to it at checkout, to send you e-mails about Wellaray products and offers — you can unsubscribe at any time using the link in every e-mail or by writing to us;
- to measure how the Site performs, to improve the Site and to keep it secure;
- to keep the accounting, tax and other records the law requires, and to establish or defend legal claims.
Where the GDPR or UK GDPR applies, we rely on: performance of the contract with you (orders, delivery, support); our legitimate interests (fraud prevention, security, measuring and improving the Site); your consent (marketing e-mails, non-essential cookies); and compliance with legal obligations (tax and accounting).
3. Who we share it with
We share personal information only as needed to run the Site and fulfil your order, with:
- payment processors and payment-method providers (card acquirers, PayPal, Apple Pay, Klarna) and fraud-prevention services;
- the order-management (CRM) platform that stores orders and sends order e-mails;
- warehouse and fulfilment partners, our product supplier where necessary to fulfil, replace or return an order, and the carriers that deliver the parcel;
- e-mail delivery, website hosting, error-monitoring and attribution service providers acting on our instructions;
- professional advisers (accountants, lawyers) and public authorities where the law requires it.
We do not sell your personal information. We may share limited campaign and order information with attribution partners to measure which campaigns lead to orders; to the extent this counts as “sharing” under California law, you can opt out by e-mailing us (section 7).
4. International transfers
We are based in Hong Kong and our service providers process data in the United States, the European Union, the United Kingdom and other countries. Where we transfer personal information of EU or UK residents outside those areas we use appropriate safeguards such as standard contractual clauses; transfers of personal data from Hong Kong are made in line with the Personal Data (Privacy) Ordinance.
5. How long we keep it
We keep order and payment records for as long as tax and accounting law requires (generally up to seven years), support correspondence for up to two years after the last contact, and technical data for up to 13 months, after which it is deleted or anonymised. Marketing preferences are kept until you unsubscribe.
6. Cookies and similar technologies
The Site uses strictly necessary cookies and local storage to keep the checkout working, remember your selections and prevent fraud, and first-party attribution identifiers to understand which campaigns bring visitors and orders. You can delete or block cookies in your browser settings; blocking necessary cookies may prevent the checkout from working. We do not load third-party advertising or analytics tags on the Site.
7. Your rights and choices
Depending on where you live you may have the right to access the personal information we hold about you, to have it corrected or deleted, to receive a copy in a portable format, to object to or restrict certain processing, and to withdraw consent at any time. California residents have the right to know what personal information we collect, use and disclose, to delete it, to correct it, to opt out of sale or sharing, and not to be discriminated against for exercising these rights. Residents of the EU, EEA and UK may also complain to their data-protection authority.
Under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486, “PDPO”) you have the right to request access to the personal data we hold about you and to request that it be corrected (a data access request may carry a reasonable fee). We use your data for direct marketing only with your consent, and you may at any time ask us, free of charge, to stop using your data for direct marketing. Complaints about our handling of personal data may be made to the Office of the Privacy Commissioner for Personal Data, Hong Kong.
To exercise any right, e-mail support@wellarayhq.com from the address used for your order (we may ask for further verification). We respond within one month (40 days for PDPO data access requests, 45 days for California requests) and do not charge a fee unless the law allows one or a request is clearly unfounded or excessive. You may authorise someone to act for you; we will verify the authorisation.
8. Children
The Site is intended for adults. We do not knowingly collect personal information from anyone under 16; if you believe a child has provided us with personal information, contact us and we will delete it.
9. Security
The Site is served over HTTPS, payment details are handled by PCI-DSS-compliant processors, and access to order data is limited to people who need it to fulfil and support your order. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
10. Changes and contact
We may update this Notice from time to time; the current version is always on this page with its effective date. Questions or requests: [COMPANY NAME] LIMITED, [REGISTERED OFFICE ADDRESS], Hong Kong, support@wellarayhq.com, +1 (320) 381-0320.