Last updated: 07/27/2026
WITECH COMM LIMITED (“Witech Comm,” “we,” “us,” or “our”) operates the website https://witechcomm.com (the “Site”), through which we provide bulk trading, auction, and bidding services for pre-owned smartphones, tablets, laptops, and related parts and accessories. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you visit the Site, register for an account, participate in auctions, or otherwise interact with us.
By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the Site.
1. Information We Collect
1.1 Information You Provide to Us
- Account and registration information: name, company name, business registration/license details, job title, email address, phone number, billing and shipping address, and password, when you create an account or register to bid.
- Bidding and transaction information: bid history, purchase and sales records, invoices, payment details (processed as described in Section 1.3), and order communications.
- Contact form and inquiries: name, email address, phone number, and the content of any message you send us.
- Newsletter subscription: email address, when you subscribe to auction alerts or inventory updates.
- Communications: records of correspondence if you contact our sales or support team.
1.2 Information Collected Automatically
When you visit the Site, we and our service providers may automatically collect:
- IP address, browser type and version, device information, operating system.
- Pages visited, time and date of visit, time spent on pages, and referring website.
- Cookies and similar tracking technologies (see Section 6).
1.3 Payment Information
Payments made through the Site are processed by third-party payment processors [INSERT PAYMENT PROCESSOR NAME(S), e.g., Stripe, PayPal]. We do not store full payment card numbers on our own servers. Please review the privacy policy of our payment processor(s) for details on how they handle your payment data.
1.4 Information from Third Parties
We may receive information about you from business partners, credit or trade reference agencies (for business verification purposes), or publicly available sources, where relevant to verifying bidder eligibility or conducting due diligence.
2. How We Use Your Information
We use the information we collect to:
- Create and manage your account and verify bidder eligibility.
- Process orders, auctions, bids, invoices, and payments.
- Communicate with you about your account, transactions, or inquiries.
- Send auction alerts, inventory updates, and newsletters (where you have subscribed or consented).
- Improve and maintain the Site, including troubleshooting and analytics.
- Detect, prevent, and address fraud, unauthorized transactions, or security issues.
- Comply with legal, tax, customs, and regulatory obligations, including anti-money-laundering and export/import controls applicable to international electronics trading.
- Enforce our Terms of Service.
3. Legal Basis for Processing (Where Applicable)
Where applicable law requires a legal basis for processing (e.g., for users outside Hong Kong), we rely on:
- Performance of a contract (processing your registration, bids, and orders);
- Legitimate interests (fraud prevention, Site security, and business analytics);
- Consent (marketing communications and certain cookies); and
- Legal obligation (tax, customs, and trade compliance records).
4. How We Share Your Information
We do not sell your personal data. We may share information with:
- Service providers: payment processors, shipping and logistics partners, IT hosting providers, and email/newsletter platforms, who process data on our behalf.
- Business partners and counterparties: as necessary to complete a bid, sale, or purchase transaction (e.g., sharing shipping details with a logistics provider).
- Professional advisors: lawyers, accountants, auditors, and insurers, where necessary.
- Regulators and authorities: customs, tax, and law enforcement authorities, where required by law or to protect our legal rights.
- Successors: in connection with a merger, acquisition, financing, or sale of business assets.
5. International Data Transfers
As we work with clients, suppliers, and partners across Asia and worldwide, your information may be transferred to, stored, and processed in countries other than your own, including outside Hong Kong. Where required, we take steps intended to ensure such transfers comply with applicable data protection law, including the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong.
6. Cookies and Tracking Technologies
The Site may use cookies and similar technologies to operate core functionality (such as login sessions and shopping cart), remember preferences, and analyze Site usage. You can control cookies through your browser settings; disabling cookies may affect the functionality of the Site, including account login and cart features.
[INSERT DETAIL: cookie categories used, e.g., strictly necessary, analytics (Google Analytics), advertising — and link to a cookie consent tool if one is implemented.]
7. Data Retention
We retain personal data for as long as necessary to fulfil the purposes described in this Policy, including to satisfy legal, accounting, tax, customs, or reporting requirements. Account and transaction records are generally retained for [INSERT RETENTION PERIOD, e.g., 7 years] after account closure or the relevant transaction, unless a longer period is required by law.
8. Data Security
We implement reasonable technical and organizational measures designed to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.
9. Your Rights
Subject to applicable law (including the Hong Kong PDPO), you may have the right to:
- Request access to the personal data we hold about you.
- Request correction of inaccurate or incomplete data.
- Withdraw consent to marketing communications at any time (e.g., via the unsubscribe link in our newsletters).
- Request deletion of your account and associated data, subject to our legal retention obligations.
To exercise these rights, contact us using the details in Section 12.
10. Children’s Privacy
The Site is intended for business use by professional buyers, traders, and retailers. It is not directed at, and we do not knowingly collect personal data from, individuals under the age of 18.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page indicates when it was last revised. Material changes will be notified via the Site or by email where appropriate. Continued use of the Site after changes take effect constitutes acceptance of the revised Policy.
12. Contact Us
If you have questions about this Privacy Policy or wish to exercise your data protection rights, please contact us at:
WITECH COMM LIMITED
Email: sales@witechcomm.com
Tel: (+852)-39565822
Address:
RM/FLAT 17-18 HUNG TO RD, No.1
KWUN TONG, HONG KONG