Privacy policy

PRIVACY POLICY

Last Updated: June 17, 2026

1. Welcome & Acceptance

Welcome to Hamilton Fine Havana Merchant (hereinafter referred to as "Hamilton Fine Havana Merchant", "we", "us", or "our"), operated by The International Marketing Exchange Limited (Company No. 0001876), with its registered address at 601 Car Po Commercial Building, 18–20 Lyndhurst Terrace, Central, Hong Kong.

We operate this boutique store and website, including all related information, content, features, tools, products, and services, in order to provide you, the customer, with a curated shopping experience (the "Services").

Hamilton Fine Havana Merchant is powered by Shopify, which enables us to provide the Services to you. This Privacy Policy describes how we collect, use, and disclose your personal information when you visit, use, or make a purchase or other transaction using the Services or otherwise communicate with us. If there is a conflict between our Terms and Conditions and this Privacy Policy, this Privacy Policy controls strictly with respect to the collection, processing, and disclosure of your personal information.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you acknowledge that you have read this Privacy Policy and understand the collection, use, and disclosure of your information as described herein.

2. Personal Information We Collect or Process

When we use the term "personal information," we refer to information that identifies or can reasonably be linked to you or another individual. Personal information does not include information that is collected anonymously or that has been completely de-identified so that it can no longer identify or be reasonably linked to you.

We may collect or process the following categories of personal information, including inferences drawn from this data, depending on how you interact with our Services and as permitted or required by applicable law:

  • Contact Details: Your full name, physical billing address, shipping address, phone number, and email address.

  • Financial Information: Credit card, debit card, and financial account numbers, payment card data, transaction details, form of payment, payment confirmations, and other relevant billing metrics.

  • Account Credentials: Your created username, password, security questions, shopping preferences, and platform settings.

  • Transaction Information: Items you view, put in your cart, add to your wishlist, purchase, return, exchange, or cancel, along with your comprehensive past transaction history.

  • Customer Communications: Any information you include in correspondence with us, such as customer support inquiries, feedback, or retail requests.

  • Device Information: Technical data regarding your device, browser type, network connection, IP address, and other unique digital identifiers.

  • Usage Data: Information regarding your real-time interaction with the Services, including how, when, and where you navigate our platform.

3. Personal Information Sources

We gather personal information via the following channels:

  • Directly From You: When you create an account, complete a transaction, visit our brick-and-mortar boutique, or communicate directly with our staff.

  • Automatically Through the Services: Collected from your device when you browse our website, utilizing cookies, web beacons, and similar tracking technologies.

  • From Service Providers: Third parties we engage to execute operational tech on our behalf (such as cloud hosting, payment gateways, and data processing vendors).

  • From Corporate Partners: Third-party entities, advertising networks, or data brokers as permitted under local regulatory frameworks.

4. How We Use Your Personal Information

Depending on your operational interactions with us, we process your personal information to:

  • Provide, Tailor, and Improve the Services: To fulfill our retail obligations under our contract with you. This includes processing payments, dispatching orders, managing your account, facilitating returns, and serving a customized product layout or tailored recommendations.

  • Marketing and Advertising: To send promotional announcements, updates, text alerts, or direct postal mail, and to generate targeted display ads on our platform or external websites based on your browsing habits.

  • Security and Fraud Prevention: To validate account logins, secure our point-of-sale systems, protect public safety, investigate malicious activity, and insulate our business against e-commerce fraud or unauthorized payment reversals.

  • Maintain Client Communications: To handle your back-end customer support requests swiftly and build a continuous commercial relationship.

  • Legal & Regulatory Enforcement: To fulfill our obligations under Hong Kong law (such as mandatory record-keeping or age-verification compliance under the Smoking Ordinance), react to judicial subpoenas, or support active litigation.

5. How We Disclose Personal Information

We may share your personal information with selected third parties for legitimate operational reasons:

  • Shopify and Primary Core Vendors: To processing companies, logistics providers, IT management groups, customer support desks, and cloud storage systems essential to fulfilling your orders.

  • Business and Marketing Partners: To personalized ad services to run retargeting campaigns across the internet. You may hold a localized legal right to direct us not to share information for cross-context behavioral advertising.

  • Explicit Directives: When you explicitly request or authorize us to pass data to an outside vendor (e.g., shipping couriers or third-party social media integrations).

  • Corporate Affiliates: Inside our consolidated corporate network managed under The International Marketing Exchange Limited.

  • Business Restructuring: In association with an acquisition, corporate merger, asset sale, or restructuring event where customer databases represent an element of business assets.

6. Relationship with Shopify

Our digital storefront is hosted by Shopify, which independently processes data to facilitate and refine our e-commerce performance. Information submitted by you will be securely transmitted to and stored on Shopify’s infrastructure, which may be located in jurisdictions outside your home country.

To help protect and optimize our business operations, we utilize enhanced features provided by Shopify that integrate metrics compiled from cross-merchant data and platform-wide user profiles. Shopify acts as an independent controller regarding this platform-wide data analysis. To learn more about how Shopify processes data and to exercise your independent choices, you can review the Shopify Consumer Privacy Policy and access the Shopify Privacy Portal.

7. Third-Party Websites and Links

Our digital platform may house outbound links to external online channels operated by third parties. We do not exercise structural control over, nor take liability for, the security and data management schemes enforced on unaffiliated platforms. Review the unique privacy documentation of any off-site channel you interact with.

8. Children's and Minor's Data

Our Services are strictly restricted to adults and are not designed for or targeted to minors. In alignment with our strict Terms and Conditions, we do not knowingly process details relating to anyone below the legal age of majority in their jurisdiction (and in any event, no younger than 18 years of age). If a parent or legal guardian discovers that a minor has circumvented age gates and submitted personal records, you can request data elimination by contacting us via the details below.

9. Security and Retention of Your Information

Security Notice: While we enforce robust encryption mechanisms to safeguard data, please remember that no structural cybersecurity framework is completely impenetrable. Any information sent to us over transit via open webs or public protocols travels at your own risk. We strongly recommend using secure channels when sharing sensitive payment details.

We store data for as long as necessary to support your commercial account, ensure full tax/statutory compliance, settle operational disputes, or enforce the specific terms of our transactional contracts.

10. Your Rights and Choices

Depending on your regional jurisdiction, you may hold localized legal entitlements regarding your personal records, including:

  • Right to Access / Know: To demand clear accounting and delivery of a copy of the explicit details we maintain on your identity.

  • Right to Delete: To request the wholesale eradication of historical personal entries we maintain on you.

  • Right to Correct: To direct us to amend outdated, broken, or inaccurate records.

  • Right of Portability: To request the technical migration of your files to an outside business or platform.

  • Managing Communication Preferences: You can unsubscribe from our marketing distribution list at any point via the "Unsubscribe" mechanism found at the base of our emails. We will still communicate operational and order-fulfillment details regarding purchases you execute.

To exercise these options, contact our administrative office using the data supplied below. We will never discriminate against you for exercising your privacy privileges. We reserve the right to demand verification of identity or request validation proofs from designated authorized agents prior to releasing data file adjustments.

11. International Transfers

We operate a global luxury supply model and may transmit, store, and process your records in data hubs situated outside your native jurisdiction. If we handle data extractions originating out of the European Economic Area (EEA) or the United Kingdom (UK), we execute these movements in full reliance on recognized structural transfer legalisms, specifically the European Commission's Standard Contractual Clauses (SCCs), or matching UK legislative counterparts.

12. Changes to This Privacy Policy

We maintain the operational authority to update or modify this Privacy Policy as our business practices and regulatory landscapes evolve. Any adjustments will be signal-posted on this web location, alongside an update to the "Last Updated" field at the top of this document.

13. Contact Us

For general inquiries concerning this Privacy Policy, your personal rights, or to submit data management requests, please reach us through the official touchpoints below:

  • Primary Corporate Email: [email protected]

  • Administrative Management Email: [email protected]

  • Registered Corporate Address:

    The International Marketing Exchange Limited,

    601 Car Po Commercial Building,

    18–20 Lyndhurst Terrace, Central, Hong Kong

  • Retail Boutique Address:

    Shop C, G/F, Duke Wellington House,

    18 Wellington Street, Central, Hong Kong