THRIWA Privacy Policy

1. Scope and who is responsible

This Policy applies to personal information processed through thriwapoker.com, our inquiry and sample-request forms, email and other business communications, and our custom card manufacturing relationship with customers, suppliers and other business contacts.

Guangzhou Sanwa Poker Co., Ltd. ("THRIWA," "we," "us" or "our") is the organization responsible for the processing described in this Policy. In data-protection terms, we act as the personal information processor or data controller unless a contract states otherwise.

This Policy does not govern a third party's own website, platform or service, even if it is linked from or embedded in our website.

2. Information we collect

Information you provide

• Business and contact details: name, company, job title, business email address, telephone number, country or region, billing or delivery address and preferred communication method.
• Inquiry and project information: product type, specifications, quantities, target market, budget or quotation details, delivery requirements, messages and records of our communications.
• Files and creative materials: artwork, logos, layouts, packaging content, technical documents and other files submitted for feasibility review, proofing or production. These files may contain personal information if you choose to include it.
• Transaction and fulfilment information: purchase order, contract, invoice, payment status, bank remittance reference, tax or customs information, shipment details and recipient contact details. Payment account information is normally handled through banks or payment providers rather than stored on the public website.
• Marketing preferences: subscription, consent and opt-out records, together with your areas of business interest.
• Other information: information you voluntarily provide when requesting a catalog, sample, factory visit, support or another service.

Information collected automatically

When you use the website, we and our service providers may automatically collect IP address, browser and device type, operating system, language, approximate location derived from IP address, referring page, pages viewed, links selected, date and time, session identifiers, error logs and interactions with forms, videos or other content. We collect this information through server logs, cookies, pixels, local storage and similar technologies.

Information from other sources

We may receive business contact or transaction information from your employer or colleagues, distributors, sales representatives, logistics providers, payment providers, trade-show organizers, public company sources and other parties involved in your request or order. Where required, we will provide additional notice at the point of collection.

3. How we use personal information

We may use personal information to:

• respond to inquiries and provide quotations, samples, catalogs and product information;
• evaluate project feasibility, review artwork, develop proofs, manufacture custom products and provide quality-control or after-sales support;
• create and manage business records, purchase orders, contracts, invoices, payments, deliveries, customs documentation and warranty or dispute records;
• communicate about an inquiry, order, shipment, service update, security matter or policy change;
• operate, secure, troubleshoot, measure and improve the website and our services;
• understand demand, improve products and plan our B2B sales and manufacturing operations;
• send relevant marketing communications where permitted, and maintain opt-out or suppression records;
• detect fraud, misuse, security incidents and violations of our terms or rights;
• protect our business, customers, personnel, intellectual property and legal rights; and
• comply with legal, accounting, tax, sanctions, export-control, customs and regulatory obligations.

We do not use personal information to make decisions that produce legal or similarly significant effects based solely on automated processing.

4. Legal bases for processing

Where a law such as the EU GDPR or UK GDPR requires a legal basis, we rely on one or more of the following:

5. Cookies, analytics, chat and embedded media

Cookies and similar technologies help the website remember information about a browser or device, keep core features working, protect the site, understand performance and support visitor communications. The services currently used or loaded on the website may include:

• UEESHOP platform and content delivery services for page delivery, sessions, forms, language preferences and website functions. Cookies may include PHPSESSID, session_id, userSetLanguage and request or referrer-related identifiers.
• Cloudflare for network security, bot management and service availability. Its security cookies may include __cf_bm.
• MyShopTago analytics to measure visits, traffic sources, page performance and website interactions.
• Google Tag Manager and Google Consent Mode to manage tags and communicate consent choices. Google analytics or advertising services configured through these tools may receive device and activity data when enabled and permitted.
• Tawk.to live chat to provide online communication and support when you open or use the chat feature.
• YouTube or privacy-enhanced YouTube embeds to display video content. The video provider may receive device, usage and cookie information when a video is loaded or played.

These service names and cookies may change as the website is updated. Where required by law, non-essential technologies are used only after you make a choice through the cookie banner or preference tool. You can also limit cookies through your browser settings, although blocking necessary cookies may affect website functions. Cookie names, providers, purposes and durations should be shown in the cookie preference tool where available.

Our systems may not respond to every browser "Do Not Track" signal. Where legally required and technically supported, we process recognized opt-out preference signals, such as Global Privacy Control, as a request to opt out of sale or sharing for the associated browser or device.

6. How we disclose personal information

We may disclose relevant personal information to the following categories of recipients for the purposes in this Policy:

• Technology and business service providers: website hosting, content delivery, security, cloud storage, email, customer relationship management, analytics, translation, communications and IT support providers.
• Manufacturing and fulfilment partners: material suppliers, approved subcontractors, proofing or testing providers, freight forwarders, couriers, customs agents, warehouses and delivery partners where needed for a project.
• Financial and professional advisers: banks, payment providers, insurers, auditors, accountants, consultants and legal advisers.
• Corporate recipients: affiliates and a buyer, investor or adviser involved in an actual or proposed merger, financing, reorganization, sale of assets or similar transaction, subject to appropriate confidentiality measures.
• Authorities and other parties: regulators, courts, law-enforcement agencies, customs authorities or other parties when required by law or reasonably necessary to protect rights, safety and security.
• Recipients you direct: another party where you ask us to disclose information or give valid consent.

We require service providers to handle personal information only for authorized purposes and with appropriate safeguards. We do not sell personal information for monetary consideration. If optional advertising technologies are enabled, their data exchange may be treated as a "sale," "sharing" or targeted advertising under certain U.S. state laws; where applicable, you may opt out as described below.

7. International data transfers

THRIWA is based in China and serves customers internationally. Your personal information may therefore be processed in China and in other countries where our customers, service providers, banks, advisers, logistics partners or other recipients operate. Data-protection laws in those locations may differ from those in your country.

When you submit an inquiry, request a quotation, send project files or place an order, the information needed to handle that request will be transferred to and processed by us in China. We take reasonable steps to limit the information transferred, protect it during handling and require relevant service providers and business partners to use it only for authorized purposes. Where applicable law requires an additional notice or consent for a specific transfer, we will provide it at the relevant time.

8. How long we keep information

We retain personal information only for as long as reasonably necessary for the purpose collected, including to provide services, maintain business and opt-out records, resolve disputes, enforce agreements and meet legal, tax, accounting, customs and compliance requirements.

When retention is no longer necessary, we delete, anonymize or securely isolate the information, subject to technical backup cycles and legal requirements.

9. Information security

We use reasonable administrative, technical and physical safeguards designed to protect personal information. Measures may include access controls, role-based permissions, confidentiality requirements, system monitoring, secure transmission where supported, backups and service-provider reviews. No internet transmission or storage system is completely secure, so we cannot guarantee absolute security.

You are responsible for using secure channels and appropriate access controls when sending confidential artwork, credentials or commercially sensitive project files. Please contact us before sending unusually sensitive materials so that we can agree on a suitable transfer method.

10. Your privacy rights and choices

Depending on your location and the circumstances, you may have the right to:

• know whether and how we process your personal information;
• request access to or a copy of your personal information;
• correct inaccurate or incomplete information;
• request deletion or erasure;
• restrict or object to certain processing, including direct marketing;
• request data portability where applicable;
• withdraw consent without affecting processing already carried out;
• opt out of sale, sharing or targeted advertising where applicable;
• appeal a refusal where applicable; and
• complain to a competent data-protection authority.

To exercise a right, email info@gzsanwa.com with the subject line "Privacy Request" and describe your request and country or region. We may ask for information reasonably necessary to verify your identity and authority. Authorized agents may submit requests where permitted, but we may require proof of authorization and identity verification.

We will respond within the period required by applicable law. Some rights are limited by legal exceptions, including where information must be retained for a contract, legal obligation, security investigation or legal claim. We will not discriminate against you for exercising a privacy right.

11. Regional disclosures

European Economic Area, United Kingdom and Switzerland

If relevant data-protection law applies, the sections above describe the controller, purposes, legal bases, recipients, international transfers, retention criteria and rights associated with our processing. You may lodge a complaint with the data-protection authority where you live, work or believe an infringement occurred. Please contact us first if you would like us to address a concern directly.

California and other U.S. states

To the extent an applicable U.S. state privacy law covers our processing, the categories of personal information collected during the preceding 12 months are described in Section 2; the sources are you, your organization, website technologies, service providers, business partners and public business sources; the business purposes are described in Section 3; and the recipient categories are described in Section 6.

We do not use or disclose sensitive personal information for purposes that require a right to limit under California law. We do not have actual knowledge that we sell or share the personal information of consumers under 16. You may submit applicable requests to know, access, correct, delete, opt out or limit, and you may exercise an appeal right where provided, by using the contact method in Section 15. Browser-based choices apply to the browser or device used and may need to be repeated if cookies are cleared.

People's Republic of China

Where the Personal Information Protection Law of the People's Republic of China applies, we process personal information on a lawful basis and according to the principles of openness, necessity, good faith and data minimization. You may exercise applicable rights to know, decide, restrict or refuse processing, access or copy, correct, supplement or delete personal information. Where separate consent or another specific procedure is legally required, we will implement it for the relevant activity.

12. Children's privacy

Our website and services are directed to businesses and are not intended for children. We do not knowingly collect personal information from children under 16 through the website. If you believe a child has submitted personal information to us, please contact us so that we can investigate and take appropriate action.

13. External websites and embedded services

Our website may link to external websites or display third-party content, such as maps, videos, social-media features, downloadable documents or payment and logistics services. These providers may collect information directly from your browser or device under their own privacy policies. Review their policies and controls before using those services. A link does not mean that we control or endorse the provider's privacy practices.

14. Changes to this Policy

We may update this Policy to reflect changes in our services, technology, vendors or legal obligations. We will post the revised version on this page and change the "Last updated" date. If a change materially affects how we use personal information, we will provide additional notice or seek consent where required.

15. Contact us