Privacy policy
Privacy Policy
Last updated: September 1, 2026
This Privacy Policy describes how HONG KONG NEWBEST TRADING LIMITED, operating the FreeWink brand and the website https://freewink.us ("FreeWink," "we," "us," or "our"), collects, uses, discloses, retains, and protects personal information when you visit our website, purchase our products, communicate with us, or otherwise use our services (collectively, the "Services").
Our online store is powered by Shopify. Shopify and other authorized service providers may process personal information in connection with providing the Services.
For privacy questions or requests, contact us at support@freewink.us.
1. Personal Information We Collect
Depending on how you interact with FreeWink, we may collect the following categories of personal information.
Contact Information
This may include:
- Name
- Billing address
- Shipping address
- Email address
- Telephone number
- Other contact details you provide
Order and Transaction Information
This may include:
- Products purchased or considered
- Order details
- Payment status
- Shipping and delivery information
- Returns and refunds
- Warranty requests
- Customer service records
Payment Information
We collect or process information necessary to complete your transaction.
Complete payment-card details may be processed directly by Shopify, payment processors, financing providers, or other authorized payment-service providers. FreeWink may not directly receive or store complete payment-card information.
Account Information
If you create an account, we may collect:
- Account credentials
- Account preferences
- Purchase history
- Saved contact or delivery information
- Other information associated with your account
Device and Usage Information
We and our authorized service providers may automatically collect:
- IP address
- Browser type
- Device type
- Operating system
- Referring pages
- Pages viewed
- Website interactions
- Approximate location
- Cookie, pixel, or similar technology identifiers
Communications and Customer Support Information
We may collect information you provide when communicating with us through email, website chat, contact forms, customer support, surveys, reviews, or other communication channels.
This may include photographs, videos, serial numbers, product information, rider measurements, accessibility preferences, or other information you voluntarily provide when requesting product guidance, troubleshooting, warranty assistance, or customer support.
Please do not provide medical records or other sensitive information unless it is reasonably necessary for us to assist with your request.
Sources of Personal Information
We may collect personal information:
- Directly from you
- Automatically when you use our website
- From Shopify and other ecommerce service providers
- From payment or financing providers
- From shipping and fulfillment providers
- From customer support and communication services
- From analytics and advertising providers
- From other sources where permitted by applicable law
Information Required to Provide the Services
You are not generally required to provide personal information simply to browse our website.
However, certain information is required to complete an order, process payment, arrange delivery, provide customer support, handle a return, or respond to a warranty request. If required information is not provided, we may be unable to complete the requested transaction or service.
2. How We Use Personal Information
We may use personal information to:
- Process and fulfill orders
- Arrange shipping and delivery
- Process payments
- Process returns, refunds, cancellations, and warranty requests
- Provide customer service and product support
- Respond to questions and communications
- Communicate with you about orders, products, services, and account activity
- Detect, investigate, and prevent fraud, unauthorized transactions, security incidents, and unlawful activity
- Maintain, operate, and improve our website, products, services, and customer experience
- Understand how customers use our Services
- Perform analytics and measure website performance
- Personalize content and product recommendations where permitted
- Send marketing communications where permitted by law and consistent with your preferences
- Comply with legal, regulatory, tax, accounting, and contractual obligations
- Establish, exercise, or defend legal claims
- Protect the rights, property, safety, and security of our customers, FreeWink, and others
We will not use personal information for a materially unrelated new purpose without an appropriate legal basis or consent where required.
3. Shopify and Authorized Service Providers
Our online store is hosted and powered by Shopify.
We may also use third-party service providers to support our business, including providers of:
- Website hosting and ecommerce services
- Payment processing
- Financing and installment-payment services
- Shipping, fulfillment, warehousing, and logistics
- Customer support and communications
- Email and messaging
- Analytics and measurement
- Fraud prevention and security
- Advertising and marketing
- Cloud storage and information technology
- Accounting, insurance, legal, and other professional services
These service providers may process personal information as necessary to perform services for us or as otherwise permitted by applicable law and their applicable terms and privacy policies.
4. Payment and Financing Services
When you choose a payment, financing, or installment-payment option, personal information may be provided directly to the applicable payment or financing provider.
Eligibility decisions, credit assessments, payment schedules, financing terms, interest, fees, and other financing-related matters may be handled independently by the relevant provider and may be subject to that provider's separate terms and privacy policy.
FreeWink does not control the independent eligibility, underwriting, credit, or financing decisions of third-party providers.
5. Cookies and Similar Technologies
We and our authorized service providers may use cookies, pixels, tags, local storage, and similar technologies to:
- Operate the website and shopping cart
- Remember customer preferences
- Maintain security
- Measure website performance
- Understand website usage
- Provide analytics
- Measure advertising performance
- Support advertising and marketing where permitted
Where required by applicable law, we provide appropriate privacy choices or obtain consent before using non-essential cookies, pixels, or similar technologies.
You may control certain cookies through your browser or device settings. Disabling cookies may affect some website features or functionality. Where available, you may also manage your privacy and cookie preferences through the privacy controls provided on our website.
6. Marketing Communications and Advertising
Where permitted by applicable law, we may use your contact information to send information about FreeWink products, services, offers, or promotions.
You may unsubscribe from marketing emails at any time by selecting the unsubscribe link included in a marketing email, adjusting available account or privacy preferences, or contacting us at support@freewink.us.
Choosing not to receive marketing communications will not prevent us from sending transactional or service-related communications concerning your orders, account, delivery, returns, refunds, warranty requests, or customer support inquiries.
We will not use your personal likeness, photographs, videos, testimonials, or other identifiable customer-submitted media for advertising or promotional purposes without obtaining appropriate prior permission or consent where required.
Information submitted privately for troubleshooting, warranty assistance, or customer support will not automatically be treated as permission to use that information publicly or for advertising.
7. How We Disclose Personal Information
We may disclose personal information to:
- Shopify
- Payment processors
- Financing or installment-payment providers selected by you
- Shipping carriers
- Warehouses and fulfillment providers
- Customer service and communication providers
- Technology and cloud-service providers
- Analytics and measurement providers
- Advertising and marketing providers
- Fraud prevention and security providers
- Accountants, auditors, insurers, legal advisers, and other professional advisers
- Government authorities, regulators, courts, or law-enforcement agencies where disclosure is legally required
- Parties involved in a merger, acquisition, restructuring, financing, sale of assets, or similar corporate transaction
We do not disclose personal information for purposes unrelated to operating our business except as permitted or required by law.
Sale or Sharing of Personal Information
FreeWink does not sell personal information for monetary consideration.
However, depending on how advertising, analytics, cookies, pixels, or similar technologies are configured, disclosure of certain identifiers or website activity to advertising or analytics providers may be considered a "sale," "sharing," or use for "targeted advertising" under certain U.S. state privacy laws, even when no money is exchanged.
Where applicable law provides a right to opt out, eligible consumers may exercise that right by using the Your Privacy Choices link if it is displayed on our website, by using available website privacy controls, or by contacting us at support@freewink.us.
Where required by applicable law, recognized opt-out preference signals, including Global Privacy Control signals, will be treated as requests to opt out of applicable sale or sharing.
8. International Data Transfers
Because we operate an international ecommerce business and use service providers located in different countries and regions, personal information may be processed or stored outside your country or region.
These locations may have data-protection laws that differ from those in your place of residence. Where required by applicable law, we take reasonable steps designed to ensure that personal information transferred to authorized service providers is handled with appropriate privacy and security protections.
9. Data Retention
We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including:
- Fulfilling orders
- Processing payments
- Providing customer service
- Processing returns and warranty requests
- Maintaining transaction and business records
- Resolving disputes
- Preventing fraud
- Enforcing agreements
- Complying with legal, tax, accounting, contractual, and regulatory obligations
Retention periods may vary depending on the type of information, the purpose for which it is processed, and applicable legal requirements.
When personal information is no longer reasonably necessary, we may delete, anonymize, aggregate, or otherwise dispose of it as appropriate.
10. Data Security
We use reasonable administrative, organizational, and technical safeguards designed to protect personal information against unauthorized or accidental access, disclosure, alteration, loss, destruction, or misuse.
Our online store is powered by Shopify. Connections to Shopify stores are protected using Transport Layer Security, commonly associated with SSL and HTTPS encryption. This helps protect information transmitted between your browser and our website.
Payment information may also be processed through secure systems operated by Shopify and authorized payment-service providers. However, no electronic transmission, website, or storage system can be guaranteed to be completely secure.
11. Your Privacy Rights
Depending on where you live and whether applicable privacy laws apply to FreeWink, you may have certain rights regarding your personal information.
These rights may include the ability to:
- Request access to personal information we hold about you
- Request information about how personal information is collected, used, or disclosed
- Request correction of inaccurate personal information
- Request deletion of eligible personal information
- Object to or restrict certain processing where applicable
- Withdraw consent where processing relies on consent
- Opt out of marketing communications
- Opt out of certain sale, sharing, or targeted advertising where applicable
- Request limitation of certain uses or disclosures of sensitive personal information where applicable
- Receive information in a portable format where applicable
- Exercise applicable privacy rights without unlawful discrimination
Hong Kong Residents
Under Hong Kong's Personal Data (Privacy) Ordinance, individuals may have rights to request access to and correction of their personal data, subject to applicable legal requirements and exceptions.
United States Residents
Residents of certain U.S. states may have additional privacy rights under applicable state privacy laws. The specific rights available depend on your state of residence, the applicable law, and whether FreeWink is subject to that law.
California Residents
If you are a California resident and the California Consumer Privacy Act, as amended, applies to FreeWink and your personal information, you may have rights including the right to:
- Know or access categories and specific pieces of personal information collected about you
- Request deletion of eligible personal information
- Request correction of inaccurate personal information
- Opt out of the sale or sharing of personal information
- Limit certain uses or disclosures of sensitive personal information where applicable
- Receive information about categories of personal information collected, used, or disclosed
- Not receive discriminatory treatment for exercising applicable privacy rights
Where legally required, recognized opt-out preference signals may be treated as requests to opt out of sale or sharing.
Exercising Your Privacy Rights
To submit an access, correction, deletion, or other privacy request, contact support@freewink.us.
Please provide sufficient information for us to understand and respond to your request. We may need to verify your identity before processing certain privacy requests. Where permitted by applicable law, an authorized agent may submit a request on your behalf, subject to appropriate verification.
To opt out of data processing that may be considered a sale, sharing, or targeted advertising under applicable U.S. state privacy laws, use the Your Privacy Choices link if it is displayed on our website, use available website privacy controls, or contact us at support@freewink.us.
We will respond to eligible privacy requests within the period required by applicable law. If applicable law provides a right to appeal a decision concerning a privacy request, instructions for submitting an appeal will be included in our response.
12. Children's Privacy
Our Services are intended for adults and are not directed to children under 13.
We do not knowingly collect personal information from children under 13.
Our mobility products may be used under appropriate adult supervision, but purchases and customer accounts should be managed by an adult or a person legally capable of completing the transaction.
If you believe a child under 13 has improperly provided personal information to us, please contact us at support@freewink.us. We will review the request and, where appropriate, delete the information.
13. Third-Party Links and Services
Our website may contain links to websites, applications, payment providers, financing providers, social media services, or other services operated independently by third parties.
We do not control and are not responsible for the privacy practices, security practices, availability, or content of independent third parties.
We recommend reviewing the applicable third party's privacy notice before providing personal information.
14. Changes to This Privacy Policy
We may update this Privacy Policy periodically to reflect changes to our business, products or Services, technology, service providers, legal requirements, or privacy practices.
When changes are made, the updated Privacy Policy will be posted on this page with a revised "Last updated" date. Where required by applicable law, we may provide additional notice of material changes.
We encourage you to review this Privacy Policy periodically.
15. Contact Us
For questions about this Privacy Policy or requests concerning your personal information, contact:
HONG KONG NEWBEST TRADING LIMITED
Operating the FreeWink brand
Registered business address:
ROOM D5, 5/F., KING YIP FACTORY BUILDING
NO. 59 KING YIP STREET
KWUN TONG, KOWLOON
HONG KONG
Email: support@freewink.us
Website: https://freewink.us
Customer Support Hours:
Monday–Friday, 9:00 AM–6:00 PM Pacific Time (PT)
Typical Response Time:
Within 1 business day