Alliance have provided below an example Terms of Use on the Kelo-cote local website. This can be used as a basis for drafting terms of use if the Distributor does not have a current Terms of Use that the site can direct the end consumer to.

These terms and conditions have been reviewed on the basis of English Law for Alliance and Alliance can accept no liability to the distributor that arises as a result of the Distributor not having them checked by local legal advisors.

These terms and conditions are a contract between Distributor and the end consumer and not between the end user and Alliance and therefore the end user will not have a right to a refund directly from Alliance as a result of any transactions on the site unless provided for under local consumer legislation.



The information on this site is intended to be useful and informative for customers and investors in Hong Wo Pharmaceutical Company Ltd. will use all reasonable care to ensure that the information is accurate and up to date. However, Hong Wo Pharmaceutical Company Ltd cannot guarantee the information is accurate and it shall not be liable for any losses or damage that anyone may suffer as a result of relying on this information. The information may be changed by Hong Wo Pharmaceutical Company Ltd at any time.

Please also note that the contents of this website do not constitute an invitation to invest or otherwise deal in shares of Hong Wo Pharmaceutical Company Ltd and Hong Wo Pharmaceutical Company Ltd accepts no responsibility for the contents of any other websites to which the Hong Wo Pharmaceutical Company Ltd website has links.

Should you choose to gain access to this site from any location other than the HKSAR, China, you do so by your own choice and are responsible for compliance with all applicable local laws.


The copyright in the material contained in this Web site, and any trademarks and brands included in that material belong (unless otherwise stated) to Hong Wo Pharmaceutical Company Ltd. All rights are reserved. Permission is granted to users to electronically copy or print portions of this site solely for their own personal, non-commercial use. Any other use of materials on this site without prior written consent is strictly prohibited.

All product names, logos and devices displayed on this website are either trade marks and/or registered trade marks of Hong Wo Pharmaceutical Company Ltd, or trade marks and/or registered trade marks owned by third parties and used under licence by Hong Wo Pharmaceutical Company Ltd, unless otherwise noted. Trade marks owned by or licensed to Hong Wo Pharmaceutical Company Ltd are indicated by an appropriate trade mark symbol (® or ™), or are set off from surrounding text (for example by use of CAPITALS). Hong Wo Pharmaceutical Company Ltd also owns goodwill and/or reputation associated with these trade marks, unless otherwise noted.

The use or misuse of these trade marks or any other materials by third parties, except as permitted herein, is expressly prohibited and may be in violation of copyright law, trade mark law, the law of passing off, the laws of slander and libel, the laws of privacy and publicity, and communications regulations and statutes. Please be advised that Hong Wo Pharmaceutical Company Ltd actively enforces its intellectual property rights to the fullest extent of the law.


  1. 1. Controller

    1. We are Hong Wo Pharmaceutical Company Ltd (referred to as “Hong Wo Pharmaceutical Company Ltd”, “we”, “us” and “our” in this Privacy Policy), a company incorporated in HKSAR, China with company registration number 30281642-000-07-20-2.
    2. We are the data controller in relation to the processing of the personal information that you provide to us. Our contact details are as follows:
      1. Address: Rm 2010-11, Wayson Commercial Bldg, Connaught Road West, Sheung Wan, Hong Kong
      2. Telephone number: (852) 2547-5633
      3. Email address: (please include “Personal Data Request” in your subject heading to ensure it receives the correct attention).
  2. 2. Overview

    We use personal data in relation to individuals who are not employed in our group for the following:

    1. Marketing of our products (Marketing)
    2. Fulfilling orders placed with us for our products (Order Processing)
    3. Assisting with customer queries or reports of problems relating to our products (including adverse events) and, keeping records required by law (Product Issues)
    4. Dealing with applications for employment (Job Applications)
  3. 3. What information will we collect from you?

    1. We may collect personal information about you from a number of sources, including information you provide via our website, from telephone discussions with you (including call recording), from written information you have sent to us and from other communications.
    2. We may also verify or correct your information from publicly available sources such as the electoral register.
    3. Personal data may be collected by us directly from you; or you may direct third parties to submit or share personal data about you with us. The types of personal data we may
      collect, and process include:

      1. personal contact information, such as your name, email address, mailing address, and phone number;
      2. business contact information, such as your name, job title and employer name, email address, mailing address, and phone number;
      3. healthcare/medical professionals’/researchers’ information including information about their work and research;
      4. (Product Issues only) medical or other health information that you choose to provide to us (whether in writing or via telephone), including information about any adverse effects you may suffer having used medicinal or other products, any other treatments you are undertaking for medical conditions and medications you may be taking; and.
      5. (Job Applications only) information provided by job applicants, including but not limited to education, salary, previous employment and other details an applicant chooses to provide to us when applying for a job.
  4. 4. Purposes/legal basis for processing

    1. We, or our business partners who act on our behalf, will use your data:
      1. Marketing: in relation to promotion or marketing activities surrounding or in relation to our business or our products, via email or in writing where you have indicated that you wish to receive such communications; We rely on your consent for this purpose.
      2. Product Issues: in relation to any medical issues, medical information enquiries or adverse events which you or your healthcare professional have reported to us, by email, in writing or via telephone via email; We process this information:
        1. with your consent, or in your vital interests, in order to deal with the query or respond to the problem identified; and
        2. to the extent we are legally required to keep records of the issues do so by any regulatory authority (including the MHRA) in order to comply with a legal obligation to which we are subject; and
      3. Job Applications: in relation to any speculative communications sent by you for job applications/vacant positions, by email or in writing to the address provided by you in relation to the same; we rely on your consent for this purpose.
    2. We will also anonymise and aggregate your data with others:
      1. for market research purposes;
      2. to help us to administer accounts, services and products which we offer;
      3. to publish trends; and/or
      4. to improve the usefulness and content of our services.
    3. We will only process personal data categorised under EU Regulation 2106/679 (GDPR) as “special categories of personal data” where we are required to do so in order to fulfil our obligations in relation to (i) the reporting of adverse events communicated to us by you, other members of the public, your healthcare professional or pharmacists; (ii) the receipt of medical information enquiries from members of the public in relation to our products. For these purposes “special categories of personal data” shall mean: personal data revealing racial or ethnic origin and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
  5. 5. Recipients of the data

    1. Other members within the Hong Wo Pharmaceutical Company Ltd Group (where such members carry out functions which support the business of Hong Wo Pharmaceutical Company Ltd) will be entitled to use your personal data for any of the purposes set out in this privacy policy.
    2. It may also be the case that we choose to share your data with third parties with whom we have business or marketing relationships from time to time for to use your personal data, for and on our behalf, for any of the purposes set out in this privacy policy. If you do not wish us to do this, please either: (i) tick the box when registering your details or on the order confirmation screen or (ii) make this clear in any writing or telephone communications with us which contain, or would in accordance with this privacy policy lead to the collection of, any of your personal data.
    3. We will also provide your personal data to the extent required by law or regulation to various legal and competent authorities including but not limited to:
      1. Medicines & Healthcare products Regulatory Agency and/or the European Medicines Agency, in relation to our obligation to report any adverse events;
      2. Her Majesty’s Revenue and Customs, in relation to any payments received by us for the sale of our products to third parties; and/or
      3. the police and other law enforcement agencies arising from any matters including counterfeit medicines.
  6. 6. International transfers

    We will not transfer personal data to a country which is outside the European Economic Area unless:

    1. the country or recipient is covered by an adequacy decision of the Commission under GDPR Article 45;
    2. appropriate safeguards have been put in place which meet the requirements of GDPR Article 46 by us; or
    3. one of the derogations for specific situations under GDPR Article 49 is applicable to the transfer. These include (in summary):
      1. the transfer is necessary to perform, or to form, a contract to which we are a party with you or, in your interests, a third party;
      2. the transfer is necessary for the establishment, exercise or defence of legal claims;
      3. you have provided your explicit consent to the transfer; or
      4. the transfer is of a limited nature and is necessary for the purpose of our compelling legitimate interests.
  7. 7. Retention

    1. We, or our business partners, retain personal data for certain periods which are dependent upon the reason for collection, details of which are as follows:
      1. Order Processing: for such time as is required in order to fulfil the order placed and also track any returns of such products – we would usually expect this to be a period of 45 days after despatch of the products;
      2. Product Issues:
        1. fulfilling regulatory obligations in relation to adverse event reporting: for the entire period that the product is available for sale;
        2. medical information queries: for 60 days after the date upon which the query has been resolved;
      3. Job Applications: CVs and other job application documentation are retained for a period of 12 months from the date of receipt;
      4. Marketing: for such time as consent to our use of the information remains in force.
  8. 8. Protection of your data

    As part of our business, we maintain stringent security measures designed to protect your personal data. This may include following certain procedures, physical or technological protection and may include encryption of data or asking you for proof of identity before we disclose your personal data to yourself.

  9. 9. Accuracy of your data

    We will endeavour to ensure that the data we hold about you will be accurate and up to date. You can check the data that we hold about you by e-mailing us. If you find any inaccuracies in such data, please notify us and we shall delete or correct it promptly.

  10. 10. Your rights

    1. If you are based within the UK or the EEA or within another jurisdiction having similar data protection laws, in certain circumstances you will have the following rights:
      1. right to access: the right to request certain information about, access to and copies of the personal data about you that we are holding (please note that you are entitled to request one copy of the personal data that we hold about you at no cost, but for any further copies, we reserve the right to charge a reasonable fee based on administration costs);
      2. right to rectification: the right to have your personal data rectified if it is inaccurate or incomplete;
      3. right to erasure/“right to be forgotten”: the right to withdraw your consent to our processing of the data (if the processing is based on your consent) and the right to request that we delete or erase your personal data from our systems (however, this will not apply if we are required to hold on to the information for compliance with any legal obligation or if we require the information to establish or defend any legal claim);
      4. right to restriction of use of your information: the right to stop us from using your personal data or limit the way in which we can use it;
      5. right to data portability: the right to request that we return any information you have provided in a structured, commonly used and machine-readable format, or that we send it directly to another company, where technically feasible; and
      6. right to object: the right to object to our use of your personal data including where we use it for our legitimate interests or for marketing purposes.
    2. If you consider our use by us of your personal data to be unlawful, you have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office. Please see further information on their website:
  11. 11. Requirement/consequence

    1. You are not required under statute or contract to provide us with any personal data.
    2. If you do not provide personal data to us:
      1. (in relation to Order Processing): we will not be able to take or fulfil any orders you may wish to make for our products;
      2. (in relation to Product Issues): validly respond to or take necessary actions in relation to any adverse events or other Product Issues reported by you; and/or
      3. (in relation to Job Applications): to process and/or consider you for any job you have applied for.
  12. 12. Automated decision making

    1. We do not make decisions based solely on automated data processing, including profiling.
  13. 13. Cookies and e-mail

    1. We also use “cookies” to gather information regarding the use of our site. A cookie is stored on your computer’s hard drive by you and enables quick access to the site and provides us with certain information about your use of websites generally. You can amend the settings of your Internet browser to prevent automatic acceptance of cookies.
    2. If you have given consent for us to do so, then we may from time to time use e-mail to contact you to notify you of new products or services, which we may from time to time supply. However, please contact us at any time by e-mail should you wish to change your decision either way.
  14. 14. Call monitoring

    We reserve the right to monitor all forms of communication whether electronic or otherwise with you for the purposes of development of the service and compliance with our policies and procedures. We may also use such monitoring to provide evidence of transactions which we have entered into with you.