Cody Outdoor International (Hong Kong) Limited (“Cody”)   respects your right to privacy. We are sensitive to the concerns that our clients, customers and online users may have with regards to the confidentiality, security and use of their personal information. Cody is committed to the protection of your personal information and would like to reassure you of our position on this matter. Cody has developed this Privacy Policy in line with the ‘Data Protection Principle’ (“DPP”)   as established under the Personal Data (Privacy) Ordinance (the “Ordinance”).  

The purpose of this Privacy Policy is to tell you what type of information we collect, how we may use that information, whether we disclose it to anyone, the opportunities you have to access and correct the information we hold, and how you may make a complaint about a breach of the DPP.

Occasionally, Cody may, in our discretion, make changes to the Privacy Policy. We encourage you to check this policy regularly as this policy may change from time to time. All new and/or revised Privacy Statement take effect immediately and apply to your use of the Site & Social Media from that date on. Your continued use of the Site & Social Media after new and/or revised Privacy Statement becomes effective indicate that you have read, understood, and agree to those provisions. If you have any suggestions or concerns that are not addressed in this policy, please contact us. Please take some time to read through this policy and understand our position on privacy before you provide us with any personal information.

Personal information we may collect  

Cody will only collect personal information about you if it is reasonably necessary for our functions and activities. When submitting information to us, we may collect details such as your name and email (but not limited to), which may personally identify you. Some of this information is essential for us to be able to identify accurately who is using our services so that we may be able to respond to your requests and, as such, is indicated by mandatory fields. Mandatory information requirements are clearly identified and are denoted by an asterisk (*). When submitting a form, you will also be prompted if any mandatory data has not been completed. Other types of information are collected to help us provide better services. Information of this type is optional – you need only fill it in if you wish to do so.

You may be asked to provide Cody with personal information when you: 

  • Send us your comments, suggestions or other information;
  • Report a technical problem;
  • Request sales and advertising information;
  • Subscribe to a newsletter;
  • Enter a competition, promotion or event; or
  • Order products or services using our website (or otherwise).

We also collect personal information in the normal course of business through meetings, phone calls, letters, faxes and emails, as well as via third party credit agencies, mailing lists, advertisers, commercial agreements, documents and dealings. All this information is subject to the DPP.

In addition, we may also collect information about you if you:

  • post comments or submit content which is publicly available which contains information about you – this may include information such as your name, user name, likes, tweets, status, profile information and pictures; and
  • log-in to or access one of our sites, services or activities through a third party social media service or connect one of our sites, services or activities to a third party social media service – this may include information such as your user ID, user name, information you have disclosed via the social media service and information or content you have permitted the social media service to share with us (for example your profile picture, email address, followers or friends lists).

When you engage in the activities described above, you are authorising us to collect, store, use and disclose such information and content in accordance with this policy. Cody will not collect sensitive information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or details of health, disability or sexual activity or orientation. However if we do collect sensitive information we will do so in compliance with the DPP. You have the option of not identifying yourself or dealing with us using a pseudonym in relation to particular matters. We will endeavor to make it clear where you may withhold your name or use a pseudonym.

Non-personal information we may collect

Cody may also collect non-personal information, such as your IP address or your browsing patterns, by using cookies on its websites. Cookies do not personally identify you, but assign a unique number to the visitor to track user navigation and customise site information to further improve the user experience on an aggregate and anonymous basis. Cookies can make using Cody’s website & Social Media easier and better – for example by storing information about your preferences on a website & social media. The use of cookies is an industry standard and you will find most major websites & social media use them. One way to prevent the use of cookies is to activate the facility which is available in most web browsers that enables the user to deny or accept cookies.

How we use your information

If we hold personal information about you that was collected for a particular purpose, we will not use or disclose it for another purpose unless: (a) you consent; (b) you would reasonably expect us to use or disclose it for that other purpose; or (c) it is required or authorised by law or a court/tribunal order. Cody will not rent or sell your personal information to others.

Cody generally uses personal information, and you consent to us using your personal information, to:

  • provide you with products or services you have requested;
  • provide you with relevant advertising and promotional material;
  • conduct promotions or competitions, including Joint Activities;
  • help Cody manage and enhance its services, websites & social media;
  • communicate with you; or
  • send you ongoing information and promotional material about opportunities, services and products (relating to our business or a third party business) in which Cody believes you may be interested.

We may also share your personal information with our Related Companies, Partners and others, as referred to below. The information and feedback you provide through our websites & social media may be used to identify ways of improving the websites & social media and how we can make them more effective for your use.

Opting in or out and unsubscribing

At the time we collect information from you, you may be asked to “opt-in” to consent to us using or disclosing your personal information, other than in accordance with this policy or any applicable law. For example, you may be asked to “opt-in” to receive further information or communications from us, our Related Companies or our Partners, as referred to below.

You will be given the opportunity to “opt-out” or unsubscribe from receiving communications from us, our Related Companies or our Partners in accordance with this policy. Alternatively, you may contact us at the address below to “opt-out” of, or unsubscribe from, any future communications. Cody will use reasonable endeavours to comply as quickly as possible with that request.

If you receive communications purporting to be connected with us or our services that you believe have been sent to you other than in accordance with this policy, or in breach of any law, please contact us.

Disclosure of your personal information

You consent to Cody disclosing your personal information to the authorised personnel of Cody and to:

  • our Related Companies;
  • our Partners;
  • third parties which we engage with in Joint Activities;
  • parties involved in a business sale or restructure, as referred to further below.

Related Companies

You acknowledge and agree that we may collect and share personal information about you with related bodies corporate, joint venture partners and affiliated companies and businesses (Related Companies) so we can provide you with the products and services you request and bring you information about products and services we offer. We will inform our Related Companies that information shared with them must be collected, used, disclosed and stored in accordance with this policy.


In some cases, we contract with other companies or individuals to work with us or provide goods or services for us (Partners) including business partners, distributors, suppliers and advertisers. Examples of the goods and services our Partners may provide are electronic communications, data storage, deliveries, direct marketing services, market research, prizes, advertising, public relations, debt collection, legal advice, accounting and audits. We provide our Partners only with such information about you as they need to provide their goods or perform their services and we impose strict requirements of security and confidentiality on them in how they handle your personal information. We make it clear that our Partners are not permitted to use your personal information other than as permitted under this policy.

Joint Activities

We may jointly conduct activities, such as competitions and other promotions, with sponsors, prize providers and other third parties (Joint Activities). We may share personal information you submit in connection with the Joint Activities with the third parties involved and you consent to us doing so. Information shared with such third parties will be collected, used, disclosed and stored in accordance with the third parties’ privacy policy. Terms and conditions for Joint Activities will inform you that your information is being shared and the terms upon which it may be used by the third party.

Sale of business

If we sell all or part of our business, merge with another company or business, or restructure our business, we may transfer or disclose your personal information to the parties involved in the transaction.

Access and correction

Cody will take reasonable steps to ensure your personal information is accurate, up to date and complete.


Where Cody holds personal information about you, we will provide you with access to the information on request within a reasonable time. In that case, where required, we will give you written notice setting out the reasons for our refusal and the mechanisms available if you wish to complain about our refusal.

We will also give you access to the information in the particular manner you request if it is reasonable and practicable to do so. If we do not give you access in the manner requested, we will take reasonable steps to give you access in a way which meets both your needs and ours. We may also impose a reasonable charge for giving you access to your personal information.


If Cody is satisfied that your personal information is inaccurate, out of date, incomplete, irrelevant or misleading, we will take reasonable steps to correct your personal information. In addition, if you request us to correct your personal information, we will take reasonable steps to do so within a reasonable time. If you request it, we will also take reasonable steps to notify any other Related Companies or Partners of the changes if we have previously provided your personal information to that entity. There is no fee for correcting your personal information. We may require you to provide particulars of your identity before providing you with access to, or making changes to, your personal information.


Cody will take reasonable steps to protect your personal information from misuse, interference, loss, unauthorised access and modification or disclosure. Any personal information that we receive is securely stored and access is restricted to authorised personnel of Cody, its Related Companies and Partners, as described above. Please contact us immediately at the address listed below if you become aware of any unauthorised use of your personal information.

Third party websites

You may follow links on our sites & social media to other third party websites (Other Sites). We encourage you to always read the privacy policies on those Other Sites as they may also collect your personal information. Cody is not responsible for the information on, and the contents of, those Other Sites or their practices or policies.

Contact us

If you: (a) have any questions or comments on this policy; (b) would like a hard copy of this policy; (c) would like to know how we received your personal information; or (d) would like to make a complaint about a breach of the DPP or the use or disclosure of your personal information, then please contact Cody at:

Email us at
Telephone us on 2235 3900
or Write to us at:

1401A Lee Garden Two
28 Yun Ping Road
Causeway Bay
Hong Kong



The effective date of this Privacy Policy is November 1, 2022.  This Privacy Policy is written in English. If there is any conflict, inconsistency or ambiguity between the English version and any translated version of this Privacy Policy, the English version shall prevail.