PRIVACY POLICY

We, Wineworld Limited (“Wineworld”), respect personal data and are committed to fully implementing and complying with the data protection principles and all relevant provisions of the Personal Data (Privacy) Ordinance of the Hong Kong Special Administrative Region (“the Ordinance”).  This Privacy Policy Statement is intended to explain our privacy practices. 

“Personal data” refers to any data which directly or indirectly identifies you as an individual, or is capable of doing so. This Privacy Policy discloses the privacy practices for www.wineworld.com.hk (“Website”). This Privacy Policy governs the use and collection of information collected from you on the Website. Please read this Privacy Policy carefully so that you understand our privacy practices. In addition, please review our Terms of Use, which also govern your use of the Website and which incorporate this Privacy Policy by reference.

This Privacy Policy may be modified at any time and from time to time. The date of the most recent revision will appear on this page. You agree that your use of the Website is subject to this Privacy Policy as then in effect. Continued access to the Website by you following any modification to this Privacy Policy will constitute your acceptance of this Privacy Policy as modified. If you do not agree to be bound by all of the terms set forth below, you should stop using the Website.

1. What Information Is Collected?

A. Personal Identification Data

To take advantage of certain optional features or functions of the Website, we may ask you to provide us with certain personal identification data. Personal identification data is information that could reasonably be used to identify you personally. 

We collect and use personal data that we believe is necessary to conduct our business with you.  The types of personal data we collect may include, but is not limited to:

• i.                Contact information such as your name, email address, mailing address, telephone number, and fax number;
• ii.               Billing information such as your credit card number, bank account information, and billing address;
• iii.              Demographic information such as age, gender, nationality, martial status, preferences, education background, and employment history.  

Supply of personal data to Wineworld is non-obligatory, but failure to do so may result in Wineworld unable to conduct business and/or provide information to you.

The personal data which we may refer to here as "PID”. After creating a profile on the Website, if you wish to change any of your profile information, you may do so by logging in “Member Sign In” and edit to update your contact information.

Authorized Purposes and Offers. Personal identification data that you voluntarily submit may be used for the purposes authorized when it was submitted. For example, if you submit PID to request services or content, the information that you submit may be used to fulfill your request.

Administrative Purposes. We may use PID you submit to contact you for internal administrative purposes such as site administration, troubleshooting, or relating to your use of the Website or content you post on the Website, or in our discretion to notify you of major changes to the Website or this Privacy Policy.

Service Providers and Third Parties. Personal identification data may be shared with third parties as disclosed in this Privacy Policy or at the time you provide your information. Third parties that provide support for the operation of the Website or features thereof may also have access to such information. We may also share PID we have about our users with third parties so that the third parties can send you information and special offers, unless you choose to opt out from such sharing by clicking on the unsubscribe link included in such emails. We may also combine information about our subscribers with PID you submit on the Website.

In any case, we will use the information only as permitted by law.

B. Non-Personal Identification Data

Cookies. We may use collected information to create aggregate statistics about activity on and visitors to Wineworld’s Website.  Like many website operators, we sometimes make use of browser "cookies." to gather information through the use of it.  A "cookie" is a small piece of information that are, on an instruction from a website, automatically stored on a person’s web browser on their computer.  We use it to assign each visitor's computer a unique, random numerical identification code that resides in a designated file on your computer. Our cookies do not automatically collect personal identification data. We may use information collected from cookies to recognize your browser when you visit us, to facilitate easy login, to attempt to personalize our services for each user, to sequence ads and offers in a series and to track page usage and paths, to help serve advertisements, or to facilitate your ability to navigate the Website. We may link the cookie to PID you submitted or other information we collect. Separately, third party companies that serve advertisements on the Website may use cookies, to collect information about your visits to this Website and other websites.

If you wish to prevent access to cookies by any website you can configure your web browser to refuse all cookies or to indicate when a cookie is being set by choosing this option in the preferences or menu options in your browser. However, if you disable cookies, you may not be able to use certain optional features or functions of the Website.

Log Files. Like most websites, we use tracking programs that collect information about log files, which may include browser types, Internet service providers (ISPs), referring/exit pages, platform types, date/time stamps, number of clicks, and Internet protocol (IP) addresses. An IP address is a number that is automatically assigned to your computer whenever you access the Internet, which web servers use to identify where to send the information your computer requests. We may use IP addresses for a number of purposes, such as system administration, to report aggregate information to our business partners, or to audit the use of the Website. We may disclose such non-personal identification data, such as aggregated statistics, to third parties for a variety of purposes, including describing our services, marketing, and improving the experiences of visitors to the Website. The information that we collect regarding log files is not linked to personally identification data.

2. How is the Information Collected Used, and How Can I Opt Out?

Facilitating Use of the Website Services and Customizing Content, Advertising and Offers. We may use information collected from cookies and other tracking technology to recognize your browser when you visit the Website and may attempt to personalize the Website for each user, to sequence ads and offers in a series and to track page usage and paths. We may also use collected information to allow editorial content and/or advertising on the Website to be targeted to groups of users for whom it is most pertinent. This means that users see editorial content and/or advertising most likely to interest them. In connection with these uses, we may disclose information to third parties.

Statistical Analysis. We may use collected information to create aggregate statistics about activity on and visitors to the Website, including the number of return visits to the Website or our advertisers' websites, the number of unique visitors that have viewed or "clicked" a particular ad or visited a particular web page and how much time is spent on each page of the Website. We may also create aggregate demographic statistics. We may use these aggregate statistics to measure interest in various areas of the Website, to better design the Website and to improve our marketing strategy and services. We may share the aggregate statistical information with third parties. We may also use third parties to assist us with collecting and using these aggregate statistics.

C.  Direct Marketing

Wineworld intends to use your personal data for direct marketing and your personal identification data may be carried out by us or shared with or disclosed by us (or by an agent on behalf of Wineworld), and for such purposes your personal data held by us may be provided to our other business partners for their use for direct marketing at the time you provide your information.  The intended kinds of personal data to be used and the intended classes of marketing subjects are specified below.  However, we may not so use or provide your personal data unless exempted by the Ordinance or we have received your consent or unless you choose to opt out from such sharing by written notice here to us. 

In any case, we will use the information only as permitted by law. 

For the above direct marketing use, Wineworld intends to:

• ·       use your name, contact information and demographic information; and
• ·       market or promote our services and related events and activities offered or arranged by us for Members.

You can always opt-out free of charge by contacting Wineworld if you no longer wish any of your personal data to be used in any of the described direct marketing purposes.  

D. Disclosures Required by Law.

Personal data supplied to Wineworld will be kept confidential.  However, certain uses of collected information may involve disclosure to third parties. In addition, we may disclose collected information when required to do so by law, or when doing so is reasonably necessary: (1) in compliance with the law or legal process; (2) in response to any claims; (3) for the purpose of protecting and defending the rights, property or safety of the Website, and its subsidiaries and affiliates, as well as our users or the public; or (4) for the purpose of protecting against misuse or unauthorized use of the Website. In addition, collected information may be disclosed as part of any bankruptcy, merger, sale, transfer of company assets or acquisition.  Your personal data may also be provided to other entities for fulfilling the purposes for which it was collected (subject to any consent requirement relating to “Direct Marketing” above), and to our business partners for direct marketing use as described in “Direct Marketing” above.   Other disclosure of your personal data will only be undertaken after we have obtained your prescribed consent, or as may be required by law.

3. Third Party Sites and Content

During your visit to the Website, you may view as part of a frame that includes our content, certain content and websites that are actually created, operated, owned and/or hosted by a third party or third parties. You may also see links on the Website to other websites. We are not responsible for the privacy practices or the content of third parties. You should check the applicable privacy policies of those third parties when providing personally identifying information. In addition, certain sections of the Website may have their own, specialized privacy policies, for example because they are part of a social network or hosted by a third party. You should check the applicable privacy policies of those sections and/or of such social networks.

E. Data Retention

Unless there is a specific legal requirement for us to keep the data, we will take all reasonably practicable steps to erase your personal data that is no longer required for the purposes for which the data was originally collected.

F. Commitment to Data Security

4. Is My Information Protected?

We use reasonable administrative, technical, personnel and physical measures to safeguard personal identification data against loss, theft and unauthorized use, disclosure or modification. As effective as our security measures are, no security system is impenetrable. Moreover, we cannot guarantee that information that you supply will not be intercepted while being transmitted to us. PID may also be stored on computers of third parties that provide technical support for the operation of the Website or who otherwise have access to your PID as disclosed in this Privacy Policy. We do not control the security measures used by such third parties.

Unfortunately these security measures are not 100% secure and it is possible that others may intercept the information you are sending. 

We will of course take such steps as are appropriate to ensure the security of such information while it is held by us.  This will include password protection and other electronic security methods as well as physical security methods, where appropriate, to help ensure that the information can only be accessed by our authorized employees, which employees shall be made aware of the terms of this statement and our duties to you under it. 

If you have any more questions, please email us at info@wineworld.com.hk