Privacy Policy

The protection of privacy in relation to your personal data is a priority of Winestry’s operations. We respect privacy and are committed to fully implementing and complying with the Data Protection Principles and all relevant provisions of the Personal Data (Privacy) Ordinance (Cap. 486, “PDPO”), and for the purpose of this policy (“this Privacy Policy”), (i) “Winestry”, “we”, “our”, “us” or “ours” is a reference to [Great Wall Belt & Road International Limited] which establishes, develops and operates the e-Store under the brandname “Winestry” together with, for the purpose of this Privacy Policy, our associated parties involved in the collection of personal data and bound by this Privacy Policy, (ii) “you”, “your” or “yours” is a reference to the person who accesses to or uses the Website and/or the Mobile App or otherwise may provide certain personal data to us, and (iii) “personal data” has its meaning ascribed to it under PDPO. Unless otherwise expressly defined in this Privacy Policy, words and expressions defined in the User Terms and Conditions, of which this Privacy Policy form part, as updated from time to time and is shown at [URL], have the same meanings when used in this Privacy Policy.

• Purpose of Collection of Personal Data

  You need not provide any personal data in order to access to, visit or browse our website (the “Website”) and/or download or use our mobile app (the “Mobile App”), but we may use cookies to store and track information about you and your preferences. When you participate in, access, browse, sign up or use any of our services, activities or online content on, in or through the Website and/or the Mobile App, including without limitation products and services of the Sellers and our suppliers, service providers and business partners (collectively referred to as "Services"), personal data is collected from you to enable us, the Sellers or our suppliers, service providers or business partners to provide you with the Services. You may decline to provide us with the requested personal data, but in such case we may not be able to provide the Services to you. By submitting your personal data to the Website and/or the Mobile App, you consent to the use by us of that data as set out in this Privacy Policy.

  Personal data collected from you may be used by us for:

  • identifying you and any accounts or records of you with us;
  • enabling the provision of the Services to you;
  • conducting identity verification and/or credit or know-your-client checks;
  • determining and verifying your eligibility for discounts and promotions on the Services;
  • processing applications or renewal applications for the Services or our business partners’ products and services on your behalf (see section “Direct Marketing” below);
  • processing enquiries or claims associated with the Services;
  • processing of payment instructions or collection of amounts outstanding from you in relation to the provision of the Services;
  • order processing, billing and fulfilment;
  • creating and maintaining your logged-on identity so that you may use the Website, the Mobile App, software and other platforms without having to log-on again;
  • enabling us to store your personal data so you do not have to re-enter it each time you purchase a product or service or renew the subscription of a product or service;
  • direct marketing of the Services (see section “Direct Marketing” below);
  • direct marketing of the products and services of our business partners (see section “Direct Marketing” below);
  • designing services for you;
  • conducting research, statistical analysis and behavioural analysis;
  • conducting program viewership survey and analysis;
  • customer profiling and analysing your purchasing preferences;
  • making suggestions and recommendations to you and other users of our Services or goods and services that may interest you or them;
  • customising the Website and/or the Mobile App and their content to your particular preferences;
  • provisioning of customer services;
  • handling your complaints and enquiries, and handling any claim, action and/or proceedings against us or any party;
  • fraud prevention and detection;
  • auditing purposes;
  • making such disclosures as required by applicable laws, rules and regulations; and
  • any other purposes directly related to the purpose for which the personal data were originally collected.

• Types of Personal Data Collected

  At times, you may be required to give your personally identifiable information including without limitation:

  • your personal information and contact information such as your name, gender, date of birth, identity card number, telephone number, social media contact, email address, residential address, mailing address, and billing address;
  • your business information such as company name, occupation and business title;
  • your account details or user accounts with respect to your settlement of amounts due from you;
  • your household income range, and personal interest;
  • IP address, real-time geographic location data, browser settings, browsing records, and/or other Internet log information of your computer or mobile device; and
  • telephone numbers and email addresses contained in your phone book, when you choose to participate in interactive features of the Services. In this case we will have informed you when you access to the Services and by providing that data to us you agree that you have obtained consent from those individuals in the phone books.

  We may access, use and/or process your biometric data including without limitation fingerprints and facial images stored on your mobile device or other device for the purpose of conducting identity verification, however we will not collect nor store such data.

  Refusal to provide such information or provide incomplete or incorrect information may deny you access to certain parts of the Website and/or the Mobile App, or may render us unable to handle an application or request you are making or may otherwise defeat the objectives of your visit or use.

• Use of Personal Data Collected

  Specific purposes for which your personally identifiable information may be used are set out in the annexed Personal Information Collection Statement which forms part and parcel of this Privacy Policy.

• Retention of the Information

  If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party. If your mobile number is used for account login, you shall ensure that timely update is made by logging in to “[your account]” section of the Website or the Mobile App when your mobile number is to be changed or returned to your mobile operator. This is important to ensure that your account information will not be accessed by a third party who may have acquired the right to use your discarded mobile number. You are solely responsible for securing your account in this particular way. We shall have no liability to you for any loss or damage in this regard.

  Unless there is a mandatory legal requirement for us to keep your personal data for a specified period, we will only retain your personal data for as long as is necessary to fulfil the purpose for which the personal data were originally collected.

  In your dealings with us, we retain records of your online transactions for auditing purposes. Our general policy is to retain the information for a reasonable period. We do not offer online facilities for you to delete personal data held by us.

• Disclosure of Information

  We do share your information with the Sellers and our suppliers, service providers and business partners, or transfer it to our subsidiaries and affiliated companies and any company in which the same has an interest, but where disclosure is necessary for us to comply with any statutory obligations or requirements, or for us to provide the Services to you or to carry out the original purpose, or a directly related purpose, for which the personal data were collected, those data may be provided to the following parties (whether within or outside Hong Kong):

  • court of law, law enforcement agency, or other governmental or statutory authority, institution or organisation of a competent jurisdiction;
  • the Sellers or our suppliers, service providers or business partners, or directors, officers, employees, agents, contractors or other service operators of any of the foregoing, in each case who are involved in the sales and marketing, fulfilment, administration or provision of the Services;
  • any other person under a duty of confidentiality to us including a member of our group of companies, IT consultants, data processors, auditors, accountants, or lawyers, which has undertaken to keep such information confidential; and
  • banks, financial institutions, insurance companies, credit card issuing companies or debt collection agencies.

  All personal data which we collect is kept confidential to the best of our commercially reasonable efforts as if those were our own confidential information.

• Direct Marketing

  If you have provided us with your personally identifiable information, you may receive telephone calls, email, in-app notifications, SMS and direct mailings containing promotional materials from us or the Sellers, our suppliers, service providers or business partners.If you prefer not to receive any direct marketing communications from us or the parties aforesaid, you can opt out at any time by updating your preferences through your registered account or an “unsubscribe” link so provided.

• Access to and Correction of Information

  If you want to access and/or correct your personal data which you have given us via the Internet, you may write to us. We may charge you a reasonable fee for each successful access from time to time. However, such fee will be waived if the access is necessary to make a genuine and reasonable correction.

• Confidentiality

  Whilst we shall use commercially reasonable efforts to maintain confidentiality of your personal information and data so provided to us, we do not warrant (and accept no responsibility for) confidentiality of any information or data whether personal or otherwise transmitted through the Website and/or the Mobile App.

• Dealing with Advertisers

  Your correspondence or business dealings with, or participation in promotion of third parties placing advertisements on the Website and/or the Mobile App or other parties found on or through the services of the Website and/or the Mobile App, including payment and delivery of related goods or services, and any other terms, conditions, warranties or representations associated with such dealings, are solely between you and those third parties. You agree that we shall not be responsible or liable for any loss or damage of any sort incurred as the result of any such dealings or as the result of the presence of such advertisers on the Website and/or the Mobile App.

• Links to Third Party Websites

  Winestry or companies that help us provide services may provide links to external websites or online resources. By clicking on third party links on the Website and/or the Mobile App, you acknowledge and agree that Winestry is not associated with, responsible for, or endorses any content, advertising, products, or other materials on or available from such sites or resources. All external websites operated by third parties are the sole responsibilities of their web operators and therefore beyond our control and responsibility. We cannot guarantee the appropriateness, reliability, timeliness, effectiveness, correctness, and completeness of external websites.

• Governing Law and Severability

  This Privacy Policy shall be construed in accordance with, and is governed by the laws of the Hong Kong Special Administrative Region of the Peoples' Republic of China (“Hong Kong”) and each part of this Privacy Policy shall apply to the extent permitted thereby. Any part of this Privacy Policy which is prohibited or unenforceable in any jurisdiction is ineffective as to that jurisdiction only to the extent of the prohibition or unenforceability. That does not invalidate the remaining parts of this Privacy Policy nor affect the validity or enforceability of that part in any other jurisdiction.

• Enquiries

  Should you have any enquiries concerning our Privacy Policy, please feel free to contact us. The address is as follows:

  Room 1005, 10th Floor, Tower 2, Lippo Centre, 89 Queensway, Hong Kong

  Email: cs@winestry.com.hk

  We keep this Privacy Policy under regular review and place updates on the Website and/or the Mobile App from time to time.

ANNEXURE

Personal Information Collection Statement

As an user, buyer and/or a seller of the Website and/or the Mobile App, it may be necessary for you to provide us with your personal data when you apply to us and or continue to subscribe with us for the Services. If your personal data is incomplete or incorrect, we may not be able to provide or continue to provide the Services to you. We shall keep your Personal Data confidential at all times. Our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of personal data will be in accordance with the laws of Hong Kong and are as set out in our privacy policy (“this Privacy Policy”) of which this Personal Information Collection Statement forms part. Unless otherwise expressly defined or the context otherwise requires, words and expressions defined in this Privacy Policy have the same meanings when used in this Personal Information Collection Statement.You agree that your personal data provided by you to us may be used and retained by us for the purposes stated in the “Purpose of Collection of Personal Data” section of this Privacy Policy and for other purposes as shall be agreed between you and us or required by law from time to time.

In addition, in accordance with your agreement with us, we may disclose and transfer your personal data (whether in Hong Kong or abroad) to any company and to include that personal data in one or more databases held by us for the marketing of goods and/or services by us and for the performance of procedures for comparing personal data with other information supplied by you to us for the above purposes. If you do not wish to receive marketing information from us with respect to goods and/or services or for us to disclose, transfer or use your personal data for the direct marketing or other purposes as set out in this paragraph, you may opt out at any time by updating your preferences through your registered account or an unsubscribe link provided.

Transfer of Personal Data outside Hong Kong

If necessary, we may transfer the personal data to places outside Hong Kong for carrying out the purposes, or the directly related purposes, for which the personal data were collected. All the transfer of those personal data will be carried out in compliance with the requirements of the PDPO.

Data Access

Under and in accordance with the laws of Hong Kong, you have the right to:

• check whether we hold any of your personal data;
• access your personal data held by us;
• require us to correct any personal data which is inaccurate; and
• ascertain our policies and practices (from time to time) in relation to personal data and the types of personal data held by us.

We have the right to charge a reasonable fee for the processing of any personal data access request. All requests for access to or correction of personal data or information regarding policies and practices and types of personal data held should be in written format.