Oriental Pearl (HK) Limited (“the Company”) respects the privacy of all its customers, potential customers and registered users of its website and is committed to protect the privacy, confidentiality and security of the personal data provided by you.

We pledge to fully comply with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong and, where possible, internationally recognised standards of personal data privacy protection.

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The Application of this Privacy Policy

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This Privacy Policy (the "Policy") applies to personal data regarding customers, registered users of the website and other individuals with whom we do business and to the management of that data in any form, whether electronic or written. This Policy explains our personal data practices and the choices you can make about the way your personal data is used. This Policy gives effect to our commitment to protect your personal data.

 

Our Collection of Personal Data

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The term "personal data" in this Policy refers to personal information which is capable of identifying you as an individual. When we need to collect personal data from you to provide you with a particular service, we will ask you to voluntarily supply us with the information we need. You may always choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details, we may not be able to provide you with the goods, services or information that you request.

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Personal data may be collected as part of: (i) purchasing goods and services, (ii) use of our website, (iii) event bookings or other reservations, (iv) provision of information, (v) submitting job applications and (vi) facilitating communications by email, telephone or other methods.

 

Types of Personal Data we Collect

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The types of personal data and information that we collect includes (but is not limited to):

● personal details, date of birth, contact information;
● goods and services purchased, observations about your preferences;
● wine club membership and account information, profile or password details;
● any information necessary to provide goods and services or fulfill special requests;
● your reviews and opinions about our services; and
● information collected through the use of telecommunications systems.

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Where you provide personal data of third parties (for example, names and contact details of your family members or friends or any other persons), you confirm that you have their consent to provide their personal data to us. We recommend that you show them this Policy.

 

How we use Personal Data

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We may use and disclose relevant portions of your personal data for the purposes set out below.

For the performance of our agreement with you, in order to:

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● provide and charge for the goods and services you purchase;
● process event bookings, reservations and activity registration;
● process wine club membership applications;
● administer our business.

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For our legitimate commercial interests, in order to:

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● provide information including news and updates;
● conduct market analysis, market research, customer satisfaction and quality assurance surveys;
● provide information in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by

● another company, or any change of management of the Company.

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To comply with legal obligations to which we are subject:

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● meet legal and regulatory requirements of any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise respond to any request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;
● administer general record keeping.

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Use of information based on your consent:

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● facilitate direct marketing, promotional and customer management purposes, including sending you sales promotional communications (including without limitation emails and push notifications) or special offers if you have consented to receive the same; This does not include disclosure of your personal data to third-party providers of products and services to be marketed. Please see the section “Direct Marketing” below;
● for any other purposes for which we have your consent.

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Disclosures of your Personal Data

 

From time to time, we may disclose and transfer your personal data (i) to service vendors who provide us with administrative, telecommunications, payment and delivery services to enable the Company to provide you with goods and services and (ii) as are relevant for the aforementioned purposes.

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Direct marketing

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We may use your personal data (including your name, address, telephone number and email) for direct marketing of offers and promotions to be offered by us in relation to:

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● Wine and wine-related products and services

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We may also use such data for direct marketing of offers and promotions to be offered by our business partners in relation to:

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● Travelling, transportation, dining and entertainment;
● Credit cards, insurance, financial and investment services;
● Health and wellness, sports and leisure activities;
● Non-profit making or charitable activities.

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We will not share your personal data with these business partners or any other third party for the purpose of direct marketing.

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We will not use your personal data for direct marketing if you have (i) opted-out of (when filling out the order form or providing your personal data); or (ii) at any time, unsubscribed to, by writing to us at wine@opl.hk; receiving any of the marketing communications. An email of confirmation would be sent to you.

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We reserve the right to disclose any personal data we have concerning you if we are compelled to do so by a court of law or requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property. We also reserve the right to retain information collected and to process such information to comply with accounting and tax rules and regulations.

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Except as described herein, we do not permit the sale or transfer of personally identifiable information to third parties.

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Centralised Processing and Retention of Personal Data

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We may centralise certain aspects of our data processing activities, which may result in the transfer of your personal data from one country to another. For example, if we use a service provider who stores data outside of Hong Kong, the personal data gathered in that process will be transferred to and processed outside of Hong Kong. Your personal data will only be transferred to locations outside of Hong Kong where we are satisfied that adequate or comparable levels of protection are in place to protect personal data held in that jurisdiction, and (where we are required to do so) with your consent.

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We retain the personal data collected for so long as may be necessary to fulfill the afore-mentioned purposes (including any directly related purpose), under sections “How we use Personal Data” and “Disclosure of your Personal Data”.

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Our commitment to Data Security

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We take appropriate steps to protect the personal data we hold against loss, unauthorised access, use, modification or disclosure.  We use industry standard practices to protect the personal information we collect. Notwithstanding the foregoing, no data transmission over the Internet or any other public network can be guaranteed to be completely secure, and privacy cannot be assured in your communication with us.

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How to Access or Correct Your Personal Data

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You are entitled to access and make changes to any personal data relating to your profile held in our database. You should update the personal data held by us whenever there is a change. If you have any questions about this Policy, or if you would like to submit a request for access to or change of the personal data that we maintain about you, please contact wine@opl.hk.

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We reserve the right to charge a reasonable fee for the processing of any such access request. As indicated above, all requests for access to your personal data must be submitted in writing. When communicating your request, please be sure to include your full name, date of birth, address and telephone number so we can ascertain your identity, and specify clearly the type of enquiry and the original source of data collection.

 

Changes to the Policy

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We may modify this Policy from time to time. Any changes to this Policy will be posted to our website so that you are always informed of the way we collect and use your personal data. Updated versions of our Policy will include the date of the revision at the end of this Policy so that you are able to check when the Policy was last amended.

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Any changes to our Policy will become effective upon directly notifying you or posting of the revised Policy on the website whichever is the earlier.

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Miscellaneous

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This Policy is governed by and shall be construed in accordance with the laws of Hong Kong Special Administrative Region.

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This Policy is written in the English language and may be translated into Chinese. In the event of any inconsistency between the English version and the Chinese version of this Policy, the English version shall prevail.