Personal Data and Privacy Statement
of
Sims Wine Club
1. General
1.1 This statement provides information on the policies of Sims Wine Club, under the Personal Data (Privacy) Ordinance (Cap.486) of Hong Kong (“Ordinance”).
1.2 Terms used in this statement shall, unless otherwise specified, be construed in accordance with the Ordinance.
2. Purpose of collection of personal data
2.1 The provision of any personal data by you or on your behalf to Sims Wine Club shall be voluntary and shall be deemed to authorize such members to collect, retain, update and use your personal data for the purpose of clause 2.2 below.
2.2 The personal data provided by you or on your behalf to Sims Wine Club from time to time as well as all other personal data related to you collected and held by such member will be used for the following purposes:
  1. Processing your application for membership of customer loyalty programmes of Sims Wine Club;
  2. Operating daily for provision of goods, facilities and services to you;
  3. Providing additional goods, facilities and services to you as they may arise from time to time;
  4. Providing information, promotion offers or activities of Sims Wine Club;
  5. Collecting outstanding amount payable by customers or assistance in conducting credit checks with other companies;
  6. Updating and verifying your identity and other information in accordance with relevant laws;
  7. Marketing and direct marketing purposes, including the service or products of selected business partners, and issuing any advertising and/or marketing materials to you;
  8. Conducting statistics and market research for the purpose of providing products or services to you;
  9. Performing statistical analysis of your driving habit and behaviour in order to design suitable products and services to you;
  10. Comparing the personal data provided by you with your other information possessed from time to time by Sims Trading Company Limited for verification purposes;
  11. Conducting financial audit;
  12. Making such disclosures as may be required for any of the above purposes or by law; and
  13. Achieving any other lawful purposes relating to any of the aforesaid purposes; and
  14. Enforcing any legal or other rights of Sims Wine Club may have against you.
2.3 In the event that, in the opinion of the member of Sims Wine Club to which you provided personal data, the personal data provided by you is insufficient or such member is not satisfied that such data is true and accurate, such member reserves the right to refuse to withhold process of your application or provision of any service to you unless and until the personal data required by such member is provided.
2.4 For the purposes stipulated in clause 2.2 above, any employee of Sims Wine Club or any person retained by Sims Trading Company Limited shall be entitled to inspect the personal data provided by you.
3. Use of personal data
Sims Wine Club will ensure the confidentiality of collected personal data but may provide such information to the following parties (including parties within as well as outside the Hong Kong Special Administrative Region (“Hong Kong”)) for the purpose of implementing the “purpose of collection of personal data” mentioned above:
  1. Any agent, contractor or third party service provider who provides administrative, telecommunications, computer, or other services to Sims Wine Club and Sims Wine Club’s customers;
  2. Any agent authorized by Sims Wine Club from time to time to process personal data of Sims Wine Club’s customers;
  3. Any business partner selected by Sims Wine Club;
  4. Any other members of Sims Trading Company Limited, within as well as outside Hong Kong;
  5. Auditors, consultants or legal adviser(s) of Sims Wine Club, within as well as outside Hong Kong;
  6. Any other person under a duty of confidentiality to Sims Wine Club; and
  7. Any of the actual or proposed assignees or transferees of Sims Wine Club.
4. Duty of confidentiality
4.1 Sims Wine Club shall exercise reasonable endeavours to ensure that the personal data provided by you shall be kept confidential and be placed in secure locations. Sims Wine Club shall further exercise reasonable endeavours to ensure the integrity, prudence and competence of the persons who have access to such data.
4.2 In compliance with any law in Hong Kong, Sims Wine Club may disclose the personal data provided by you to governmental authorities or other regulatory bodies or persons.
5. Special provisions for personal data held by Sims Wine Club on the internet
5.1 By assessing Sims Wine Club through its website (“Site”), you shall be deemed to agree to the terms and conditions in this statement.
5.2 All reasonable efforts are made to ensure that any personal data held by Sims Wine Club from time to time through the Site is stored in secure and safe storage.
5.3 Sims Wine Club may use “cookies” on the Site so as to:
  1. enable tighter security;
  2. enable you to complete the application process;
  3. personalize the Site for you; and
  4. build online profile for you.
5.4 You may disallow "cookies" at any time on your web browser.
6. Your rights
6.1 In the event that you have objections to any use of the personal data in accordance with clause 2 or any provision or disclosure of such data in accordance with clause 3 above, please inform Sims Wine Club to which you provided your personal data in writing. The address of such member is stated in the relevant forms/contracts executed between you and such member. Sims Wine Club shall cease the use and/or provision or disclosure of such data upon confirmation of your request.
6.2 Unless you request Sims Wine Club to dispose all personal data provided by you, you acknowledge that Sims Wine Club shall retain all such personal data and may continue to deliver to you marketing information even after cancellation or withdrawal of your application for membership of any of the clubs organized by Sims Wine Club or your membership in such clubs, expiry of the warranty period of any goods supplied or service provided by Sims Wine Club or completion of any sale of goods or provision of services by Sims Wine Club (as the case may be).
7. Access and correction request
7.1 You have the right to request access to and correction of your personal data in accordance with the Ordinance.
7.2 In the event that you intend to correct any personal data, please inform Sims Wine Club to which you provided your personal data in writing so that such member shall be able to make the amendments accordingly.
7.3 Enquiries concerning the personal data collected, including access and corrections, should be addressed to the address stated in the relevant forms/contracts executed between you and Sims Wine Club or any other address from time to time stipulated by Sims Wine Club.
7.4 In accordance with the terms of the Ordinance, Sims Wine Club has the right to charge a reasonable fee for the processing of any data access request. You agree to pay such fees.
8. Use of personal data in Direct marketing
Sims Wine Club intends to use a customer's personal data in direct marketing and may not so use the data unless Sims Wine Club has received the customer's consent (which includes an indication of no objection) to such intended use.  In this connection, please note that:

  1. the name, contact details, products and services portfolio information, transaction pattern and behavior, consumption preference, financial background and demographic data of the customer held by Sims Wine Club from time to time may be used by Sims Wine Club in direct marketing;
  2. the following classes of goods, facilities, services, and other marketing subjects may be marketed by Sims Wine Club, namely:
    1. Sims wine club activities including wine promotion offers, wine tasting events, (electronic) direct mailing to members, redemption gifts/coupons, online wine club shop;
    2. reward, loyalty or privileges programs and related services and products;
    3. services and products offered by Sims Wine Club’s co-branding / joint promotion business partners
    4. Professional and consulting services for product information
    5. All products and services offered in Sims wine club shop
    6. Products and services offered by Sims Wine Club including food and beverages
    7. Donations and contributions for charitable and/or non-profit making purposes;
  3. the above goods, facilities, services and marketing subjects may be provided or solicited by Sims Wine Club and/or:
    1. any subsidiary, affiliate or associated company of Sims Trading Company Limited;
    2. any third party goods and/or services provider;
    3. any third party reward, loyalty, co-branding or privileges programme provider; and
    4. any charitable organization;
  4. in addition to marketing the above goods, facilities, services and other marketing subjects by itself, Sims Wine Club also intends to provide the above personal data to all or any of the persons described in sub-paragraph (iii) above for use by them or it in marketing those goods, facilities, services and other marketing subjects, and Sims Wine Club may not so provide the data unless Sims Wine Club has received the customer's consent (which includes an indication of no objection) to the intended provision.
If the customer does not wish Sims Wine Club to use or provide to any other persons his personal data for use in direct marketing as described above, the customer may exercise his opt-out right by notifying Sims Wine Club, in which event Sims Wine Club must, without charge to the customer, cease to use or provide to other persons the customer's personal data for use in direct marketing.

The customer may provide his consent to Sims Wine Club's using or providing to other person his personal data for use in direct marketing as described above by Sims Wine Club's Data Protection Officer, whose contact details are set out below, or through such other channel which the customer may be advised of when providing personal data to Sims Wine Club.

9. Data protection officer of Sims Wine Club
The person to whom requests for access to data or correction of data or for information regarding Sims Wine Club’s privacy policies and practices and kinds of data held and for any other communications hereinabove described are to be addressed as follows:

The Date Protection Officer
Sims Wine Club
7/F DCH Building, 20 Kai Cheung Road, Kowloon Bay, Hong Kong
Tel : 2262 1798        Fax: 2707 9602        E-mail: wineclub@sims.com.hk

10. Language
If there is any discrepancy between the Chinese and English versions, the English version shall prevail.
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