We comply with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong (“PDPO”) and related codes of practice issued by the Privacy Commissioner for Personal Data.
Our privacy statement highlights why we collect your personal information, what information we collect, how we use this information and how long we store it. We also want you to know how you can access, amend or in some cases delete your information.
WHY DO WE COLLECT INFORMATION?
We collect, use, store and disclose personal data in accordance with the Data Protection Principles (“DPPs”) set out in the PDPO. We will inform you of the purpose and classes of persons to whom your data may be transferred before or at the time of collection.
You can access our website and browse our site without disclosing your personal data. In the event that you volunteer personal information (such as opting into our marketing communications) we will only process your personal information for legitimate business purposes, which include some or all of the following:
We collect personal information when you submit an enquiry via our website, so that we can follow-up with a response.
To send relevant communications .i.e. subject to your consent, sending regular email marketing communications which we think will be of interest to you.
We collect information sent by your browser to enhance, modify, personalise or otherwise improve our services / communications for the benefit of our visitors / customers. We aim to provide a personalised user experience that we think will be relevant to you and collect this information to better understand how people interact with our website.
We collect personal / business information when you buy and/or use our services. We do this to be able to deliver our services and send you important company announcements, operational information, for contractual reasons, to process financial transactions and for legal reasons.
We collect personal information through online customer surveys in order to gain an understanding of customers' experiences working with FINE+RARE and how to improve our products and services.
We collect information to determine the effectiveness of marketing campaigns, content and advertising.
Our website does not enable our visitors to communicate with other visitors or to post information that can be accessed by other visitors.
We only collect personal data that is necessary and adequate for the purposes stated, and will not keep such data longer than necessary.
If you buy our products or use our services, it is mandatory to provide the information requested in order for us to provide you with our products and services. We will not be able to provide the relevant products or services to you if you fail to do so.
WHAT IS OUR LEGAL JUSTIFICATION FOR USING YOUR PERSONAL INFORMATION?
We do not sell or rent your personal information to other companies or individuals.
All processing is carried out for lawful purposes directly related to our functions and activities and in a fair and lawful manner as required under DPP1 & DPP3.
We do not sell or rent your personal information to other companies or individuals.
Marketing information - If you have requested information about our products or services or have participated in a FINE+RARE marketing event, we may use your personal information to follow-up with important announcements and to keep you informed of any news, special offers or promotions that we believe might be of particular interest to you. We will only send you direct marketing materials if you have given your express consent or have not objected to such use, in accordance with the PDPO. You may opt out at any time (see below).
General service provision - to communicate with you in the event that any products or services you have requested are unavailable or require delivery and general service provision.
Tracking activity on our website
For internal sales analysis
Vendors that may collect anonymous data on our behalf if we request it, are:
Google Analytics: We use Google Analytics to analyse the performance of our websites and follow up on the effectiveness of our marketing efforts. Google Analytics allow us to analyse data in aggregate, we do not collect or store any personal information in Google Analytics.
Advertising: We may use a number of services, listed below, for advertising based on your web activity, or remarketing. We use this to show adverts to visitors that have been to our websites, on Google, Facebook, LinkedIn, and other participating websites. If you have an account with any of the vendors below, their privacy statement may allow them to connect the fact that you have been to our websites and the pages you have viewed with your profile. Your anonymous browsing behaviour may in turn be shared by the following partners as outlined in their privacy statements. We do not share any personal information with these vendors.
Email Marketing & Direct Mail: If you are a customer, partner, or prospect we may use your business contact information and business address to send you marketing communications such as email marketing and direct mail. We may also send you product or company news and service updates that are relevant to your use of our website, products and services. We will process this personal information for the legitimate business purposes stated above.
Where we engage service providers (including those located outside Hong Kong) to process personal data on our behalf, we will ensure by contract or other means that they provide a level of protection comparable to the requirements of the PDPO.
If you do not wish to receive email marketing content from us, you can email unsubscribe@frw.co.uk
HOW LONG DO WE KEEP YOUR INFORMATION FOR?
Personal data will be retained only for as long as is necessary to fulfil the purpose for which it was collected or to satisfy any applicable legal or compliance requirements (DPP2).
We keep your business / personal information as long as it is warranted for us to fulfil our commitments to you, or to adhere to legal or regulatory requirements.
If you are a customer, we keep information for the duration of the relationship. If you have requested to receive marketing communications, we will keep your personal information only as long as you interact with us, or until the data subject opts-out or asks to be forgotten.
If you have transacted with us we will keep your information for at least 7 years for legal reasons.
If you store wines with us we will keep your data for the whole duration until 7 years after you have removed the wines unless you have asked to be forgotten.
If you have asked to be forgotten, your data will be removed in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679) with effect from 25th May 2018.
HOW DO WE KEEP YOUR INFORMATION SECURE?
Transmissions over the Internet are not completely secure or error-free. We do however take appropriate technical and organizational measures to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration, and destruction e.g. fire walls, physical security. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information and to help ensure that your data is safe, secure, and only available to you and to those with authorized access.
We take all practicable steps to ensure personal data is protected against unauthorised or accidental access, processing, erasure, loss or use in compliance with DPP4.
If you have any questions about the security of your personal information, you may contact us using the email customerservice@finerare.hk.
WHAT RIGHTS DO YOU HAVE REGARDING YOUR PERSONAL INFORMATION?
Under sections 18 and 22 and DPP6 of the PDPO, you have the right to request access to and correction of personal data held by us.
Opt-Out: You can choose to opt out of marketing communications at any time, by emailing unsubscribe@frw.co.uk
Subject Access Requests: You can request a copy of your personal information, and you can update any incorrect information by emailing Sara Cairns at customerservice@finerare.hk.
Right to be Forgotten: You may request erasure of your personal data where retention is no longer necessary for the purpose collected, subject to any legal obligations we have to retain certain records.
DOES THIS PRIVACY POLICY APPLY TO THIRD PARTY LINKS?
In order to provide our products and services, we may need to pass information on to our agents and sub-contractors or appoint other organisations to carry out some of the processing activities on our behalf, such as logistics companies.
In these circumstances, we will ensure that your information is protected and used in accordance with this privacy policy. We may also disclose information to the investigating authorities such as the police, and customs and excise, or if required to do so by law.
Any transfer of your personal data to agents or contractors will be done in compliance with DPP3 and DPP4 and only for the purposes stated at the time of collection.
HOW DO WE APPROACH CHANGES TO THIS PRIVACY POLICY?
If we decide to change our privacy policy, we will post the changes on this page so that you are aware of the information we collect, how we use it and under what circumstances we disclose it. A hard copy of the policy is available from Fine & Rare Wines (Asia) Limited, 8 Wyndham Street, 22/F, Central, Hong Kong,. Any revised policy will apply only to data collected after the new policy comes into effect.
HOW DO WE USE COOKIES?
Cookies are small text files which are stored on your computer, mobile phone or device. Cookies may be placed on your device when you visit a website or open a marketing email. FINE+RARE does not use cookies to collect personally identifiable information about you. We use cookies for a variety of reasons, such as to remember your preferences when you visit our sites to tailor your visit and monitor traffic to enable us to improve our sites.
Where required by applicable laws, we will obtain your consent before placing non-essential cookies or similar technologies on your device.
We also set third-parties cookies to allow you to easily link to third parties you may be subscribed to, such as Twitter and YouTube. We do not control these cookies, but we check how these cookies might use your information before allowing them to be set on our sites. Please visit the third-parties’ websites for more information on these cookies.
Our partners may also set cookies when they direct you to our site.
STRICTLY NECESSARY COOKIES
Cookie: hide-cookie-banner
Source: F+R
Purpose: Used for cookie banner handling.
Expiry: End of session
Cookie: hide-notification-banner
Source: F+R
Purpose: Used for notification banner handling.
Expiry: End of session
Cookie: cartId
Source: F+R
Purpose: Used to store user cart identifier.
Expiry: 8 hours
Cookie: documentReferrer
Source: F+R
Purpose: Used to store the page url which linked to this page.
Expiry: 8 hours
Cookie: frw-global-auth
Source: F+R
Purpose: Used for authentication purposes.
Expiry: 8 hours
ANALYTICAL COOKIES
Cookie: fbp
Source: Facebook
Purpose: Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers.
Expiry: 3 hours
Cookie: qca
Source: Google Inc.
Purpose: Used to provide usage data for the website.
Expiry: 8 hours
Cookie: ga
Source: Google Inc.
Purpose: Used to track the navigation on our Website and it helps to improve the use of our Website.
Expiry: 2 years
Cookie: gid
Source: Google Inc.
Purpose: Used to track the navigation on our Website and it helps to improve the use of our Website.
Expiry: 24 hours
Cookie: ai_session
Source: Microsoft Corporation
Purpose: Used to store a unique anonymous session identifier.
Expiry: End of session
Cookie: ai_user
Source: Microsoft Corporation
Purpose: Used to enable counting of the number of users accessing the application over time.
Expiry: 7 months
Cookie: hjid
Source: Hotjar
Purpose: Used to store a unique identifier for Hotjar analytics.
Expiry: 1 year
Cookie: hjMinimizedPolls
Source: Hotjar
Purpose: This cookie is set once a visitor minimizes a Feedback Poll widget. It is used to ensure that the widget stays minimizes when the visitor navigates through your site.
Expiry: 1 year
Cookie: hhjIncludedInSample
Source: Hotjar
Purpose: Used to let Hotjar know whether that visitor is included in the sample which is used to generate funnels.
Expiry: 1 year
MARKETING COOKIES
Cookie: hs_opt_out
Source: Hubspot
Purpose: This cookie is used by the opt-in privacy policy to remember not to ask the visitor to accept cookies again. This cookie is set when you give visitors the choice to opt out of cookies.
Expiry: 6 months
Cookie: __hs_do_not_track
Source: Hubspot
Purpose: This cookie can be set to prevent the tracking code from sending any information to HubSpot. It contains the string "yes".
Expiry: 6 months
Cookie: __hstc
Source: Hubspot
Purpose: The main cookie for tracking visitors. It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
Expiry: 6 months
Cookie: hubspotutk
Source: Hubspot
Purpose: This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts. It contains an opaque GUID to represent the current visitor.
Expiry: 6 months
Cookie: __hssc
Source: Hubspot
Purpose: This cookie keeps track of sessions. This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
Expiry: It expires in 30 minutes.
Cookie: __hssrc
Source: Hubspot
Purpose: Whenever HubSpot changes the session cookie, this cookie is also set to determine if the visitor has restarted their browser. If this cookie does not exist when HubSpot manages cookies, it is considered a new session. It contains the value "1" when present.
Expiry: end of the session.
Cookie: LPVID
Source: LivePerson
Purpose: Used to store a unique identifier.
Expiry: 2 years
Cookie: LPSID-8503086
Source: LivePerson
Purpose: Used to store the current active monitoring session.
Expiry: End of session
LAW
This Privacy Policy shall be governed by and construed in accordance with the laws of Hong Kong. The courts of Hong Kong shall have non-exclusive jurisdiction to resolve any disputes arising out of or in connection with this Privacy Policy.