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PRIVACY AND SECURITY POLICY

This Website ("Website") is published and maintained by Sotheby’s Wine Hong Kong Limited (referred to in this Privacy and Security Policy as "Sotheby’s Wine HK," "we," "us," "our," or other similar pronouns).

This Privacy and Security Policy governs your use of the Website and the services offered by us at our retail store (the "Services"). By visiting this Website, and/or using the Services, you agree to the terms of this Privacy and Security Policy as they may be amended from time to time. As we update and expand our Services, this Privacy and Security Policy may change, so check back to this page from time to time. This Privacy and Security Policy is incorporated into, and part of, the Sotheby’s Wine HK Website Terms and Conditions of Use, which governs your use of this Website in general.

PURPOSE

Your privacy is a serious matter to us. In order to make your visits to our Website and use of the Services as worthwhile as possible, we may ask you for Personal Data (as defined below) and we may collect certain information from you and your computer (about you and your interaction with the Website) each time you visit the Website. "Personal Data" includes, for example, your name; Identity Card copy; title; home and/or business address; e-mail address; home and/or business telephone, wireless and/or fax number; credit card and other payment information; demographic information; wine interests or preferences, wine purchases, payment history; and/or other information that may identify you as an individual or allow online or offline contact with you as an individual. This Privacy and Security Policy explains, in general, what Personal Data and other information is collected from you, how the Personal Data and information is used, and with whom we may share such information. Please take a few minutes to read our Privacy and Security Policy so that you understand how Sotheby’s Wine HK treats your Personal Data and other information.

RIGHT TO OPT IN AND OPT OUT

You have the right to "opt in" and "opt out" of certain of our uses of your Personal Data. For example, at the time you are requested to provide Personal Data on this Website, you may have the opportunity to elect to, or not to: (1) receive correspondence from us, or (2) have your Personal Data shared with other entities for their marketing purposes. You may also make this request by sending us an e-mail. In this e-mail, please say whether: (i) you would like to opt out of receiving promotional correspondence from Sotheby’s Wine HK in general, or just via e-mail or postal mail, (ii) you would only like to opt out of certain of Sotheby’s Wine HK mailings, e-newsletters, e-mail alerts or other correspondence, and if so which ones, and/or (iii) you would like to elect for us not to share your Personal Data with third parties for their marketing purposes. You may also opt-out of Sotheby’s Wine HK promotional e-mails by clicking on an opt-out link within the e-mail you receive, or of Sotheby’s Wine HK postal mailings by following the directions in such mailings.

Please understand that if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions and communications with us. You may control how you receive such non-promotional correspondence from us by updating your account preferences. Also, a request to have us stop sharing your Personal Data with other entities for marketing purposes will only apply as of your request, and we will not be responsible for any communications that you may receive from entities that received your Personal Data prior to such request. In these cases, please contact that entity directly.

WHAT INFORMATION IS COLLECTED ON THIS WEBSITE?

(i) User-Provided Information
We collect Personal Data from users of our Website and/or Services, for example, through such users' activities, transactions and completion of forms on our Website or at our retail store. Such information is collected, for example, when users register or subscribe for accounts or features on our Website , make online purchases , complete surveys, submit a comment or question to us using a "contact us" or similar feature on our Website, send us an e-mail, or in any other way submit Personal Data to us via our Website or otherwise.

You may be able to send information about our products and Services to your friends and family members through our Website by clicking on an "E-mail to Friend" or similar button on our Website or in an e-mail that we have sent you.

 

(ii) Website Usage Information
Cookies

If you have permitted your computer to accept cookies, we may use "cookies" to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser or related software from a web server and stored on your computer's hard drive. Cookies track where you travel on our Website and what you look at, transact and purchase. They may store the information in your shopping cart, and/or your username and/or password, and we may use them to deliver specific messages to you (for example, to announce a new feature that was added since the last time you visited the Website). A cookie may enable us to relate your use of our Website to other information about you, including your Personal Data. All of these purposes serve to improve and personalize your experience on our Website.

Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Additionally, if you have a Flash player installed on your computer, your Flash player can be set to reject or delete Flash cookies. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Website or certain areas or features of the Website.

Clear GIFs
We may use "clear GIFs" (aka "Web beacons" or "pixel tags") or similar technologies, in the Website and/or in our communications with you to enable us to evaluate Website Usage Information about visitors to the Website, target campaigns, upgrade visitor information, and know whether you have visited a web page or received a message. A clear GIF is typically a one-pixel, transparent image (although it can be a visible image as well), located on a web page or in an e-mail or other type of message, which is retrieved from a remote site on the Internet enabling the verification of an individual's viewing or receipt of a web page or message. A clear GIF may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personal Data.

IP Address and Clickstream Data
Our server automatically collects data about your server's Internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that's automatically assigned to your computer by your Internet service provider whenever you're on the Internet. When you request pages from our Website, our servers may log your IP Address and sometimes your domain name. Your IP Address is used to help identify you and to gather demographic information about our customers as a whole, but does not include personally identifiable information. Our server may also record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on this Website; the website you visit after this Website; the ads you see and/or click on; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Website or a referral site; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our server, and to administer our Website. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We may link this information with your Personal Data.

Any or all of these activities with regard to Website Usage Information may be performed on our behalf by our services providers, including, for example, our analytics vendor(s) and our e-mail management partner(s).

HOW DO WE STORE YOUR PERSONAL DATA

Your Personal Data is retained only for as long as is necessary for the fulfilment of the purposes for which the personal data is collected.

Your Personal Data may be stored on servers located outside of the country or region from which you originally entered the personal data.

HOW IS YOUR PERSONAL DATA USED?

We will use the Personal Data you provide to us, for example, to respond to your requests and to provide you with our product and Service offerings. For example, we will process and fulfill your orders, respond to your requests and inquiries and provide you with the Services and features offered on or through our Website or at our retail store. We may also use your Personal Data to maintain our internal record keeping. To the extent permitted by the applicable law, we may match information collected from you through different means or at different times, including both Personal Data and Website Usage Information, and use such information along with information obtained from other sources, including third parties. We also may compare your contact information to data in our worldwide databases in order to improve our Website and marketing. Also, advertisements and other content displayed to you on the Website may be customized to your interests and preferences, based on your Personal Data and Website Usage Information, including (but not limited to) non-personally identifying information, which we may obtain from you or from other sources.

In addition, we may use your Personal Data to send you notices about, or invitations to upcoming events hosted by Sotheby’s Wine HK, and to otherwise correspond with you about products, services, companies and events, sponsored by us, that we think might interest you. You may opt-out of receiving such notices from us by following the instructions in the Right to Opt In and Opt Out section above.

We may analyze user behavior as a measure of interest in, and use of, our Website and e-mails, both on an individual basis and in the aggregate.

DO WE SHARE PERSONAL DATA AND WEBSITE USAGE INFORMATION WITH OTHERS?

Sotheby’s Wine does not sell, lease or give your Personal Data to any other company, unless otherwise stated herein.

Service Providers
We may use third party partners to help operate our Website and deliver our products and Services, and may share your information with our affiliates, service providers and other third parties that provide products or Services for or through this Website or for our business (such as Website or database hosting companies, address list hosting companies, e-mail service providers, analytics companies, distribution companies, fulfillment companies, and other similar service providers that use such information on our behalf). For example, Sotheby’s Wine HK may use a reputable third-party company to manage its e-mail campaigns. This e-mail management partner is obligated to protect your confidential information.

Aggregate Statistics
We may disclose aggregate statistics regarding user behavior as a measure of interest in, and use of, our Website and e-mails to third parties in the form of aggregate data, such as overall patterns or demographic reports that do not describe or identify any individual user.

Legally Compelled Disclosures
We may disclose user information to government authorities, and to other third parties when compelled to do so by government authorities, at our discretion, or otherwise as required or permitted by law, including but not limited to in response to court orders and subpoenas. We also may disclose user information in connection with investigations or when we have reason to believe that someone is causing injury to or interference with our rights or property, other users of the Website, or anyone else that could be harmed by such activities.

Disclosure to Credit Bureaus
We may also report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.

Disclosure to Third Parties for Marketing Purposes
We may also disclose your Personal Data to other members of the Sotheby’s group of companies for their use in marketing purposes.

YOU MAY OPT IN OR OPT OUT OF OUR SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES FOR THEIR MARKETING PURPOSES BY FOLLOWING THE DIRECTIONS IN THE "RIGHT TO OPT IN AND OPT OUT" SECTION ABOVE.

WIRELESS ADDRESSES

If the email address you provide to us is a wireless email address, and you have elected to receive promotional messages from Sotheby’s Wine HK, you agree to receive messages at such address from us, unless and until you have elected not to receive such messages by following the instructions in the Right to Opt In and Opt Out section above. You understand that your wireless carrier's standard rates apply to these messages, and that you may change your mind at any time by following the instructions in the Right to Opt In and Opt Out section above. You represent that you are the owner or authorised user of the wireless device on which messages will be received, and that you are authorised to approve the applicable charges.

Business Transfer
Sotheby’s Wine HK regards its databases of customer information (which will include your Personal Data) as a valuable asset. In the event that Sotheby’s Wine HK or substantially all of its assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, such databases containing Personal Data may be one of the transferred assets. In addition, such a transfer may mean that Personal Data collected in Hong Kong is transferred to other countries. In using the Services you consent to such transfer of your Personal Data.

PLEASE NOTE THAT THE ABOVE TRANSFERS MAY BE WITHIN OR OUTSIDE HONG KONG. SOME COUNTRIES DO NOT OFFER EQUIVALENT LEGAL PROTECTION OF PERSONAL DATA TO THAT OFFERED WITHIN HONG KONG. IT IS OUR POLICY TO REQUIRE THAT ANY SUCH THIRD PARTIES RESPECT THE PRIVACY AND CONFIDENTIALITY OF YOUR PERSONAL DATA AND PROVIDE THE SAME LEVEL OF PROTECTION FOR YOUR PERSONAL DATA AS PROVIDED WITHIN HONG KONG, WHETHER OR NOT THEY ARE LOCATED IN A COUNTRY THAT OFFERS EQUIVALENT LEGAL PROTECTION OF PERSONAL DATA.

DIRECT MARKETING
We intend to use your Personal Data for direct marketing in relation to our products, events and Services subject to your consent (including indication of no objection). We would like to use the following categories of your Personal Data for direct marketing: your name, home and/or business telephone number, home and/or business address and e-mail address.

We also intend to provide your above categories of Personal Data to other members of the Sotheby’s group of companies for their use in direct marketing in relation to their products, events and services subject to your written consent (including indication of no objection). The provision of the Personal Data is for gain.

You may at any time partially or entirely opt-out from receiving our direct marketing communications and/or from our provisioning of Personal Data to third party for its use in direct marketing by (a) contacting our staff (contact details of which are set out in the “Enquiries” section below); or by (b) following the instructions contained in the Website. We shall, without charge to you, cease to use your Personal Data in direct marketing and/or to provide your Personal Data to third party for its use in direct marketing if you so request. We shall also write to any such third party to notify it to cease to use your Personal Data in direct marketing if you so request.

YOUR ACCESS RIGHTS

You may access, review and correct your Personal Data (including those stored in your user account on this Website e.g., your passwords and other contact information) by visiting a "My Profile" or similar area of your account on this Website and/or by contacting our staff (contact details of which are set out in the “Enquiries” section below) . We will send you a copy of your Personal Data we have on file (if any). You may send us new or updated information at any time. For example, clients may change their passwords and validation reminder at any time. We will endeavor to respond to your request to access, correct or delete your information as soon as practicable. Before we are able to provide you with any information, correct any inaccuracies or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request.

SECURITY

Sotheby’s Wine HK will take reasonable steps to protect the security and integrity of all Personal Data provided to us against unauthorized or accidental access, processing, erasure, loss or use, including making your sensitive information available to our employees and agents on a need-to-know basis. However, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

If you contact us by e-mail or a "contact us" or similar feature on our Website, you should be aware that your transmission might not be secure. A third party could view information you send by these methods in transit.

You may be able to create an account on our Website with a username and password. Passwords are encrypted and Sotheby’s Wine HK’s policies preclude access to passwords by anyone at Sotheby’s Wine HK or its service providers except on a need-to-know basis. If you do create a username and password, you are responsible for maintaining the strict confidentiality of your account password, and you shall be responsible for any access to or use of the Website by you or any person or entity using your password, whether or not such access or use has been authorised by or on behalf of you, and whether or not such person or entity is your employee or agent. You agree to (a) immediately notify Sotheby’s Wine HK of any unauthorised use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your account, and notify Sotheby’s Wine HK when you desire to cancel your account on this Website. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

We will have no liability for disclosure of your information due to errors or unauthorised acts of third parties during or after transmission.

In the unlikely event that we believe that the security of your Personal Data in our possession or control may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we would endeavor to do so as promptly as possible under the circumstances, and, to the extent we have your e-mail address, we may notify you by e-mail. You consent to our use of e-mail as a means of such notification. If you prefer for us to use another method to notify you in this situation, please e-mail us at winehk@sothebys.com with the alternative contact information you wish to be used.

PHISHING

With identity theft a continuing problem, it has become increasingly common for unauthorised individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the e-mail address from which the e-mail appears to have been sent, and the domain name of the Website requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorised individual to be used for purposes of identity theft. This illegal activity has come to be known as "phishing."

If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your Website password or credit card information) via e-mail or to a Website that does not seem to be affiliated with our Website, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us at winehk@sothebys.com

THIRD PARTY “LINKED-TO” WEBSITES

When you are on our Website you may have the opportunity to visit, or link to, other sites not operated by Sotheby’s Wine HK. These sites may collect Personal Data or other information of you. Sotheby’s Wine HK does not control sites that are operated by these entities and is not responsible for the information practices of these sites. This Privacy and Security Policy does not address the information practices of those other Websites.

CHANGES TO THIS PRIVACY AND SECURITY POLICY

Sotheby’s Wine HK reserves the right to change or update this Privacy and Security Policy, or any other of our policies or practices, at any time, and will notify users of this Website and/or our customers by posting such changed or updated Privacy and Security Policy on this page. Any changes or updates will be effective immediately upon posting to this Website. Under certain circumstances, we may also elect to notify you of changes or updates to our Privacy and Security Policy by additional means, such as posting a notice on the front page of our Website or sending you an e-mail.

ENQUIRIES

If you have any questions or comments regarding our privacy practices, you may contact our staff at winehk@sothebys.com or
Sotheby’s Wine
5/F One Pacific Place
Hong Kong

In the event of any inconsistency between the English and the Chinese versions of this Privacy and Security Policy, the English version shall prevail.

Last Updated July 2014