Privacy Policy

Privacy Policy Statement

We are committed to safeguarding your privacy and ensuring that your Personal Data is protected. This Privacy Policy Statement explains the types of Personal Data we collect and how we process and protect that data.

We shall keep your Personal Data confidential and shall ensure that our policies and practices with respect to the collection, use, retention, disclosure, transfer, security and access of your Personal Data comply with the laws of Hong Kong.

Personal Information Collection Statement (“PICS”)

This PICS is issued pursuant to PDPO in relation to the operation of our retail and trade business by Vintasia Limited and our online shop, www.citicellar.store (together referred to as “we” or “us”).

1. This PICS is last updated on the Effective Date.

2. Definitions
Under this PICS, unless the context otherwise requires, the following words and expressions shall have the following meanings:

a. “Database” means the database of our customers’ Personal Data.

b. “Effective Date” means September 22, 2022.
“Our App” means the mobile application operated by us.

c. “Our Affiliates” means companies related to Vintasia Limited, which operate Retail Goods or Services business.

d. “Our Stores” include Citicellar® and other store formats that we may operate from time to time (whether online or offline).

e. “Our Subsidiaries” means all the retail and distribution divisions operating under Vintasia Limited offering Retail Goods or Services to consumers.

f. “PDPO” means the Personal Data (Privacy) Ordinance (Cap.486).

g. “Personal Data” has the meaning ascribed to it under the PDPO.

h. “Our Website” means www.citicellar.store

i. “Registered Customer” means our customer who has registered for an account in Our App or Our Website.

j. “Retail Goods or Services” means sales of goods or provision of services in relation to any of the following (whether through physical or online channels): wine and liquor, and related accessories, books and equipment.

Personal Data: What We collect and Why

1. In order for you to become a Registered Customer and to enjoy our various products and services, it is necessary for you to provide us with certain essential Personal Data as indicated at the time of collection. We may also ask for other information which helps us to offer you tailored products and services that we think may be of interest to you. The types of Personal Data we may collect include your name, address, email, telephone number, date of birth, gender, age, shopping preferences and hobbies.

2. We shall have the right to collect, hold, process and/or use, the Personal Data in the Database in each case for the purposes as set out in, and in accordance with, this PICS. If you are unable or unwilling to provide us with complete and correct Personal Data, we may not be able to provide or continue to provide our products and services to you.

Use of Your Personal Data

1. You agree that the Personal Data you provide to us and all information relating to the use of Our App and/or Our Website may be used and retained by us for:

a. processing your application as a Registered Customer

b. providing you with our services;

c. the normal management, operation, and maintenance of Our App and/or Our Website

d. providing you with regular communications from us with details of our retail business and benefits;

e. providing you with Retail Goods or Services which you have requested;

f. processing your order for purchases at our Stores (online or offline), including verifying your payment details/status;

g. carrying out prize draws, games or competitions which you have entered;

h. carrying out data sorting and analysis to enable us to better understand your characteristics and buying behaviour and to provide other services better tailored to your needs, and to assist us in selecting Retail Goods or Services that are likely to be of interest to you;

i. designing new or improving existing services provided by us, Our Affiliates and/or Our Subsidiaries to you;

j. investigation of complaints, suspected suspicious transactions, and research for service improvement;

k. prevention or detection of crime;

l. disclosure as required by law; and

m. aggregated behavioural analysis.

2. With your consent or indication of no objection, will use your Personal Data for direct marketing to you (whether by post, email, phone, SMS, or other media whether now known or available in the future) in relation to offers and promotions from:

a. us, Our Affiliates and/or Our Subsidiaries;

b. hird party merchants that we cooperate with to provide benefits to you in relation to Retail Goods or Services.

3. We may disclose and transfer (whether in Hong Kong or abroad) your Personal Data to our agents or contractors under a duty of confidentiality to us who provide administrative, data processing, research and marketing, distribution, telecommunications, professional or other similar services to us.

4. We may also disclose and transfer (whether in Hong Kong or abroad) to any of our actual or proposed assignees or transferees of our rights with respect to your Personal Data in connection with a re-structuring of our retail business and/or merger (as between us and a third party), sale, or transfer (whether of assets or shares, in whole or in part), to use, hold, process or retain such Personal Data for the purposes mentioned in clauses 5 and 6 above.

Your rights in relation to your Personal Data

1. You have the right to:

a. check whether we hold any of your Personal Data;

b. access your Personal Data held by us;

c. require us to correct any Personal Data which is inaccurate;

d. ascertain our policies and practices (from time to time) in relation to Personal Data and the type of Personal Data held by us;

e. opt out from receiving direct marketing materials from us at any time.

Any request in relation to the above shall be in writing sent via Contact Us, or by Email to cs@citicellar.store.

2. In accordance with the Ordinance, we have the right to charge you a reasonable fee for the processing of any Personal Data access request.

Protecting your Personal Data

1. We maintain appropriate technical and organizational measures to protect the Personal Data you provide to us against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your Personal Data.

2. Our Website may contain hyperlinks to other websites provided by third parties. We do not control these third party websites or any of the content contained on those websites. Once you have left our website, we cannot be responsible for the protection and privacy

About Using Our Sites

1. When you choose to use access or download our Sites or allow connectivity via Wi-Fi connections to your device, we receive information about your location and mobile device, including a unique identifier for your personalised device, your GPS data or wireless networks data (WLAN). Location data is neither stored nor transmitted to third parties. If you agree with the localisation function and/or enable the notifications function on your device mobile, we can provide you with location-based services including advertising, search results and personalised content. When you are near one of our Stores, then we can use push email communications or notifications (such as recommended promotion and recommended products) to you based on your geo-location data services and/or immediately previous on-line activities if you have provided your consent to receive such communications and advertising.

2. Most mobile devices allow you to turn off location services and push notifications on your device. Should you wish to do so, please access your own device and vary the settings for notification on your device to reflect your own preference to be notified (or not) following the relevant instructions under your device.

Miscellaneous

1. Nothing in this Privacy Policy Statement shall limit your rights under the PDPO.

2. If there is any inconsistency or conflict between the English and Chinese versions of this Privacy Policy Statement, the English version shall prevail.

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

4. We may change this Privacy Policy Statement from time to time by posting an updated version on the Our Website and Our App.