Sovy Wine Platform Limited – Privacy Policy Statement (Hong Kong)

Sovy Wine Platform Limited and its subsidiaries and associated companies (collectively "we", "us", or "Sovy") respect the privacy rights of visitors to this website and of individuals who participate in, access, or sign up to any of Sovy's services, activities, or online content (collectively referred to as "Services").

We endeavour to ensure that all our collection, transmission, processing, storage, and usage of personal data shall be carried out in strict compliance with the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of the Hong Kong Special Administrative Region ("PDPO"). The term "personal data" shall have the meaning ascribed to it by the PDPO.

1. Purpose of Collection and Use of Personal Data

You need not supply any personal data in order to access or browse this website. When you participate in, access, or sign up for any of the Services, personal data is collected from you to enable Sovy to provide you with those Services. You may decline to provide Sovy with the requested personal data, but in such cases, Sovy may decline to provide you with the Services.

Personal data collected from you may be used by Sovy for:

• Processing your application for the Services.
• Enabling the provision, logistics, and delivery of the Services to you.
• Conducting identity verification, age verification (to ensure compliance with laws regulating the sale of alcohol), and/or credit checks at the time of your application.
• Processing payment instructions or collecting amounts outstanding from you in relation to the provision of the Services.
• Designing and customizing services or offers for you.
• Conducting market research, statistical analysis, or consumer opinion surveys.
• Provisioning customer services, handling your complaints, and managing account enquiries.
• Targeted Digital Marketing & Advertising: Utilizing customer data to serve relevant advertisements to you on external digital networks.
• Compliance with applicable laws, rules, judicial orders, and regulatory requirements within the Hong Kong Special Administrative Region.
• Any other purposes directly related to the original purpose for which the personal data were collected.

2. Types of Personal Data Collected

Types of personal data collected by Sovy may include:

1. Personal Information & Contact Details: Your name, gender, date of birth, telephone number, email address, residential address, correspondence address, and/or billing address. (Official identity card numbers are only collected where strictly necessary and legally permitted for credit or security validation).
2. Business Information: Company name and business title.
3. Financial & Credit Information: Name of cardholder, credit card number, expiry date, and security codes.
4. Account Details: Account numbers, user accounts, and system login credentials.
5. Technical & Tracking Data: IP addresses, cookies, browsing history, and device identifiers.
6. Supplementary Data: Any other information as necessary for the provision of the Services to you.

3. Confidentiality, Disclosure, and Security of Personal Data

All personal data collected and held by Sovy will be kept confidential. However, where disclosure is necessary for Sovy's compliance with statutory obligations, or to provide the Services to you, those data may be provided to the following parties:

• The Office of the Communications Authority or other governmental, judicial, or statutory authorities, institutions, or organizations.
• The Company’s associated companies, contractors, agents, or third-party service operators who are involved in the sale, administration, data storage, logistics, or provision of the Services.
• Banks, financial institutions, credit card issuing companies, or debt collection agencies.
• Third-Party Advertising Partners: We share customer contact data (such as names, phone numbers, and email addresses) with third-party service providers—specifically Google—to perform advertising services on our behalf. This involves securely masking and matching your profile data with Google’s database (Google Customer Match) to display relevant online ads to you across the internet (including Google Search, YouTube, and the Google Display Network). Prior to transmission, this data is securely obfuscated and hashed using SHA256 protocols to ensure it remains unreadable to unauthorized parties and is used solely for ad-matching purposes.
• Note on Non-Personal Data: Any questions, comments, suggestions, or information other than personal data sent or posted to this website by you will be considered as voluntarily provided to Sovy on a non-confidential and non-proprietary basis. Sovy reserves the right to use, reproduce, disclose, transmit, publish, and post such information freely elsewhere.

All reasonable commercial efforts are made to ensure that any personal data held by Sovy is stored in a secure and safe place.

4. Direct Marketing & Personalized Ads Consent

Sovy intends to use your personal data to keep you up to date on our Services, wine promotions, and events.

• Strict Opt-In Policy: In compliance with Part 6A of the PDPO, we will not use your personal data for direct marketing or online advertising matching unless we have obtained your explicit, written, or affirmative consent (e.g., via an un-ticked optional checkbox during your registration).
• Ad Personalization: By providing consent, you agree that we may use your data signals, website interactions, and hashed customer lists to optimize and personalize ads tailored specifically to your interests across Google's advertising infrastructure.
• Right to Opt-Out Free of Charge: If you consent to receive marketing or personalized ads and later change your mind, you have the absolute right to opt out at any time. Upon receiving your request, we shall immediately cease to use your personal data for marketing and ad-matching services, entirely free of charge. You may opt out by adjusting your Google Ad Settings or by writing to our Personal Data Officer.

5. Use of Cookies and Tracking Technology

Sovy may use "cookies", web beacons, and tracking pixels on this site in order to:

• Enable tighter security and verify session ownership.
• Enable you to seamlessly keep browsing across pages.
• Personalize websites and offerings for you.
• Build general online user or visitor profiles for website optimization and targeted remarketing campaigns.

If you want to disallow the use of cookies, you can do so by adjusting the preferences on your own web browser, though this may impact certain features of our platform.

6. Transfer of Personal Data Outside Hong Kong

If necessary, Sovy may transfer the personal data to places outside the Hong Kong Special Administrative Region (including cloud data servers or Google processing centers located globally) for carrying out the purposes, or the directly related purposes, for which the personal data were collected. All transfers of those personal data will be carried out in strict compliance with the requirements of the PDPO.

7. Retention of Personal Data

Unless there is a mandatory legal or tax requirement for us to keep your personal data for a specified period, we will only retain your personal data for as long as is necessary to fulfill the purpose for which the personal data were originally collected.

8. Third-Party Links

This Privacy Policy Statement only applies to this website. This site may contain links to other sites and pages (such as advertisers' banners). By activating a link, you leave this site, and Sovy does not exercise control over any personal data or any other information you give to any other entity after you have departed. Access to and use of such other websites is entirely at your own risk.

9. Data Access and Correction Rights

Under the Hong Kong PDPO, you have the right to request access to, check whether we hold, and request the correction of any of your personal data held by us. If you wish to exercise these rights or have any queries regarding our privacy policy, you may contact us by writing to:

As permitted by the PDPO, Sovy reserves the right to charge you a reasonable and proportional fee for complying with any data access request.