McCaine Wines is fully committed to protecting the privacy interests of individuals who provide us with information about themselves and to complying with the requirements of the Hong Kong Personal Data (Privacy) Ordinance (the "Ordinance"). In doing so, we instruct our staff to comply with strict internal standards of security and confidentiality.

THE PERSONALLY IDENTIFIABLE INFORMATION ("PI Information") which we collect at the web site comprises any or all of the following: a. the IP address of the visitor's personal computer; the country from which the inquiry is made; the pages visited; the time at which a visit is made and the browser type; b. certain personal details of the visitor (these may for instance include his/her name; age; sex; profession); contact details; whether the visitor purchases any wine from McCaine Wines and wishes to receive information and if so, what kind of information. This PI information, when collected, is not electronically encrypted; and c. in the case of an existing account client who is a Hong Kong resident and who has been accepted by McCaine Wines for the on-line dealing facility, PI Information collected at the website may include identification details, an electronically encrypted security passcode for that client and information regarding wine courses or workshops by McCaine Wines which the client wishes to switch or redeem.

Apart from any security passcode, PI information collected at the web site is not electronically encrypted.

We may use software tools or 'cookies' to gather information about site visitors' browsing activities. Cookies are small files which are sent to visitors' browsers and stored on visitors' computer hard discs. Through the use of cookies we may obtain information as to the manner in which this site is used. The information collected may be used for statistical and evaluation purposes and may be processed by us or any other third party which provide services to McCaine Wines.

PI INFORMATION RECEIVED BY McCaine Wines MAY BE USED BY McCaine Wines and/or any of McCaine Wines's associated companies, within or outside Hong Kong, for direct marketing purposes and in this connection, McCaine Wines may transfer or disclose that information to any of those other companies or third parties which may provide services to McCaine Wines, within or outside Hong Kong. PI Information which may be collected over the website may be used by McCaine Wines and transferred or disclosed to any partnership with McCaine Wines in which you may invest; any of their or McCaine Wines's associated companies and any other third party which provides services to McCaine Wines , within or outside Hong Kong, for the purposes of processing any request that On-line client may make and providing any related services, including direct marketing (by means of mail drops or via the internet). McCaine Wines will cease to use your PI Information for direct marketing purposes if you request us to do so.

McCaine Wines'S POLICY IS TO RESTRICT ACCESS TO PI INFORMATION concerning individuals to employees and any third party who have a need to use that information and who have been instructed to handle such information properly and observe confidentiality. Security Passcode is electronically encrypted.

AN INDIVIDUAL OR ANOTHER PERSON PERMITTED UNDER THE ORDINANCE on his/her behalf has the right to be informed by McCaine Wines whether it holds PI Information about that individual and to request access to and/or correction of any such PI Information. In order to deal with any such request, we will require evidence from you that you are the individual in respect of whom the request is made or a person permitted under the Ordinance to make the request on that individual's behalf. We will deal with any such request as soon as possible but in any event within the 30 days maximum period set by the Ordinance.