Dear Customer,

The purpose of this letter is to advise you that following amendments made to the Personal Data (Privacy) Ordinance and with effect from 1 April 2013, your consent or indication of no objection is required for us to use your personal data for direct marketing. The attached “Circular”, describes the data which we collect from you and which we propose to use for direct marketing and the type of marketing subjects which we propose to market by way of direct marketing. Under the Ordinance, we require your consent or indication of no objection before we are able to do this.

【For use in relation to persons of 18 years of age and over】

On Excel Fine Wine Limited

CIRCULAR (“CIRCULAR”) RELATING TO THE PERSONAL DATA (PRIVACY) ORDINANCE (THE “ORDINANCE”)

1. Collection of Personal Data: From time to time, it is necessary for the Company to collect personal data in connection with its activities from its customer, officials, officers and employees (“Data”).

In this circular, the term “Relevant Person” means customer, officials, officers and employees.

2. Purposes of Collection:

(i) The purposes for which personal data are divided into obligatory purposes and voluntary purposes. If Data are to be used for an obligatory purpose, the Relevant Person MUST provide his/her data to the Company if he/she wants the Company to admit a person to customer or appoint a person to act in any official capacity or to be employed by the Company. Failure to supply such Data may result in the Company being unable to admit a person to customer, to appoint a person to act in any official capacity or to employ a person.
(ii) If personal data are only to be used for a voluntary purpose, the Relevant Person can tell the Company not to use Data for that purpose and the Company will not do so.
(iii) Purposes for which it is obligatory for the Relevant Persons to provide Data are as follows:

(a) the daily operation of the Company;
(b) employment purposes including payroll, mandatory provident fund schemes, promotion, assessment or termination;
(c) customer registration, correspondence with Relevant Persons or other related purposes;
(d) official registration, recording of information relating to qualifications of officials and officers and officers assessments;
(e) providing news to customer, officials and officers regarding events and activities organized by the Company through any of its divisions;
(f) providing notices to customer of activities, training courses, interest groups, classes, workshops, gatherings, exchange programmes, tours, trips, excursions, meetings, forums, conferences, and campsites and other activities;
(g) providing newsletters, reports, promotional pamphlets, periodicals or other documentation issued by the Company or other organizations or government departments;
(h) providing invitations to attend programmes and activities or join in competitions/nominations which are organized by other organizations or government departments;
(i) purposes directly relating to the purposes listed above.

3. Transferring of Data to Other Persons: The Company may provide your personal data to any other persons whether or not such persons are customer of the Company and/or any other persons who need to use your personal data for operational purposes or any other purpose4s related to Guiding. These persons include:

(i) Staff of Sponsoring Authorities including schools and welfare agencies which sponsor the Company or its activities;
(ii) customer of different Working Committees and Organizing Committees set up by the Company for the purposes of advising and assisting in the operations of the Company; and
(iii) customer of Regional Company or District Company established to support and take an interest in local units;
(iv) in relation to office bearers of the Company, to banks for the purpose of bank account opening in respect of the operation of Guiding units.

4. Direct marketing: The Company wishes to use the Data for direct marketing in the manner provided in this paragraph – permission to use Data for this purpose is voluntary only. The Company must obtain a written consent (which can include an indication of no objection) if it is to use Data for this purpose.

In this connection:

(i) the name, phone number (mobile or residential), address (office and residential), email address, SMS (Short Message Service), fax number (office and residential) of a Relevant Person held by the Company from time to time may be used by the Company for direct marketing;
(ii) the following classes of services, products and subjects may be marketed:

(a) solicitation of donations to the Company;
(b) sale of goods namely souvenirs, publications;
(c) participation in paid events such as courses, activities, programmes, workshops, seminars, tours, trips, excursions, exchange programmes, camps, conferences, use of campsites and properties or programmes and activities which are organized by other organisations, government department.

If a Relevant Person does not wish the Company to use his/her Data for use in direct marketing as described above, he/she may say so in the Request form or notify the Company of the same at any other time.

5. Right of Access and Correction: Under and in accordance with the terms of the Ordinance, any individual has the following rights:

(i) to check whether the Company holds Data about him/her and the right of access to such data;
(ii) to require the Company to correct any Data relating to him/her which are inaccurate; and
(iii) to ascertain the Company’s policies and practices in relation to Data and to be informed of the kind of personal data held by the Company.

In accordance with the terms of the Ordinance, the Company has the right to charge a reasonable fee for the processing of any data access or correction request.

6. Data Protection Officer: For the purposes of paragraphs 2and 5 above, the person to whom (i) consents, objections and opt-outs in relation to the use or provision of personal data for direct marketing and (ii) requests for access to data or correction of data or for information regarding policies and practices and kinds of data held, are to be addressed is as follows:

On Excel Fine Wine Limited
Unit 810, Core F,
Cyberport 3,
100 Cyberport Road,
Hong Kong.

Phone no: 【2522 1618】
Fax no: 【2522 1606】
Email: info@onexcelfinewines.com

7. Nothing in this Circular shall limit the rights of the Relevant Persons under the Ordinance.

If there is any inconsistency or conflicts between English and Chinese version, the English version will prevail.