Privacy Notice

1. Personal data we collect

Identity and contact details: name, email address, phone number, client number, and the names and emails of persons you authorise.

Account and service records: contracts, units and storage locations, end dates, bills and payments, wines bought from us, wines you add, and their valuations.

Payment information: receipts and screenshots you upload as proof of payment, which may show your name, bank, part of your account number, the amount, date and transaction reference. If card or e-wallet payment is offered, the payment provider collects your card or wallet details; we receive only the result and a reference.

Your choices: language, notification and marketing preferences, and the versions of these terms you accepted.

Technical and usage data: sign-in times; the screens you view and links you tap in metroOS; IP address and the approximate location (city and country) derived from it; device, operating system and browser type; and push notification tokens.

We obtain this data from you, from your agreements and dealings with us, from persons you authorise, and automatically when you use metroOS.

2. Is it obligatory?

Providing your email address is obligatory to sign in; without it we cannot give you access to metroOS. Other data is collected under your agreements with us or provided voluntarily, and not providing it may mean some features are unavailable.

3. Purposes of use

(a) operating your account and metroOS, and verifying your identity when you sign in; (b) administering your contracts, renewals, bills, storage and cellar services, and receiving, matching and refunding payments; (c) providing wine valuations and collection records; (d) responding to enquiries and connecting you with your representative or branch; (e) sending service notices you choose to receive, such as renewal reminders; (f) keeping our services secure, investigating misuse and preventing fraud; (g) analysing how metroOS is used to improve our services; (h) direct marketing, only with your consent (section 5); and (i) complying with legal, regulatory and accounting requirements, and establishing or defending legal claims.

4. Who we transfer it to

For the purposes in section 3, your personal data may be transferred to:

• companies within Metropolitan, and Star Group Asia and its group companies, which provide shared management, systems, accounting and customer service to Metropolitan;

• service providers who process data on our behalf under contractual confidentiality and security obligations. Cloud hosting and databases, email delivery, push notification services (such as Apple and Google), messaging and payment providers;

• banks and payment providers, to receive, match and refund payments;

• professional advisers, auditors, insurers, and any person to whom we transfer our business or rights; and

• courts, law enforcement agencies, regulators and other parties where required or permitted by law.

We do not sell your personal data.

5. Direct marketing: only with your consent

We intend to use your name, contact details (email, phone, address), language preference, and service and purchase history for direct marketing of: wine and fine wine; cellar, storage and moving services; workspace, serviced-office and meeting-room services; serviced apartments and property services; lifestyle products; and events, offers and promotions. By email, phone, SMS, WhatsApp, post or app notification.

We also intend to provide the same data to Star Group Asia and the companies within Metropolitan and Star Group Asia for their own direct marketing of the same classes of products and services. Your data will not be provided to them for gain.

We cannot do either without your consent. Your consent is optional and is not a condition of using metroOS or our services. You may withdraw it, or ask us to stop using or providing your data for direct marketing, at any time and free of charge. In the app under Me › Settings, or by contacting us (section 10). Any company you ask will stop.

6. Transfers outside Hong Kong

Our service providers store and process data on servers outside Hong Kong, currently in Japan, Singapore and the United States. These places may not have data protection laws equivalent to the Ordinance; we require our providers to protect your data with appropriate contractual and security measures.

7. Cookies and similar technologies

metroOS uses a small number of cookies and on-device storage that are necessary for it to work: to keep you signed in (for up to 180 days unless you sign out), remember your language, reopen the screen you were last on, and register push notifications. We do not use third-party advertising or cross-site tracking cookies. If you block cookies, you will not be able to sign in.

8. Retention

We keep personal data only as long as necessary for the purposes for which it was collected, including the duration of your agreements and any period required by law, accounting rules or for resolving disputes, and then delete or anonymise it. Payment records and receipts are kept for at least 7 years, as required for business records under Hong Kong law. Records of the screens you view and links you tap are deleted after 13 months. Sign-in codes expire after 10 minutes.

9. Security

We take practicable steps to protect your data against unauthorised or accidental access, processing, erasure, loss or use, including encrypted connections, one-time sign-in codes, private storage of uploaded receipts that only authorised accounts staff can open, access limited to authorised staff by role, and activity logs. No system is completely secure; please keep your email account secure and tell us promptly if you suspect misuse.

10. Your rights and how to contact us

Under the Ordinance you may request access to, and correction of, your personal data held by us, and ask about our policies and practices on personal data and the kinds of personal data we hold. You may also withdraw marketing consent at any time.

Please send requests to our Data Privacy Officer at info@metrowine.com.hk. Data access requests may be made using the Privacy Commissioner's form (OPS003). We will respond within 40 days, and may charge a fee that is not excessive for complying with a data access request, as permitted by the Ordinance.

11. Age

metroOS is not intended for persons under 18, and we do not knowingly collect their personal data through it.

12. Changes and language

We may update this notice from time to time. If changes are material, we will ask you to review them the next time you open the app. If the English and Chinese versions differ, the English version prevails.