Privacy Policy

The Hong Kong , Personal Data (Privacy) Ordinance (Cap. 486) regulates the processing of personal data in commercial transaction and applies to OENOVIVA CAPITAL RESOURCES and its related corporations (hereinafter referred to as “OENOVIVA”, “our”, “us” or “we”).

Kindly note that your access to and use of our products, services and its contents (the “Service”) is subject to the terms and conditions of this Privacy Policy (“Privacy Policy” or “Policy”) and all applicable laws.

By accessing and using this Service, you accept and agree to these terms and conditions without any limitation or qualification. For the purpose of this Privacy Policy, the terms “Personal Data” and “processing” shall have the meaning prescribed in the Personal Data (Privacy) Ordinance (Cap. 486).

OENOVIVA will occasionally update this Privacy Policy to reflect OENOVIVA, our customers’ and our users’ feedback.


This Privacy Policy applies to all operations and business units and associated parties of OENOVIVA. To the extent any operations or business unit of OENOVIVA already has a data protection notice in place; this Privacy Policy shall supersede and replace any such notice.


This notice is effective as at 1st April 2019.


3.1. General Principle:

3.1.1. This Privacy Policy serves to inform you that OENOVIVA is processing your Personal Data. The Personal Data processed by us include name, identification number, residential address, Bank account and other personal details and any such information as may be required from time to time.

3.1.2. By continuing to use OENOVIVA services and/or products, you hereby consent to OENOVIVA processing of your Personal Data in accordance with this Privacy Policy.

3.1.3. If you are under 18, you should ensure that you obtain the consent of your parents or legal guardian before using our services and/or products.

3.2. Notice and Choice Principle:

3.2.1. Please be informed that OENOVIVA may process your Personal Data for the following reasons:-

      • for the performance of OENOVIVA ’s contract with you;
      • to provide you with goods and/or services;
      • for profiling your Service preferences;
      • to assess your needs and provide better service;
      • for compliance with any legal and/or regulatory obligations;
      • for maintaining financial records, assessing or verifying credit and facilitating payments of any amount due to OENOVIVA;
      • to establish and maintain a common database of customers or processing of data as an outsourced entity both within and outside Hong Kong;
      • to send you information, promotions and updates including marketing and advertising materials in relation to our goods and services and those of organizations selected by OENOVIVA unless you have otherwise notified OENOVIVA that you do not wish for OENOVIVA to process your Personal Data for such purpose ;
      • to recover any amount due to OENOVIVA;
      • for purposes associated with the detection or prevention of crime and/or fraud;
      • for purposes of any legal proceedings related to the Services;
      • to protect OENOVIVA ’s vital interests;
      • for the administration of justice;
      • for the exercise of any functions conferred on any person by or under any law. Such other purposes as may be related to the foregoing. (collectively known as “Purposes”)

3.2.2. OENOVIVA collects your Personal Data from customer application forms, prepaid registration forms, customer relationship managements systems and our network systems.

3.2.3. It is obligatory that you supply OENOVIVA with the Personal Data in the relevant forms. Should you fail to supply OENOVIVA with the above Personal Data or subsequently withdraw your consent to OENOVIVA processing of your Personal Data, OENOVIVA may not be able to continue providing you with certain Services and/or process your Personal Data for any one above Purposes (save and except for the purposes of direct marketing).

3.3. Disclosure Principle:

3.3.1. OENOVIVA may disclose your Personal Data to certain third parties for the purposes of complying with any government agency notification requirements; and/or for the Purposes above. Such third parties include without limitation OENOVIVA service providers, agent, contractors, regulatory bodies and government authorities.

3.3.2. In addition to the aforesaid, OENOVIVA is obliged to disclose your cell phone number to other network operators to enable the use of the Services.

3.3.3. OENOVIVA may from time to time, contact you on behalf of our external business partners about particular goods, offers or services that may be of interest to you. In those cases, Personal Data that may identify you will not be transferred to the third party. All communication whether from OENOVIVA or OENOVIVA’s business partners will be sent to you by OENOVIVA. You will be given the opportunity to ‘opt-out’ from having your Personal Data processed for such direct marketing purposes at the point where OENOVIVA asks for information. If you do not wish to receive OENOVIVA’s promotional updates you may opt-out of receiving these communications by contacting OENOVIVA at our contact details as prescribed below.

3.3.4. OENOVIVA may also disclose your Personal Data to subsidiaries, its parent company or any other entity for the Purposes.

3.3.5. Save in accordance with this Privacy Policy and except as permitted or required under any enactment, law, statute or code, OENOVIVA will not use or disclose your Personal Data without prior consent.

3.4. Security Principle:

OENOVIVA shall take practical steps to safeguard the confidentiality and security of all Personal Data, including appropriate procedural, organizational and technical steps to protect your Personal Data from accidental or unlawful destruction or accidental loss, alteration or disclosure. Procedures for implementing these steps will be communicated to all OENOVIVA’s employees and third party service providers as prescribed in Paragraph 3.3.

3.5. Retention Principle:

OENOVIVA shall not retain the Personal Data longer than it is necessary for the fulfilment of the Purposes above. OENOVIVA shall also take reasonable steps to ensure that the Personal Data is destroyed or permanently deleted if it is no longer required.

3.6. Data Integrity Principle:

3.6.1. OENOVIVA strives to maintain complete, current, and accurate information about its customers. Any inaccurate information that is brought to OENOVIVA’s attention will be corrected as soon as reasonably practicable after notification. Procedures will be maintained to ensure that any reported inaccuracies are promptly and effectively handled and that customers’ information remains as accurate, current and complete as possible.

3.6.2. Notwithstanding the foregoing, you are responsible for ensuring that the Personal Data you provide to OENOVIVA is accurate, complete and not misleading and that such Personal Data is kept up to date. Failure to provide complete and correct information to OENOVIVA as required in the relevant forms as prescribed in Paragraph 3.2, may result in your application for Services being rejected, the Services or the relevant agreements being terminated and/or correspondence from OENOVIVA relating to relevant matters may fail to reach you.

3.7. Access Principle:

3.7.1. You may access and request for correction of your Personal Data and to contact us with any enquiries or complaints in respect of your Personal Data as follows:

E-mail address:

In accordance with the Personal Data (Privacy) Ordinance (Cap. 486):

      • We may charge a fee for processing your request for access or correction; and
      • We may refuse to comply with your request for access or correction to your Personal Data.


4.1. OENOVIVA provides products and services via its various websites. When a customer visits OENOVIVA’s websites the web servers generally record anonymous information such as the time, date and URL of the request. This information assists OENOVIVA to improve the structure of its websites and monitor their performance. From time to time OENOVIVA may also use third parties to analyse this information.

4.2. For the purpose of using OENOVIVA’s websites OENOVIVA may require standard information such as your Login ID, passwords and other Personal Data as prescribed above. This information is necessary for OENOVIVA to provide the Services. You are required to maintain the secrecy of your Login ID and Password enabling you to access the OENOVIVA home page and Member Management Areas. It is strongly stressed that OENOVIVA will not be able to secure the Personal Data if you reveal your Login ID and Password to anyone, and as such, is not liable for any breach of Personal Data..


5.1. OENOVIVA also collects Internet Protocol (IP) addresses. IP addresses are assigned to computers on the Internet to uniquely identify them within the global network. OENOVIVA collects and manages IP addresses as part of the service of providing internet session management and for security purposes.

5.2. OENOVIVA’s websites may transmit to any customer’s computer a “cookie”. A cookie is a package of data that allows OENOVIVA’s server to identify and interact more effectively with the customer’s computer having to spend time on identifying each user, thereby also providing additional login convenience. The customer may configure and personalise its current browser to refuse, reject or delete such cookies.


Any enquiries regarding personal data privacy policy and practice may be addressed to,




E-mail address:

We keep our privacy policy statement under regular review. This statement was last updated on 16TH APRIL 2019