Privacy Policy for Winebanc Website

Protection of your personal data is important to StorHub Hong Kong Management Limited, its affiliates and subsidiaries (collectively, “StorHub” or “we” or “us”). This Privacy Policy (together with our Website Terms and Conditions found at https://winebanc.hk/terms-and-conditions) outlines how StorHub collects, uses, discloses and/or processes your personal data which may have been or may be collected by us or through https://winebanc.hk (“Website”).

In Summary

StorHub will collect, disclose, use and/or process the personal data you have provided to us for the purposes stated below in accordance with the Personal Data (Privacy) Ordinance (Cap. 486, Laws of Hong Kong) (“PDPO”). We may also collect, use or disclose personal data without your consent if it is required, permitted or authorised under the PDPO).

By using our Website or otherwise providing us with your personal data, you acknowledge that you have read, understood, and also agree to the terms of this Privacy Policy and the collection, use, disclosure and/or processing of your personal data by us as described in this Privacy Policy.

Collection of Personal Data

We may collect your personal data, which refers to any data, whether true or not, about a living individual who can be identified from that data or from that data and other information to which we have or are likely to have access to, such as your name, telephone number(s), residential address, correspondence address, email address, IP address, cookie information, date of birth, any correspondence between you and us, and any other information relating to individuals, which you provide to us. If you provide us with personal data relating to a third party, you represent and warrant that you shall ensure accuracy of such personal data provided at all times, and have obtained such third party’s prior written consent for our collection, use and disclosure of such third party’s personal data for the relevant purposes, except to the extent that such consent is not required under relevant laws.

Cookies may be used on some pages of our Website. We use traffic log cookies to identify which pages are being used. Cookies allow web applications to respond to you as an individual and can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. This helps us analyse data about web page traffic and improve our Website in order to tailor it to customer needs. We only use this information for statistical analysis purposes, and then the data is deleted from the system once such purposes have been fulfilled. A cookie in no way gives us access to your computer or any information or data about you, other than the information or data you choose to share with us. You can choose to accept or decline cookies by modifying the settings in your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.

Use of Personal Data

We will only collect, use, disclose and/or process your personal data for one or more of the following purposes:

  • to offer you a more personalised experience and better serve your needs by customising the content that we share with you;
  • to facilitate, process, deal with, administer, manage and/or maintain your account with us, including but not limited to verification of your identity, as well as processing and administering any requests that you may have;
  • to process payments;
  • to facilitate, process, deal with, administer, manage insurance, invoicing, or financing matters;
  • to provide, manage, operate, process and/or administer our services and your access to our facilities and premises;
  • to conduct credit and background checks;
  • to resolve issues that you may encounter regarding our services, products and/or use of our Website;
  • to contact you through the contact information provided by you in order to provide you with the information that you request from us;
  • to evaluate your storage needs and provide recommendations of suitable storage products and services to you;
  • to conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our Website services, products and facilities, and in order to enhance the customer service we provide to you;
  • to process and administer your registration and participation in contests, promotions, surveys, marketing activities or other Website features;
  • to send periodic updates, communication, including but not limited to marketing and promotional materials via electronic email, where you have consented to such purposes;
  • to protect the rights, property or safety of any person (including for the purposes of fraud detection and prevention);
  • to respond to legal process, pursue legal rights and remedies, defend litigation and manage any complaints or claims;
  • to comply with any applicable laws and regulations, as well as any rule, request, requisition, requirement, directive, order, ordinance, circular, guideline, or to assist in investigations conducted by any governmental, regulatory, public or other authority, whether within or outside Singapore;
  • to share information with, or respond to any requests for information from, any affiliates, associates or related entities, and for audit, compliance, investigation and inspection purposes or otherwise;
  • to enforce or apply our Website Terms and Conditions;
  • to store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Singapore;
  • to compile reports and market studies for StorHub, Self Storage Association Asia and/or their affiliates;
  • for record-keeping purposes; and
  • to achieve any other incidental business purposes related to or in connection with the above.

The email address you provide when you fill out a form on our Website may be used to send you information and updates pertaining to your request or feedback. We may also use your email address to provide you with occasional company news, latest promotions, marketing updates, related product or service information, if you choose to receive them. If you would like to stop receiving such emails in future, we include the option to unsubscribe at the bottom of each email.

We may also seek your consent and/or notify you separately of the purposes of the collection, use, disclosure, and processing of your personal data from time to time with respect to particular products and services. Any consent that you have given for marketing purposes is not affected by the termination or suspension of your account but you may withdraw your consent for marketing purposes at any point in time by either updating your preferences using the unsubscribe function at the bottom of each email or by contacting us in the manner set out below under the section titled “Contact Us”.

Storage and Protection of Personal Data

StorHub respects your confidentiality and privacy – the protection of personal data within our possession is a matter which we take very seriously.

Your personal data is stored in a combination of secure computer storage facilities and paper-based files and other records. We take reasonable steps to maintain appropriate physical, technical and administrative security to protect the personal data we hold from misuse, loss, unauthorised access, collection, copying, disposal, modification, disclosure or similar risks, or the loss of any storage medium or device on which personal data is stored.

You should be aware, however, that no method of transmission over the Internet or method of electronic and physical storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your personal data, and are constantly reviewing and enhancing our security measures.

Within StorHub, we limit access to your personal data to authorised employees who reasonably need to use that data to provide services to you.

Should we become aware of any unlawful or unauthorised access, use or disclosure of your personal data, we will notify you if and as may be required under the PDPO, as well as take reasonable steps to mitigate the effects of any data breach.

Retention of Personal Data

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

StorHub will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for any legal or business purpose.

Your Rights and Options Regarding Your Personal Data

Access to and Correction of Personal Data

If you wish to make:

  • an access request for access to a copy of the personal data which we hold about you or information about the ways in which we had used or disclosed your personal data in the one (1) year prior to the date of your request; or
  • a correction request to correct or update any of your personal data which we hold about you,
  • you may submit your request in writing to us, in the manner set out below under the section titled “Contact Us”.

In accordance with the requirements of the PDPO, we may charge you a reasonable fee to respond to your request for access. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within forty (40) days after receiving your request, we will inform you in writing within forty (40) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so except where we are not required to do so under the applicable laws.

Disclosure of Personal Data

We do not sell or trade your personal data with any third parties under any circumstances.

We may disclose your personal data to trusted third parties, whether sited in Hong Kong or outside of Hong Kong (including the People’s Republic of China), who assist us in operating our Website, customer relationship management systems, property management systems, payment systems and other operational systems, conducting our business or servicing you, so long as these third parties agree to keep the personal data confidential. If required by applicable laws, including the PDPO, we will enter into contractual undertakings to ensure that the personal data which we collect from you and transfer to such third parties (whether or not located in Hong Kong) is adequately protected.

We may also release your personal data when it is permitted or required by law.

Accuracy of Personal Data

As StorHub relies on your personal data to provide services to you, you should ensure that the information provided by you to us is correct, accurate and complete. You should update us in a timely manner of all changes to the personal data and other information provided to us, by contacting us in the manner set out below under the section titled “Contact Us”.

Changes to this Privacy Policy

This Privacy Policy was last updated on 2 October 2023.

This Privacy Policy will be reviewed and updated from time to time. We will use commercially reasonable methods to notify you of such revisions, such as by publishing the revised policy on our Website. Your continued use of our Website and/or the services made available on or via our Website following any amendment of this Privacy Policy shall constitute your acceptance of its revised terms and conditions.

Contact Us

If you have any questions or concerns about how StorHub collects, uses, disclosures, processes or otherwise handles your personal data, or wish to access or correct your personal data, or if you believe we have not complied with this Privacy Policy or the PDPO, please contact our Data Protection Officer at [email protected].

We take any question, complaint or feedback relating to data privacy matters very seriously, and will strive to respond to you as soon as possible.