Privacy Policy

This Data Privacy and Security Policy (Privacy Policy) sets out how Sea Change  collects, stores and handles your Personal Data (i.e. any personal data that can be used to identify you as an individual).  This Privacy Policy is intended to ensure you can make informed decisions about supplying Personal Data relating to you when purchasing our products and using our services. 

Privacy Policy

Sea Change Wine is committed to protecting the privacy, confidentiality and security of the personal information we hold about our users and customers by complying with the requirements of the Personal Data (Privacy) Ordinance of Hong Kong Special Administrative Region of the People’s Republic of China (“Hong Kong”). We are equally committed to ensuring that all our officers, management and members of staff shall at all times respect the confidentiality and security of your personal information. 

This privacy policy (“Privacy Policy”) is intended to inform you about how we collect, store and use your personal information. It applies to information collected by us, or provided by you, on our web site, or in any other way (such as over the telephone). 

This Privacy Policy applies only to the web site maintained by us but not to any other companies or organisations to which we link and specifically addresses our obligations in respect of the data privacy laws of Hong Kong. 

Please take a minute to read and understand this Privacy Policy as it will assist you in making informed decisions about providing us with your information. 


We request information from you on our website, mobile services and other channels. The type of personal information we collect (“Data”) may include but is not limited to: 

  • Name
  • Gender
  • Date of birth
  • Mailing address
  • Mobile number
  • Telephone number
  • Email address
  • Nationality
  • Written language

From time to time we may give you the option to provide us with information about other people in your life. We use this Data to tell you about offers that may be relevant to your friends or family members. We will never use this information to contact your friends or family members directly. 

The provision of your personal data to us is voluntary. However, if you do not provide sufficient information, we may not be able to provide specific services to you. 

We may also collect information relating to your online session, including but not limited to the browser type and version, operating system, the IP address, geographical location of your computer, your domain name and/or URLs, the use of which is for providing statistical information so that we can provide better services. 

Our site may use a technology called “cookies” to collect information from you without your knowledge. The personal information collected may include relevant login and authentication details as well as information relating to your activities and preferences across our site. Cookies allow us to [calculate the number of people visiting our site, track users’ progress and measure users’ traffic patterns]. This will enable us to provide better services to you. 

If you refuse to accept cookies by activating relevant browser settings, you may be unable to access certain parts of our site. 


We may use the Data you provide for purposes described in this Privacy Policy or disclosed to you on our site or with our services, for example: 

  • To allow you to register with us and create an account or process any products and services requests available on our Website where you choose to do so
  • To notify you about changes to our service
  • In accordance with your wishes as communicated to us at the point of Registration (for example: registration to our newsletter or mailing list)
  • If you have given your consent at the point of Registration (for example: registration to our newsletter or mailing list), to contact you with information about products, services and special offers that you request from us, or that we feel may be of interest to you
  • To ask you to participate in one of our online feedback questionnaires
  • To fulfill your request when you use our online, mobile or other services
  • For identification and verification purpose 
  • For checking of your credit, payment and/or status in relation to the supply of products and services to you
  • For processing of any payment instructions or credit facilities in relation to supply of products and services to you
  • For the use of any of our subsidiaries, associate companies and/or business associates in connection with any of the above purposes and/or services such companies may be offering to you from time to time

We will never knowingly or intentionally use or share the Data you provided to us in ways unrelated to the purposes aforementioned. 

How we transmit, protect and store Personal Data

Security of communications 

It is important to note that no security system or system of transmitting information over the Internet can be guaranteed to be one hundred percent secure. There is a risk inherent in the submission of information online and theuse of email and facsimile. Please be aware of this when requesting information or sending forms to us online or by email or facsimile, for example, from the “Contacting us” section. We recommend that you do not include any sensitive information including credit card details when submitting information online, using email, facsimile or when using any public computers/public WIFI.

Security controls

We maintain commercially reasonable administrative, technical and physical safeguards designed to protect the Personal Data we maintain against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.  Despite such efforts, however, please note that no company can fully eliminate risks or guarantee complete security of personal information. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of your information. While we strive to put in place appropriate contractual protections, we are unable to guarantee the security of Personal Data hosted on databases run by third parties, and we bear no liability for uses or disclosures of personal information or other data arising in connection with theft of the information or other malicious actions.

We store certain customer information and order details in our Customer Information System on our subcontractor’s secure servers. Our server resides behind firewalls designed to protect Personal Data collected from you against unauthorised or accidental access. Because laws applicable to personal information vary by country, we may put in place additional measures that vary depending on the applicable legal requirements.

Personal Data transmission across international borders 

The nature of our business and our operations require us to transfer your Personal Data to other group companies, properties, centres of operations, data centres, or service providers that may be located in countries outside of your own for the purposes mentioned in this Privacy Policy. Although the data protection and other laws of these various countries may not be as comprehensive as those in your own country, the Sea Change will take appropriate measures, including contractual clauses, to secure the transfer of your Personal Data to recipients located in a country with a level of protection different from the one existing in the country in which your Personal Data is collected.

*Currently, customer data may be transferred to our headquarters in the UK as well as other countries where we are present, including China, Japan, Vietnam, United Kingdom, United States of America, Thailand, the Philippines and France. We also use third party service providers which are located in countries such as China and the USA to process mailing, certain online orders and purchases of gift cards.

Your Personal Data may be accessed by staff or suppliers, transferred, and/or stored outside of Hong Kong SAR including to countries which may have a lower level of data protection than under HKSAR data protection laws. When we do this, we will use appropriate safeguards to protect any Personal Data being transferred.  

Your Personal Data will be stored for the period of time required or permitted by law in the jurisdiction of the operation holding the information (e.g. certain transaction details and correspondence may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). So if information is used for two purposes we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires.


Your Data held by us will not be disclosed or transferred to any other party but we may, where such disclosure is necessary to satisfy the purpose, or a directly related purpose, for which the Data was collected, provide such information to the following parties: 

  • Any of our subsidiaries, associate companies, business associates, or affiliates upon your consent
  • Any person who is acting for or on behalf of us or jointly with us for administrative or other purposes deemed necessary in order to maintain or improve our services
  • Government and regulatory authorities and law enforcement agencies and other organisations as required or authorised by law

The Data that we collect from you may be transferred to, and stored at, a destination outside Hong Kong and you consent to such transfer. We will take all necessary steps in order to ensure that any Data is treated securely in accordance with this Privacy Policy. 


Your Data will be retained by us for as long as it is necessary to fulfil the original or directly related purposes for which it was collected, unless the Data are also retained in order to satisfy any applicable statutory or contractual obligations. 


You are entitled to access and make changes to any Data relating to you held by us. 

We advise you to update the Data by e-mailing us at

You may request access to all your information that we collect online and maintain in our database by writing to us at the following address: 

10 International Ltd, The Lodge, Guildford Road Effingham, Leatherhead, Surrey, KT24 5PE, United Kingdom.  


In accordance with the terms of the Hong Kong Personal Data (Privacy) Ordinance, we are entitled to charge a reasonable fee for the processing of any data access request. 

To change the email address you have used to subscribe to our newsletter please contact  


By using our site you consent to our collection and use of the information as described in the Privacy Policy. If we change our privacy policy, we will post it to the web site or otherwise notify you of all changes. 


This web site contains links to other sites that do not follow the Privacy Policy. Please be aware of other web site’s privacy policies once you leave our site. We have no control over Data that is submitted to these third parties. 


The provision of your personal data is your choice, as are the types of information you would like to receive from us. We will occasionally send you updates about our latest products and services, as well as special offers to those who subscribe to these services. 

If you would not like to receive any updates from us, please e-mail us at