Wines With Attitude Privacy Notice

 

1. INTRODUCTION 

Wines With Attitude Limited ("we") are a UK wine retailer based online.

This privacy notice (together with our Sales and Purchase of Goods Terms & Conditions and any other documents referred to in it) provides you with details of how we collect and process any personal data through your use of our website, https://www.wineswithattitude.co.uk/ ("our site") or when you sign up to our newsletter or when you communicate with us by post, phone, email or otherwise. This includes information you provide when you register to use our site or place an order on our site (see Paragraph 3 for more examples).

By providing us with your data, you warrant to us that you are over 18 years of age. It is very important that the personal data we hold about you is accurate and up to date. Please let us know if at any time your personal data changes by emailing us at hello@wineswithattitude.co.uk

Changes to this privacy notice

This privacy notice was most recently updated on 03 May 2018 and is compliant with the General Data Protection Regulation ("GDPR") that comes into force on 25 May 2018. Any changes that we make in the future to this privacy notice will be posted on this page. 

Contact Details

Wines With Attitude Limited is the data controller. Our contact details are:

Email address: hello@wineswithattitude.co.uk

Telephone: 0333 772 0301

Postal address:   Fiveways, 57-59 Hatfield Road, Potters Bar, Hertfordshire EN6 1HS 

 

 2. WHAT DATA WE COLLECT ABOUT YOU

Under the GDPR personal data means any information about you from which you can be identified. It does not include data where your identity has been removed ("anonymised data").

We may process certain types of personal data about you as follows: 

We may also process Aggregated Data from your personal data but this data does not reveal your identity and is not therefore personal data - for example we might review Usage Data to work out the percentage of website users using a specific feature of our site. If we were to link the Aggregated Data with your personal data so that you could be identified from it (which is extremely unlikely), then it would be treated as personal data which would be used in accordance with this privacy notice.

We do not collect any Special Categories of Personal Data about you (this includes for example details about your race or ethnicity). Nor do we collect any information about criminal convictions and offences.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). In this case we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

 

 3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through: 

Direct interactions: You may provide data by filling in forms on our site (or otherwise) or by communicating with us by post, phone, email or otherwise, including when you:

Automated technologies or interactions: As you use our site, we may automatically collect Technical & Usage Data about your equipment, browsing actions and usage patterns; we do this to be able to understand better how visitors move around our site so that we can improve it. We collect this data by using cookies and similar technologies.  Please see  our cookie policy for more information.

Please note that you can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. But if you disable or refuse cookies, please note that some parts of our site may become inaccessible or not function properly. 

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

        - analytics and search engine providers such as Google;

        - advertising network such as Google and Facebook; and

 

 4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to do so. The most common legal bases for using personal data are: 

For more information read the ICO's description of the legal bases. Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email, text or similar messages. You have the right to withdraw consent to marketing at any time by emailing us at hello@wineswithattitude.co.uk.

 

Purposes for processing your personal data

Set out below is a description of the ways we intend to use your personal data and which of the legal bases above we rely upon to do so. We have also identified what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below: 

 Purpose/Activity

Type of data

Lawful basis for processing

To register you as a new account / customer

(a) Identity 

(b) Contact

Performance of a contract with you

To process and deliver your order including:

(a) Managing payments, fees and charges


(b) Collecting and recovering money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b)  Necessary for our legitimate interests to recover debts owed to us

To manage our relationship with you which will include:


(a) Notifying you about changes to our terms or privacy policy


(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b)  Necessary to comply with a legal obligation

(c)   Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services

To enable you to partake in a prize draw, competition or complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b)   Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business

To administer and protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a)  Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise

(b)    Necessary to comply with a legal obligation

To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy

To use data analytics to improve our site, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy

To make suggestions and recommendations to you about goods or services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

Necessary for our legitimate interests to develop our products/services and grow our business

  

Marketing communications

You will receive marketing communications from us if you have: 

We do not share your personal data with any third party for marketing purposes but if we ever were to do so we would obtain your express opt-in consent before we shared it. 

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by emailing us at hello@wineswithattitude.co.uk at any time. Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.

 

 5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above: 

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We do not allow such third parties to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

 

 6. INTERNATIONAL TRANSFERS

Countries outside of the European Economic Area ("EEA") do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria. 

Some of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA. Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented: 

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time. 

Please email us at hello@wineswithattitude.co.uk if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

 

 7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. 

We have put in place procedures to deal with any suspected personal data breach and will notify you and the Information Commissioner’s Office ("ICO") of a breach where we are legally required to do so. The ICO is the UK supervisory authority for data protection issues (www.ico.org.uk).

 

 8. DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes. In some circumstances you can ask us to delete your data: see below for further information. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 9. YOUR LEGAL RIGHTS 

Under certain circumstances, you have rights under data protection laws in relation to your personal data held by us. These include the right to: 

You can read more about these rights on the ICO's website.

If you wish to exercise any of the rights set out above, please email us at hello@wineswithattitude.co.uk. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. 

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

 10. THIRD-PARTY LINKS

Our site may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy notice of each website that you visit.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to hello@wineswithattitude.co.uk.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the ICO but please contact us first if you do have a complaint so that we can try to resolve it for you.

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