Wines With Attitude

Wines With Attitude red logo

Privacy Policy

1. introduction

Wines With Attitude Limited (“I”) is a UK wine retailer based online.

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

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

Changes to this privacy notice

This privacy notice was most recently updated on 21 January 2023 and is compliant with the General Data Protection Regulation (“GDPR”) that came into force on 25 May 2018. Any changes that I make in the future to this privacy notice will be posted on this page. 

Contact Details

Wines With Attitude Limited is the data controller. My 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 I 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”).

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

  • Identity Data may include your first name, last name, username or similar identifier and title
  • Contact Data may include your billing address, delivery address (including delivery instructions), email address and telephone number(s)
  • Financial Data may include your bank account and payment card details
  • Transaction Data may include details about payments between me and other details of purchases made by you
  • Technical Data may include your login data, Internet Protocol address, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site
  • Profile Data may include your username and password, purchases or orders, your wine preferences and interests, feedback and survey responses
  • Usage Data may include information about how you use my site, products and services
  • Marketing and Communications Data may include your preferences for receiving marketing communications from me and your communication preferences

I 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 I might review Usage Data to work out the percentage of website users using a specific feature of my site. If I 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.

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

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


3. How I collect your personal data

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

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

  • search for or order my products or services;
  • subscribe to my services or publications;
  • request resources or marketing be sent to you;
  • enter a competition, prize draw, promotion or survey;
  • give me feedback, reviews, testimonials; or
  • report a problem with my site.

Automated technologies or interactions: As you use my site, I may automatically collect Technical & Usage Data about your equipment, browsing actions and usage patterns; I do this to be able to understand better how visitors move around my site so that I can improve it. I collect this data by using cookies and similar technologies. Please see my 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 my site may become inaccessible or not function properly.


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

  • Technical Data from the following parties:

        – analytics and search engine providers such as Google;

        – advertising network such as Google and Facebook; and

  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay; and
  • Identity and Contact data will be visible to me if you update your personal details in my newsletter subscriber list in MailChimp.

4. How I use your personal data

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

  • Where I need to perform the contract between us
  • Where it is necessary for my legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests
  • Where I need to comply with a legal or regulatory obligation.

For more information read the ICO’s description of the legal bases. Generally, I 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 me at hello@wineswithattitude.co.uk.


Purposes for processing your personal data

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

I may process your personal data for more than one lawful ground, depending on the specific purpose for which I am using your data. Please contact me if you need details about the specific legal ground I am 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 me

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

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

To manage my relationship with you which will include:

(a) Notifying you about changes to my 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 my legitimate interests to keep my records updated and to study how customers use my 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 my legitimate interests to study how customers use my products/services, to develop them and grow my business

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

(a) Identity

(b) Contact

(c) Technical

(a)  Necessary for my legitimate interests for running my 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 my advertising

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

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

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

(a) Technical

(b) Usage

Necessary for my legitimate interests to define types of customers for my products and services, to keep my site updated and relevant, to develop my business and to inform my 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 my legitimate interests to develop my products/services and grow my business


Marketing communications

You will receive marketing communications from me if you have: 

  • requested information from me or purchased goods or services from me; or
  • if you provided me with your details and ticked the box at the point of entry of your details for me to send you marketing communications; and
  • in each case, you have not opted out of receiving that marketing.

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

You can ask me 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 me at hello@wineswithattitude.co.uk at any time. Where you opt out of receiving my marketing communications, this will not apply to personal data provided to me as a result of a product/service purchase, product/service experience or other transactions.


Change of purpose

I will only use your personal data for the purposes for which I collected it, unless I reasonably consider that I 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 me.

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

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


5. Disclosures of your personal data

I 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: 

  • Delivery companies who pack and deliver or simply deliver your wine to you
  • Service providers who provide IT and system administration services
  • Mailchimp, a third party service provider through which I construct and deliver my email newsletters
  • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services
  • HM Revenue & Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances
  • Third parties to whom I may choose to sell, transfer, or merge parts of my business or my assets.

I require all third parties to whom I transfer your data to respect the security of your personal data and to treat it in accordance with the law. I 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 my 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 my 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 I transfer your personal data out of the EEA, I do my best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented: 

  • I will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or
  • Where I use certain service providers, I may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or
  • Where I use providers based in the United States, I may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

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

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


7. Data security

I 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, I 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 my instructions and they are subject to a duty of confidentiality. 

I 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 I am legally required to do so. The ICO is the UK supervisory authority for data protection issues (www.ico.org.uk).

8. Data retention

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

To determine the appropriate retention period for personal data, I 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 I process your personal data and whether I can achieve those purposes through other means, and the applicable legal requirements.

By law I have to keep basic information about my 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 me to delete your data: see below for further information. In some circumstances I may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case I 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 me. These include the right to: 

  • Request access to your personal data
  • Request correction of your personal data
  • Request erasure of your personal data
  • Object to the processing of your personal data
  • Request the restriction of processing your personal data
  • Request the transfer of your personal data
  • Withdraw consent at any time where I am relying on consent to process your personal data

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 me 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, I may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, I may refuse to comply with your request in these circumstances. 

I may need to request specific information from you to help me 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. I may also contact you to ask you for further information in relation to your request to speed up my response.

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


10. Third-party links

My 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. I do not control these third-party websites and am not responsible for their privacy statements. Ie 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 I collect and use your data, you have the right to complain to the ICO but please contact me first if you do have a complaint so that I can try to resolve it for you.

0333 772 0301

hello@wineswithattitude.co.uk

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© 2014-2023 Wines with Attitude Ltd | VAT Reg. No. 181 2419 22 | Registered in England 08918466 | Fiveways, 57-59 Hatfield Road, Potters Bar, Herts, EN6 1HS | Built by Twenty-Two