Privacy Policy

We regularly audit the personal information we hold and delete that which is not necessary.

The Wine Explorer Privacy Policy

This is the privacy policy for the Wine Explorer Limited (“WEL”, “we”, “our”, “us”). This Policy explains how and why we collect and use personal information, and what we do to ensure it is kept private and secure when we do so.

This policy governs all pages hosted at thewineexplorer.co.uk and pages hosted on any subdomain. When you visit our Website, we may collect personal information from you, either directly, or passively as you browse. Please read this policy to understand what personal information we collect and how we use it.

Contents

  • Who we are
  • The personal information we collect
  • Cookies
  • How we use your personal information
  • Legitimate interests
  • Keeping your personal information safe
  • Storage and retention
  • Disclosing your personal information
  • Disclosures required by law
  • Your rights
  • Updating this policy

1. Who we are

We are the Wine Explorer Ltd, a registered limited company in England and Wales. The registration number of which is 4477287. Our registered office is at Norfolk House 75 Bartholomew Street, Newbury Berkshire RG14 5DU. For the purposes of data protection law, we will be a controller of the personal information we hold about you. This means we make decisions about how and why your information is used and have a legal duty to make sure that your rights are protected when we do so.

If you have any questions about our Privacy Policy, please get in touch with us by writing to us at our registered address given above or telephoning us on 01189326497 (from August 15th 2018) or contacting us via our Contact page.

2. The personal information we collect

We collect the following types of personal information:

Information you give us

If you would like to take part in our Wine Explorer Community, you will need to register with us on our website www.thewineexplorer.co.uk To do so, we will need some information from you, including:

  • Your name;
  • Your contact details (postal address, e-mail address, landline and mobile phone number); and
  • Your preferred payment method and billing address. Without this information, we may not be able to deliver wine to you or provide our various wine services for you. If you apply to attend any of our wine events or wine tours, we may ask you for personal information about why you would like to attend and information about your profession. If you contact us for any reason, we may keep a record of that correspondence. We do keep a copy of this. However, we will never store your card details – these are held by our third-party payment provider.

Technical data

When you visit our Website, we may collect technical data about the device you are using, including where available your IP address, operating system and browser type. This is used for system administration and to improve the look and feel of our website.

Special Category Data (also known as sensitive personal information)

Unless you specifically provide it to us, as part of your application to attend an event or when you purchase wine, we do not collect any special categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you apply to attend a wine event and have requested reasonable accommodations in connection with a disability, we may store the information you provide to us about your disability in order to provide those accommodations if we can.

3. Cookies

A cookie is a small file of letters and numbers that we store on your browser or device, with your permission. We use the following types of cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our Websites. They include, for example, cookies that enable you to log into secure areas of our Website to buy wine. You can refuse to accept all or some cookies by modifying settings within your browser (for guidance on how to do this visit http://www.aboutcookies.org/). However, if you block strictly necessary cookies, you may be unable to access certain parts of our Website.
  • Analytical/performance cookies. These cookies allow us to recognise and count the number of visitors and to see how visitors move around our Website. This helps us to improve the way they work, for example, by ensuring that users are finding what they are looking for easily.We use third-party services such as Google Analytics to help us improve the look and feel of our Website. Google Analytics places a cookie on your browser which keeps track of certain details about your visit to our Website. These include what Google search criteria you used to find it in the first place, how long you stay on certain pages, and what website you visit immediately after leaving our own. This data will be aggregated and anonymised to the greatest extent possible. For more information about Google analytics, please visit Google’s Privacy policy. If you wish to opt out of being tracked by Google, you can do that by downloading their browser add-on.

4. How we use your personal information

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

  • With your consent or explicit consent;
  • Where we need to perform a contract with you e.g. when you purchase wine.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests (see the "Legitimate Interests" section below); or
  • Where we need to comply with a legal or regulatory obligation. If you agree, we will send you periodic e-mails about The Wine Explorer’s activities, upcoming events, wine tours, wine courses, annual retrospectives and other information that we think you might be interested in. You can opt-out of receiving these e-mails at any time by clicking the appropriate link in the e-mail itself or updating your communication preferences.

We may use personal information held about you in the following ways:

  • To process any wine orders, other purchases from the shop or wine service orders you make;
  • To fulfil any orders you make (for example, if we are selling copies of a book or wine accessories and you request that an item be sent to you, we will use the mailing address you provide);
  • To evaluate your application to attend a wine event
  • To ensure that content from our Website is presented in the most effective manner for you and for your device; or
  • To respond to queries you send us. When contacting you for any of the above purposes we may do so by phone or email, unless you tell us otherwise. Your data will be treated in accordance with applicable data protection law. It will only be shared with third-parties as described in this policy. We will never sell your personal information.

5. Legitimate interests

We may rely on legitimate interests to process your personal information, provided that your interests do not override our own. European data protection law requires us to explain what these interests are. Where we rely on legitimate interests, these interests are:

  • To keep our records updated and to study how our Website and other services are used;
  • To administer and protect the company and web presence (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting);
  • To inform our marketing strategies; and
  • To best serve our charitable aims in the most efficient manner possible.

6. Keeping your personal information safe

We employ a variety of physical and technical measures to keep your personal information safe and to prevent unauthorised access to, use of, or disclosure of it. We control who has access to your data (using both physical and electronic means), some of which are described below. Our staff receive data protection training and we have a set of detailed data protection procedures which they are required to follow when handling personal information. Our security measures include:

  • Sending all information over encrypted channels (SSL/TLS);
  • Using slow password hashing algorithms (Bcrypt);
  • Hosting data with managed VPS providers; and
  • Using PCI Compliant payment processors to avoid storing your payment details (e.g. credit card numbers). Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. We cannot absolutely guarantee the security of the internet, external networks, or your own device; accordingly any online communications (e.g. information provided by email or through our website) are at your own risk.

7. Storage and retention

Where we store your personal information

We store your personal information on secure servers. Employees and certain sub-contractors of The Wine Explorer Limited will be able to access this information.

How long we keep it

We collect and store personal information for purposes connected with our business. As such, we will only retain your personal information for as long as necessary for those purposes. If you make a purchase through our website shop, we will keep your account open and retain your personal information for 6 years from the date of your last log-in. This is because we may need this data in some way to support a claim or defence in court. That is also the period within which our tax collecting authorities may demand to see and audit our records.

We regularly audit the personal information we hold and delete that which is not necessary.

Newsletter Subscriptions

If you sign-up to our monthly newsletter, we will disclose your name and e-mail address to our partner MailChimp to manage the process of sending the completed newsletters out. You can opt out at any time by clicking the appropriate link in every newsletter we send to you.

Other Disclosures

If we choose to sell, transfer, or merge parts of the business or our assets, we may disclose your personal information to the new owners. Alternatively, we may seek to merge with another company. If a change like that happens, then the new owners may use your personal information in the same way as set out in this policy.

9. Disclosures required by law

We are subject to the law like everyone else. We may be required to give information to legal authorities if they so request or if they have the proper authorisation such as a search warrant or court order. We also may need to retain and disclose certain personal information about you to regulatory authorities and to appropriate agencies to conduct anti-money laundering and trade sanction checks and to assist with fraud prevention. We will disclose this information as is required by law.

10. Your rights

We want you to remain in control of your personal information. Part of this is making sure you understand your legal rights, which are as follows:

  • Where your personal information is processed on the basis of consent, the right to withdraw that consent;
  • The right to confirmation as to whether or not we are holding any of your personal information and, if we are, to obtain a copy of it;
  • From 25 May 2018, the right to have certain data provided to you in a portable electronic format (where technically feasible);
  • The right to have inaccurate personal information rectified;
  • The right to object to your personal information being used for marketing or profiling, or on the basis of our or a third party’s legitimate interests;
  • The right to restrict how your personal information is used; and
  • The right to be forgotten, which allows you to have your personal information erased in certain circumstances (though this is not an absolute right and may not apply if we need to continue using it for a lawful reason). If you would like further information about any of your rights or wish to exercise them, please contact us using the details given in section 1. Please also keep in mind that there are exceptions to the rights above and, though we will always try to respond to your satisfaction, there may be situations where we are unable to do so (for example, because the information no longer exists or there is an exception which applies to your request). If you feel that your rights have been infringed, you should contact the UK Information Commissioner's Office, which oversees data protection compliance in the UK. Details of how to do this can be found at www.ico.org.uk.

11. Updating this policy

We may update this Policy at any time. When we do, we will post a notification on our Website and we will also revise the updated date at the bottom of this page. We encourage users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we hold.

This policy was last updated on 29th May 2018.

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