PRIVACY POLICY

This Privacy Policy is effective upon 24 May 2018.

For the purpose of the UK Data Protection Act 2018 and the General Data Protection Regulation (GDPR) 2016 (the Law), the data controllers for any personal information that we hold about you are CITY WINE COLLECTION LIMITED, 2 Bridge Street, Richmond Upon Thames, Surrey, TW19 1TQ, United Kingdom.

This Privacy Policy aims to give you information on how we collect and process your personal data. This Privacy Policy describes our services, use, disclosure, retention and protection of your personal data. By navigating to the CITYWINECOLLECTION.COM website or mobile view, by transacting and by registering an account, you are agreeing to the terms of this Privacy Policy.

What personal data do we collect and why?

We collect, process and retain personal information from you and any devices you may use when you navigate to the CITYWINECOLLECTION.COM website or mobile view, by transacting, by registering an account and otherwise interacting with us. The personal information we collect includes the following:

• Personal information, including payment related information, that you give us when you join our mailing list and/or make a purchase via our website, social media sites, City Wine Collection store or event;

• Content that you generate when interacting with our customer services team including details we require to contact you and verify your identity;

• Other content that you generate through browsing activity; and

• Device identifiers such as IP addresses, cookie IDs, IDFAs and other device identifiers, as well as geo location information, IoT technologies and connection information such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your browsing history, hashed email addresses, and your web log information.

• We use cookies, web beacons and similar technologies to collect information about the pages you view, the links you click and other actions you take on our Services, within our advertising or e-mail content.  Cookies are text files stored on your computer when you visit web pages.

Managing cookies: most web browsers have cookies enabled; if you’d prefer to restrict, block or delete cookies from CITYWINECOLLECTION.COM, or any other website, you can use your browser to do this. Each browser is different, so check the Help menu of your particular browser (or your mobile phone’s handset manual) to learn how to change your cookie preferences.

Under the Law, we must have a legal basis to process your data. In most instances, we will process your data because we have a contract with you to deliver your purchases, or to provide you with other services that you have requested:

• We use the personal information we collect to provide and improve our services, contact you about your account, provide you customer service, provide you with personalized marketing, and detect, prevent, mitigate and investigate fraudulent or illegal activities.

• We process personal data for purchases, payments, customer support and fulfilment to enable us to perform our contract with you; where your contact details and transactional information are processed.

• We also use your personal data, with your permission, to send you sales and marketing information, including wine offers, tasting notes and other related information. You can opt out of sales and marketing communications from us at any time.

How long do we keep your data?

We will not retain your personal data for longer than is necessary to fulfil the purposes for which you provided that personal data, unless the law permits or requires that we retain if for longer. The retention period varies depending on the purpose of the processing. For example, the data collected during your purchase of goods are retained in accordance with local tax law (seven years in the UK), whilst data used to send you our marketing communications are retained until you ask to be unsubscribed.

We use and retain your personal information to prevent, detect, mitigate and investigate fraudulent or illegal activities. We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with legal requirements, prevent fraud and resolve disputes. After it is no longer necessary for us to retain your personal information, we dispose of it securely according to our data retention and deletion policies.

Your rights

The General Data Protection Regulation provides for rights of access, modification and deletion of your personal information. The GDPR provides you with the following rights:

• The right of access: your right to obtain confirmation as to whether or not your personal data is being processed, and, where that is the case, access to that personal data along with details regarding the nature of processing.

• The right of rectification: your right to obtain the rectification of inaccurate personal data.

• The right of portability: your right to receive the personal data concerning you provided to us, in a structured, commonly used and machine-readable format.

• The right to be forgotten: your right to erase your personal data.

• The right to restrict processing: your right for your data to be effectively ‘frozen’; stored and not further processed.

• The right to object: your right to object to how your personal data is processed including your right to object to our profiling of you as outlined in this privacy policy.

Disclosure and security

We protect your information using measures that reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. We minimise the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purpose.

In so doing we may disclose your personal information to authorised third party service providers who help us to provide our services such as:

• Payment providers to facilitate purchase
• Fulfilment providers to facilitate order management, packaging and delivery
• Marketing providers in order to personalise your experience

Where legally compelling grounds exist, we may also disclose your personal information to governmental and law enforcement agencies, and otherwise in the defence of legal claims.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers 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. We do NOT share or disclose your personal information to third parties for marketing purposes.

Further information

We hope that the Privacy Policy has been helpful in setting out the way in which we handle your personal data and your rights to control it. If you have any further questions about how we collect, use and store your personal data, please contact us at:

• sales@citywinecollection.com

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us:

• sales@citywinecollection.com

 

You can find more information about GDPR and your rights on the UK Information Commissioner’s Office (ICO) website at https://ico.org.uk/concerns or by calling their helpline on 0303 123 1113.