For the purpose of the Data Protection Act 1998 (the Act), the data controller is Wine behind the label of 57, Pelham Street, London SW7 2NJ.
1 INFORMATION WE GATHER AND TRACK
1.1 We may collect and process the following data about you:
1.1.1 Information you give us. You may give us information about you by filling in forms on our site https://www.winebehindthelabel.org (our site) or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our site, subscribe to our service, search for a product, place an order on our site, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our site. The information you give us may include your name, address, e-mail address and phone number, financial and credit card information, personal description and photograph.
1.1.2 Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
a. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
b. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) , and methods used to browse away from the page and any phone number used to call our customer service number. This information is used to analyze trends, administer the site, track user’s movement around the site, and gather demographic information. IP addresses, and other such information are not linked to any information that is personally identifiable.
1.1.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
2 ADVERTISING PARTNERS – VISITOR INFORMATION AND COOKIES
2.1 This website may accept forms of cash advertising, sponsorship, paid insertions or other forms of compensation. The compensation received may influence the advertising content, topics or posts made in this website. That content, advertising space or post may not always be identified as paid or sponsored content.
2.2 The owner(s) of this website may be compensated to provide opinions on products, services, websites and various other topics. Even though the owner(s) of this website receives compensation for our posts or advertisements, we always give our honest opinions, findings, beliefs, or experiences on those topics or products. The views and opinions expressed on this website are purely the author. Any product claim, statistic, quote or other representation about a product or service should be verified with the manufacturer, provider or party in question.
3 USE OF INFORMATION
3.1 Any of the information we collect from you may be used in, but not limited to, the following ways: Information you give to us. We will use this information:
3.1.1 to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
3.1.2 to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
3.1.3 to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you or to provide you with information about the product or service you purchased. This may include, but is not limited to, information about product or service updates, new features, or information we believe you may find interesting. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the [order form OR registration form]);
3.1.4 to notify you about changes to our service; and
3.1.5 to ensure that content from our site is presented in the most effective manner for you and for your computer.
3.2 Information we collect about you. We will use this information:
3.2.1 to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
3.2.2 to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
3.2.3 to allow you to participate in interactive features of our service, when you choose to do so;
3.2.4 as part of our efforts to keep our site safe and secure;
3.2.5 to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
3.2.6 to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them.
3.3 Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may us this information and the combined information for the purposes set out above (depending on the types of information we receive).
4 DISCLOSURE OF YOUR INFORMATION
4.1 We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. We may share your information with selected third parties including:
4.1.1 Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
4.1.2 Advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. [We do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in SW1). We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience].
4.1.3 Analytics and search engine providers that assist us in the improvement and optimisation of our site.
4.1.4 [Credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you.]
4.2 We may disclose your personal information to third parties:
4.2.1 In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
4.2.2 If Wine behind the label or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
4.3 We implement a variety of security measures to maintain the safety of your personal information. We will not sell, provide, or transfer you email address to others.
5 WHERE WE STORE YOUR PERSONAL DATA
5.2 All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted [using SSL technology]. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
5.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
6 YOUR RIGHTS
6.1 You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by contacting us at 57, Pelham Street, London SW7 2NJ OR email@example.com.
6.2 Our site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
7 ACCESS TO INFORMATION
7.1 The Act gives you the right to access information held about you. Your right of access can be exercised in accordance with the Act. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
8.1 These policies may be amended by us at any time and without notice, but will be posted at this page. You agree that your continued use of our websites, product or service after that date will constitute your consent and acceptance of the amendment.
9 PRIVACY OF CHILDREN
9.1 This website does not provide services or sell products to children under the age of 18.
9.2 If we discover we have received any information from a child under the age of 18 in violation of this policy, we will delete that information immediately. If you believe we have received any information from or about anyone under the age of 18, please contact us at the address listed below.
10 THIRD PARTY LINKS
10.1 Occasionally, at our discretion, we may include or offer third party products or services on our website. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.