The Clear Wine Company Ltd
Privacy Policy and Cookies
Why we collect your personal data
We collect your personal data for two main reasons:
1. To process any orders you make and to deliver those orders to you, and
2. To personalise, report on and improve the products and services we provide to you
Contact Promise
We promise:
• That you can control the personal data you provide us with and that we will always be transparent about how we collect and use it.
• We will always tell you what personal data we are collecting from you, the means by which we will collect it and how we will use it. We will only use your personal data for the purposes we originally told you about.
• We will always use market-leading technology and software to ensure that your personal data is secure and when we ask another organisation to provide services to us which involve sharing your personal data with them, we will always make sure they have appropriate security measures.
• we will always offer you a clear and simple means of changing your preferences whenever you want to.
Who we are
We are The Clear Wine Company Ltd, a private company registered in Great Britain under number 11172101, whose registered office is at 292 Longhurst Lane, Mellor, Stockport, Cheshire SK6 5PP.
If you have any questions about how we look after your personal data, you can contact us:
• In writing, at the address above. Please mark your letter for the attention of the Data Protection Officer
• By email to this address: info@clearwine.co.uk
• By telephone on 0161 706 0942
How we collect your personal data
We collect your personal data in two main ways:
1. When you give it to us directly:
When you visit our website, communicate with us or purchase our products or services, you may choose to give us certain information. For example, when you give us your name and address, tell us about your wine preferences or when clicking on active buttons on our website such as ‘Add to Cart’.
2. When our systems collect information or personal data as you use our website. The manufacturer of your device, or the provider of the operating system, will have details about what information your device shares with us.
Categories of personal data we collect
We may collect the following information about you:
• Your name, date of birth and contact details. This can include your postal, billing and delivery addresses, your telephone number(s), including, if you provide it, your mobile number, and your email address
• Purchases and orders made by you
• Your payment card details (which we encrypt) when you purchase our products or services
• Your wine preferences,
• Your on-line browsing history on our website
• Your correspondence with us including emails, letters and telephone calls
Times when we may need to collect additional personal data for the purposes set out in this privacy policy.
We will process personal data to fulfil your orders and to comply with the law, for example:
• We will share your (or your recipient's) name, address and, where applicable, telephone number with our carriers
• We will share your payment details with our bank or clearing house so that we can process payment for your order
• We will share your name, address and telephone numbers with an external provider to verify your age when you first purchase from us. This is because we are required by law to ensure that we sell products containing alcohol only to people aged 18 or over
• Occasionally with the police, or our trade body, for the purposes of preventing and investigating fraud
This is the legal basis for collecting and processing your data
The law on data protection sets out a number of lawful bases for which a company may collect and process your personal data. Only 4 of these are relevant to us.
1. Personal data is processed on the basis of our legitimate interests
2. Personal data is processed on the basis of contractual obligations
3. Personal data is processed on the basis of legal compliance
4. Personal data is processed on the basis of a person's consent
(1). Legitimate interests
"Legitimate Interests" means the interests of our company in conducting and managing our business to enable us to give you the best products and services, and the best and most secure experience. It can also apply to processing that is in your interests as well. For example, we may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we rely on our legitimate interests to send you marketing communications, we shall tell you when you become a customer how we would like to market our products and services to you, and offer you a means of opting out of those communications. You can opt out of our marketing communications at any time by contacting us on 0161 706 0942 or info@clearwine.co.uk.
We rely on our legitimate interests to process your personal data so that we can:
• Improve our existing wine range, associated products and services, and develop new ones
• Provide you with a quality customer service experience
• Protect you, our employees and our business
• Understand your likes and dislikes, what wines you want to hear about and how best to contact you to inform you about them
• Manage insurance claims made by our customers
• Taking legal action against any party in breach of its obligations to The Clear Wine Company Ltd, and handling any legal claims or regulatory enforcement actions taken against The Clear Wine Company Ltd
• Handling customer contacts, queries, complaints and disputes
• Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders
(2). Contractual Obligations
In specific situations, we collect and process your data to comply with our contractual obligations. For example, if you order an item from us we collect your address details, phone number and email and pass these to our couriers to deliver your purchase.
(3). Legal Compliance
If the law requires us to we may need to collect and process your data. We may disclose the personal information that you provide to a credit reference or fraud prevention agency which may keep a record of that information. This is done only to confirm your identity. A credit card check is not performed, and your credit rating will be unaffected.
(4). Consent
We can collect and process your data with your consent.
Reasons why we use your personal data and on what lawful basis
We use your personal data:
• On the basis of our contractual obligation to send you the wines and other products and services you have purchased; to manage any accounts you have registered with us so that (i) we can provide you with products and services; (ii) you can place orders; and (iii) we can fulfil those orders and communicate with you about them.
• On the basis of our legitimate interests to improve the range of wines, offers and associated products we offer you and to help identify new products and services in the future
• On the basis of our legal compliance to comply with the law (for example, to ensure that we only sell products containing alcohol to those aged 18 or over); to detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same) to verify your identity and your age
When we share your personal data
In order that we can provide you with our products and services, we have to share some of your personal data with certain third parties. When we share your personal data, we make sure that it remains secure:
• We conduct a data security review of third parties we share your personal data with to ensure that they will keep your personal data secure and confidential to the standards you and we would expect
• Every external company we work with is required to have a contract with us which clearly describes our expectations about the way in which they keep your personal data secure, the purposes for which they can use your personal data and which holds them fully responsible for meeting those expectations
• We will only send to third parties the personal data that is necessary for the purposes it is required for
We share your data as follows
• With core service providers to enable our business to function: we rely on a set of external companies to provide us with services that enable our business to run properly. Our core service providers include the courier companies we use to deliver our products to you; banks and clearing houses to process your payments; companies we use to carry out fraud protection and age verification checks and IT services providers
• With other partners when we have your consent to do so: we work with a number of other third party companies to provide value to our business and to you. We will only partner with a company that meets our own high standards and that we think is a good fit for our business and our customers.
• With regulators and law enforcement agencies when required to do so by law; we are required to co-operate with regulators (like the Information Commissioner's Office or HMRC) and law enforcement agencies (like the police or the Serious Fraud Office). Although it does not happen often, regulators and law enforcement agencies can require us to share information with them as part of an investigation; this may include your personal data. We would have to disclose your personal data where we believe that disclosure is reasonably necessary to comply with the regulator or crime enforcement agency's demand.
• When we think it is reasonably necessary to protect you or us: occasionally businesses are subject to attempted criminal activities; this can affect both us and you. We will take all reasonable steps to protect you and our business but sometimes we may need to share your personal data where we think it is reasonably necessary to i) detect, monitor, investigate or prevent any suspected illegal activities, fraud or security issues, ii) enforce our terms and conditions and to protect your and our rights and property, iii) investigate and defend any third party claims or allegations, iv) as part of a business sale or purchase, merger or reorganisation. For example from time to time we may look to purchase another business or sell or re-organise parts of our business to ensure that we remain in strong shape. Sometimes these types of corporate transactions involve the transfer of your personal data solely for the purposes of assessing the transaction. In the event that we sell or buy any business or assets, personal data which we hold about you may be one of the transferred assets.
• In aggregated format
Strictly speaking this is not personal data, but on occasions we will use data from which you cannot be personally identified but which does include information that relates to you (such as your purchase history). This data is combined with data from other customers to provide general trends on customers preferences, ratings and reviews and general buying habits.
The length of time we hold your personal data
We will not keep your personal data for longer than is necessary for the purposes described in this policy.
As a guide:
• Currently we retain data for 6 years from date of last purchase with us, but we may keep certain categories of personal data after your last purchase in order to meet any legal or regulatory requirements, or to resolve a legal dispute
• We may keep different types of personal data for different lengths of time (for instance, we may need to keep certain personal data relating to your purchases in order to comply with HMRC's VAT reporting requirements).
Your rights
You have a number of rights under data protection laws; these are summarised below.
• the right to be informed
We need to be clear with you about how we process your personal data. We do this through our Contract Promise and this Privacy Policy, which we will keep as up to date as possible.
• the right of access
You can access the personal data we hold on you by contacting us on 0161 706 0942 or info@clearwine.co.uk. To process your request, we will ask you to send us two forms of proof of identity so that we can be sure we are releasing your personal data to the right person. We will process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy.
If we consider the frequency of your requests is unreasonable, we may refuse to comply with your request. In those circumstances, we would notify you of your right to complain to the Information Commissioner's Office.
• the right to rectification
We welcome feedback from you to ensure our records are as accurate and up-to-date as possible. If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us on 0161 706 0942 or info@clearwine.co.uk. We will process your request as soon as we receive it or within one month of receipt at the latest.
• the right to erasure
You can ask us to delete your personal data; however, this is not an absolute right. We can refuse to erase personal data which we need to keep (i) to comply with a legal obligation (for instance, we are required by HMRC to keep certain personal data for up to 6 years for VAT reporting purposes); and (ii) in relation to the exercise or defense of any legal claims. Other than as described above, we will always comply with your request and will do so promptly. We would also notify any third parties with whom we have shared your personal data (for instance, our carriers for the purposes of delivering wine to you) about your request so that they could also comply.
• the right to transfer your personal data (known as data portability)
You have the right to move, copy or transfer your personal data from one organisation to another. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (for instance, in a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation. Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide. When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer. We will comply with your request within one month or, if the request is complex or there are a number of requests from you, within two months.
• the right to object
If you would like us to stop processing your personal data for marketing purposes simply let us know by contacting us on 0161 706 0942 or info@clearwine.co.uk
Data Protection Officer
We have appointed a Data Protection Officer. If you have any questions about how we use your personal data that are not answered here, or if you want to exercise any of your rights described above, please contact our team by contacting us on 0161 706 0942 or info@clearwine.co.uk or write to Data Protection Officer, The Clear Wine Company Ltd, 292 Longhurst Lane, Mellor, Stockport, Cheshire SK6 5PP.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner's Office.
Update
We may update this policy from time to time to take account of any new business activity or to reflect any changes in law or best practice in relation to data protection. We will notify you if we do so. This policy was last updated on 10 October 2020.
Cookie Policy
When you interact with our online services, we obtain certain information using automated technologies, such as cookies, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our website. These automated technologies are used to collect your device information, internet activity information, and inferences as described above.
These technologies are used to:
• Remember your information so you do not have to re-enter it
• Track and understand how you use and interact with our online services and emails
• Measure how useful and effective our services and communications are to you
• Otherwise manage and enhance our products and services
These automated technologies are set by third parties who deliver services on our behalf. Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. You can learn more about cookies and how to manage your preferences by visiting http://www.allaboutcookies.org.
We collect your personal data for two main reasons:
1. To process any orders you make and to deliver those orders to you, and
2. To personalise, report on and improve the products and services we provide to you
Contact Promise
We promise:
• That you can control the personal data you provide us with and that we will always be transparent about how we collect and use it.
• We will always tell you what personal data we are collecting from you, the means by which we will collect it and how we will use it. We will only use your personal data for the purposes we originally told you about.
• We will always use market-leading technology and software to ensure that your personal data is secure and when we ask another organisation to provide services to us which involve sharing your personal data with them, we will always make sure they have appropriate security measures.
• we will always offer you a clear and simple means of changing your preferences whenever you want to.
Who we are
We are The Clear Wine Company Ltd, a private company registered in Great Britain under number 11172101, whose registered office is at 292 Longhurst Lane, Mellor, Stockport, Cheshire SK6 5PP.
If you have any questions about how we look after your personal data, you can contact us:
• In writing, at the address above. Please mark your letter for the attention of the Data Protection Officer
• By email to this address: info@clearwine.co.uk
• By telephone on 0161 706 0942
How we collect your personal data
We collect your personal data in two main ways:
1. When you give it to us directly:
When you visit our website, communicate with us or purchase our products or services, you may choose to give us certain information. For example, when you give us your name and address, tell us about your wine preferences or when clicking on active buttons on our website such as ‘Add to Cart’.
2. When our systems collect information or personal data as you use our website. The manufacturer of your device, or the provider of the operating system, will have details about what information your device shares with us.
Categories of personal data we collect
We may collect the following information about you:
• Your name, date of birth and contact details. This can include your postal, billing and delivery addresses, your telephone number(s), including, if you provide it, your mobile number, and your email address
• Purchases and orders made by you
• Your payment card details (which we encrypt) when you purchase our products or services
• Your wine preferences,
• Your on-line browsing history on our website
• Your correspondence with us including emails, letters and telephone calls
Times when we may need to collect additional personal data for the purposes set out in this privacy policy.
We will process personal data to fulfil your orders and to comply with the law, for example:
• We will share your (or your recipient's) name, address and, where applicable, telephone number with our carriers
• We will share your payment details with our bank or clearing house so that we can process payment for your order
• We will share your name, address and telephone numbers with an external provider to verify your age when you first purchase from us. This is because we are required by law to ensure that we sell products containing alcohol only to people aged 18 or over
• Occasionally with the police, or our trade body, for the purposes of preventing and investigating fraud
This is the legal basis for collecting and processing your data
The law on data protection sets out a number of lawful bases for which a company may collect and process your personal data. Only 4 of these are relevant to us.
1. Personal data is processed on the basis of our legitimate interests
2. Personal data is processed on the basis of contractual obligations
3. Personal data is processed on the basis of legal compliance
4. Personal data is processed on the basis of a person's consent
(1). Legitimate interests
"Legitimate Interests" means the interests of our company in conducting and managing our business to enable us to give you the best products and services, and the best and most secure experience. It can also apply to processing that is in your interests as well. For example, we may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure. When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we rely on our legitimate interests to send you marketing communications, we shall tell you when you become a customer how we would like to market our products and services to you, and offer you a means of opting out of those communications. You can opt out of our marketing communications at any time by contacting us on 0161 706 0942 or info@clearwine.co.uk.
We rely on our legitimate interests to process your personal data so that we can:
• Improve our existing wine range, associated products and services, and develop new ones
• Provide you with a quality customer service experience
• Protect you, our employees and our business
• Understand your likes and dislikes, what wines you want to hear about and how best to contact you to inform you about them
• Manage insurance claims made by our customers
• Taking legal action against any party in breach of its obligations to The Clear Wine Company Ltd, and handling any legal claims or regulatory enforcement actions taken against The Clear Wine Company Ltd
• Handling customer contacts, queries, complaints and disputes
• Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders
(2). Contractual Obligations
In specific situations, we collect and process your data to comply with our contractual obligations. For example, if you order an item from us we collect your address details, phone number and email and pass these to our couriers to deliver your purchase.
(3). Legal Compliance
If the law requires us to we may need to collect and process your data. We may disclose the personal information that you provide to a credit reference or fraud prevention agency which may keep a record of that information. This is done only to confirm your identity. A credit card check is not performed, and your credit rating will be unaffected.
(4). Consent
We can collect and process your data with your consent.
Reasons why we use your personal data and on what lawful basis
We use your personal data:
• On the basis of our contractual obligation to send you the wines and other products and services you have purchased; to manage any accounts you have registered with us so that (i) we can provide you with products and services; (ii) you can place orders; and (iii) we can fulfil those orders and communicate with you about them.
• On the basis of our legitimate interests to improve the range of wines, offers and associated products we offer you and to help identify new products and services in the future
• On the basis of our legal compliance to comply with the law (for example, to ensure that we only sell products containing alcohol to those aged 18 or over); to detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same) to verify your identity and your age
When we share your personal data
In order that we can provide you with our products and services, we have to share some of your personal data with certain third parties. When we share your personal data, we make sure that it remains secure:
• We conduct a data security review of third parties we share your personal data with to ensure that they will keep your personal data secure and confidential to the standards you and we would expect
• Every external company we work with is required to have a contract with us which clearly describes our expectations about the way in which they keep your personal data secure, the purposes for which they can use your personal data and which holds them fully responsible for meeting those expectations
• We will only send to third parties the personal data that is necessary for the purposes it is required for
We share your data as follows
• With core service providers to enable our business to function: we rely on a set of external companies to provide us with services that enable our business to run properly. Our core service providers include the courier companies we use to deliver our products to you; banks and clearing houses to process your payments; companies we use to carry out fraud protection and age verification checks and IT services providers
• With other partners when we have your consent to do so: we work with a number of other third party companies to provide value to our business and to you. We will only partner with a company that meets our own high standards and that we think is a good fit for our business and our customers.
• With regulators and law enforcement agencies when required to do so by law; we are required to co-operate with regulators (like the Information Commissioner's Office or HMRC) and law enforcement agencies (like the police or the Serious Fraud Office). Although it does not happen often, regulators and law enforcement agencies can require us to share information with them as part of an investigation; this may include your personal data. We would have to disclose your personal data where we believe that disclosure is reasonably necessary to comply with the regulator or crime enforcement agency's demand.
• When we think it is reasonably necessary to protect you or us: occasionally businesses are subject to attempted criminal activities; this can affect both us and you. We will take all reasonable steps to protect you and our business but sometimes we may need to share your personal data where we think it is reasonably necessary to i) detect, monitor, investigate or prevent any suspected illegal activities, fraud or security issues, ii) enforce our terms and conditions and to protect your and our rights and property, iii) investigate and defend any third party claims or allegations, iv) as part of a business sale or purchase, merger or reorganisation. For example from time to time we may look to purchase another business or sell or re-organise parts of our business to ensure that we remain in strong shape. Sometimes these types of corporate transactions involve the transfer of your personal data solely for the purposes of assessing the transaction. In the event that we sell or buy any business or assets, personal data which we hold about you may be one of the transferred assets.
• In aggregated format
Strictly speaking this is not personal data, but on occasions we will use data from which you cannot be personally identified but which does include information that relates to you (such as your purchase history). This data is combined with data from other customers to provide general trends on customers preferences, ratings and reviews and general buying habits.
The length of time we hold your personal data
We will not keep your personal data for longer than is necessary for the purposes described in this policy.
As a guide:
• Currently we retain data for 6 years from date of last purchase with us, but we may keep certain categories of personal data after your last purchase in order to meet any legal or regulatory requirements, or to resolve a legal dispute
• We may keep different types of personal data for different lengths of time (for instance, we may need to keep certain personal data relating to your purchases in order to comply with HMRC's VAT reporting requirements).
Your rights
You have a number of rights under data protection laws; these are summarised below.
• the right to be informed
We need to be clear with you about how we process your personal data. We do this through our Contract Promise and this Privacy Policy, which we will keep as up to date as possible.
• the right of access
You can access the personal data we hold on you by contacting us on 0161 706 0942 or info@clearwine.co.uk. To process your request, we will ask you to send us two forms of proof of identity so that we can be sure we are releasing your personal data to the right person. We will process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy.
If we consider the frequency of your requests is unreasonable, we may refuse to comply with your request. In those circumstances, we would notify you of your right to complain to the Information Commissioner's Office.
• the right to rectification
We welcome feedback from you to ensure our records are as accurate and up-to-date as possible. If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us on 0161 706 0942 or info@clearwine.co.uk. We will process your request as soon as we receive it or within one month of receipt at the latest.
• the right to erasure
You can ask us to delete your personal data; however, this is not an absolute right. We can refuse to erase personal data which we need to keep (i) to comply with a legal obligation (for instance, we are required by HMRC to keep certain personal data for up to 6 years for VAT reporting purposes); and (ii) in relation to the exercise or defense of any legal claims. Other than as described above, we will always comply with your request and will do so promptly. We would also notify any third parties with whom we have shared your personal data (for instance, our carriers for the purposes of delivering wine to you) about your request so that they could also comply.
• the right to transfer your personal data (known as data portability)
You have the right to move, copy or transfer your personal data from one organisation to another. If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (for instance, in a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation. Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide. When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer. We will comply with your request within one month or, if the request is complex or there are a number of requests from you, within two months.
• the right to object
If you would like us to stop processing your personal data for marketing purposes simply let us know by contacting us on 0161 706 0942 or info@clearwine.co.uk
Data Protection Officer
We have appointed a Data Protection Officer. If you have any questions about how we use your personal data that are not answered here, or if you want to exercise any of your rights described above, please contact our team by contacting us on 0161 706 0942 or info@clearwine.co.uk or write to Data Protection Officer, The Clear Wine Company Ltd, 292 Longhurst Lane, Mellor, Stockport, Cheshire SK6 5PP.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response, you have the right to lodge a complaint with the Information Commissioner's Office.
Update
We may update this policy from time to time to take account of any new business activity or to reflect any changes in law or best practice in relation to data protection. We will notify you if we do so. This policy was last updated on 10 October 2020.
Cookie Policy
When you interact with our online services, we obtain certain information using automated technologies, such as cookies, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an internet tag, pixel tag, or clear GIF, is a tiny graphic image that may be used in our website. These automated technologies are used to collect your device information, internet activity information, and inferences as described above.
These technologies are used to:
• Remember your information so you do not have to re-enter it
• Track and understand how you use and interact with our online services and emails
• Measure how useful and effective our services and communications are to you
• Otherwise manage and enhance our products and services
These automated technologies are set by third parties who deliver services on our behalf. Your browser can alert you when cookies are placed on your device, and how you can stop or disable them via your browser settings. Please note, however, that without cookies all of the features of our online services may not work properly. If you use a mobile device, you can manage how your device and browser share certain device data by changing the privacy and security settings on your mobile device. You can learn more about cookies and how to manage your preferences by visiting http://www.allaboutcookies.org.