We are Cult Wines Limited, a company registered in England and Wales and with its registered office at The
Clockwork Building, 45 Beavor Lane, London, W6 9AR (we might refer to ourselves as "Cult Wines", "we",
"our" or
"us"). This is the Privacy and Cookies Policy ("Policy") our wine portfolio management services
and the website
hosted at www.wineinvestment.com ("our Site") (together the "Services"). We are committed to
protecting and
respecting your privacy.
This Policy sets out:
- What information do we collect about you?
- How will we use your information?
- Sharing your information with others
- Cookies and other technologies
- How long do we keep your information?
- How do we protect your information?
- What are your rights?
- Where we store your information
- Payment processing
- Changes to this policy
- Contact us
Please read the following carefully to understand our views and practices regarding your personal data and how we
will treat it.
By accepting our Services, you acknowledge you have read and understood this Policy.
For the purposes of UK and EU data protection law ("Data Protection Law"), we are the data controller of your
information.
1. What information do we collect about you?
Information you give us
- To use our Services, you will need to register for an account ("Account") with us through the account opening request form available on our Site (we call this your "Account Opening Request") as part of the onboarding process. You will need to be at least 18 years of age to create an Account and to use our Services.
- You will need to enter the following information into the Account Opening Request:
- full name
- address
- email address
- phone number
- As part of the onboarding process, you will also provide us with the following:
- information about your investment style, risk appetite and investment length so we can build your investor profile and furnish you with appropriate investment recommendations;
- payment details to fund your Account, which is collected via the online form or bank transfer; and
- information about your financial background (i.e. your net worth, income, or job position) when you complete our investor declaration form.
- In some circumstances, we may also need you to provide certified copies of identification documents (i.e. passports) and utility bills for verification checks purposes.
- We may also collect records of any correspondence and communication if you contact us, including information you supply if you report a problem with our Site or Services to us. This covers information we learn about you from: letters, faxes, emails, texts & other digital messaging, calls, face-to-face conversations you have with us.
- If you sign up for ongoing insights, newsletters, download reports or other promotional material from us, we will collect your contact information and marketing preferences.
2. How will we use this information?
- You can see a full list of the types of data we process, the prupose for which we process it and the lawful basis on which it is processed here.
- We use personal data held about you in the following ways:
Information you give to us:
We will use this information to:- Set up your Account and fulfil any orders you make with us, including:
- administering your account with us;
- verifying and carrying out payments that you make through our Site; and
- notifying you about changes to our Services.
- Manage your Account moving forward;
- In some circumstances, and depending on the type of account you hold with us, to set preferences and make decisions about you and your account on an automated basis i.e. through the use of artificial intelligence tools to manage your account based on your previous activity and stated preferences;
- Provide you with information about our products and Services we feel may interest you, if you have given your consent to receiving marketing material from us at the point we collected your information, where required by law or otherwise in our legitimate interests provided these interests do not override your right to object to such communications. See 'Our promotional updates and communications'.
- Ensure in our legitimate interest that:
- content from our Site is easy for you to read and understand on your devices; and
- we answer any questions you have and give you any information that you request.
Information we collect about you from your use of our Services:
We will use some information, in our legitimate interest, to help us:- to run our Site and our Services and to help us spot problems;
- to understand how people use our Site so we can improve them;
- to keep our Site safe and secure;
- to make sure any advertising we send or show to you is relevant to you; and
- to allow you to participate in any interactive features of our service, when you choose to do so.
Information we collect about you from your use of our Services:- Where permitted in our legitimate interest or with your prior consent, we will use your personal information for marketing analysis and to provide you with promotional update communications about our products.
- You can object to further marketing at any time by checking and updating your contact details within your account, or selecting the "unsubscribe" link at the end of all our marketing and promotional update communications to you, or by sending us an email at [email protected].
- Set up your Account and fulfil any orders you make with us, including:
3. Sharing your information with others
- To provide our Services, we work with the following carefully selected third parties. To do this, we may
share your information with these third parties:
- the third parties responsible for arranging and fulfilling delivery of your wine order to our storage facility or to you (specifically your name and delivery address);
- any service providers hired to provide administrative, communication, wine storage, delivery, payment processing or insurance services;
- any group companies for business purposes;
- any affiliated companies; and
- any professional advisers
- We will also disclose your information to third parties:
- in the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets subject to the terms of this Policy;
- if Cult Wines 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; and
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to enforce or apply our terms of supply and other agreements with you; or to protect the rights, property, or safety of Cult Wines, our customers, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction and to prevent cybercrime.
- We also work with several third parties to provide the Site and the Services to you, as follows:
Third party processor Purpose of sharing your personal data with them Privacy policy Google Google Analytics, Google Adwords, Google Remarketing, Google Tag Manager. https://policies.google.com/privacy/ Woopra Real-time analysis of website visitor flows. https://www.woopra.com/privacy/ Facebook Facebook Pixel, Analytics https://www.facebook.com/about/privacy/
4. Cookies and other technologies
- Our Site uses cookies and/or other similar technologies such as device-IDs, in-App codes, pixel tags and web beacons to collect and store certain information. These typically involve pieces of information or code that a website transfers to or accesses from your computer hard drive or mobile device to store and sometimes track information about you. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalised content.
- Our Site uses cookies and similar technologies either alone or in combination with each other to create a unique device ID, and to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
- A number of cookies and similar technologies we use last only for the duration of your web or app session and expire when you close your browser or exit the Site. Others are used to remember you when you return to the Site and will last for longer.
- We use strictly necessary cookies if they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights). We use all other cookies with your consent.
- We use the following types of cookies:
Strictly necessary cookies
These are cookies that are required for the operation of our website and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our website or (on other Sites) use a shopping cart.Cookie name Why we use it Expires FluentLocale (wineinvestment.com) Strictly necessary 90 PHPSESSID (wineinvestment.com) Strictly necessary Session Only
Functionality cookies
These may be used to recognise you when you return to our website. This enables us, subject to your choices and preferences, to personalise our content, greet you by name and remember your preferences (for example, choice of language or region).Cookie name Why we use it Expires __cfduid (cloudflare.com) Functionality 30 __cfduid (highcharts.com/cloudflare.com) Functionality 30 __cfduid (lightwidget.com/cloudflare.com) Functionality 30 __cfduid (wineinvestment.com/cloudflare.com) Functionality 30 basket_en_gb (wineinvestment.com) Functionality 90
Analytical / performance cookies
These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.Cookie name Why we use it Expires _hjid (wineinvestment.com/hotjar.com) Analytical/Performance 365 wooTracker (wineinvestment.com/woopra.com) Analytical/Performance 365 JSESSIONID (nr-data.net) Analytical/Performance Session Only _hjIncludedInSessionSample (wineinvestment.com/hotjar.com) Analytical/Performance Session Only _hjAbsoluteSessionInProgress (wineinvestment.com/hotjar.com) Analytical/Performance Session Only _hjTLDTest (wineinvestment.com/hotjar.com) Analytical/Performance Session Only _hjIncludedInPageviewSample (wineinvestment.com/hotjar.com) Analytical/Performance Session Only _hjFirstSeen (wineinvestment.com/hotjar.com) Analytical/Performance Session Only
Targeting / Advertising cookies
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information subject to your choices and preferences to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.Cookie name Why we use it Expires _gid (wineinvestment.com/google.com) Analytical/Performance and Targeting/Advertising 1 _fbp (wineinvestment.com/facebook.com) Analytical/Performance and Targeting/Advertising 90 _ga (wineinvestment.com/google.com) Analytical/Performance and Targeting/Advertising 730 _gat (wineinvestment.com/google.com) Analytical/Performance and Targeting/Advertising Session Only
Social networking cookies
These cookies help us manage our social media, including enabling you to share content and enabling us to understand how you interact with us. We will use this information subject to your choices and preferences to improve our Site and services. We may also share this information with third parties for this purpose.Cookie name Why we use it Expires lidc (linkedin.com) Social Networking 1 AnalyticsSyncHistory (linkedin.com) Social Networking 30 UserMatchHistory (linkedin.com) Social Networking 730 bcookie (linkedin.com) Social Networking 730 lang (linkedin.com) Social Networking Session Only lang (linkedin.com) Social Networking and Targeting/Advertising Session Only lidc (linkedin.com) Social Networking 1
We may also work with advertising networks that gather information about the content on our Site you visit and on information on other websites and services you visit. This may result in you seeing advertisements through our Site or our advertisements when you visit other websites and services of third parties. For more information about how to turn this feature off see below or visit http://www.youronlinechoices.co.uk.
Other cookies
We also use the following cookies:Cookie name Why we use it Expires __cfduid (cloudflare.com) Functionality 30 __cfduid (highcharts.com/cloudflare.com) Functionality 30 __cfduid (lightwidget.com/cloudflare.com) Functionality 30 __cfduid (wineinvestment.com/cloudflare.com) Functionality 30 basket_en_gb (wineinvestment.com) Functionality 90 __cfduid (cloudflare.com) Functionality 30
Disabling cookies
The effect of disabling cookies depends on which cookies you disable but, in general, the website may not operate properly if all cookies are switched off.
If you want to disable cookies on our website, you need to change your website browser settings to reject cookies. How you can do this will depend on the browser you use.
Microsoft Internet Explorer- Select the Tools menu > Internet Options
- Click on the Privacy tab
- Click on Advanced within the Settings section and select the appropriate setting
Google Chrome- Select Settings > Advanced
- Under Privacy and Security > Content settings
- Click Cookies and select the relevant options
Safari- Select Preferences > Privacy
- Click on Remove all Website Data
Mozilla Firefox- Choose the Tools menu > Options
- Click on the Privacy icon
- Select the Cookie menu and select the relevant options
Opera 6.0 and further- Choose Files menu > Preferences
- Select Privacy
We may also separately prompt you regarding our use of cookies on the Site.
5. How long do we keep your information?
- We retain the data you provide to us for as long as you have an Account with us in order to meet our contractual obligations to you and for six years after that to identify any issues and resolve any legal proceedings. After you have deactivated your Account, we may store your information in an aggregated and anonymised format.
6. How do we protect your information?
- All information you provide to us is stored on our secure servers.
- 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.
- 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.
- Our Site may, from time to time, contain links to external Sites. We are not responsible for the privacy policies or the content of such Sites.
- You have the right under certain circumstances:
- to be provided with a copy of any personal data we have about you (for example, your name and address);
- to request the correction or erasure of incorrect personal data held by us;
- to request that we restrict the processing of your personal data (e.g. while we verify or investigate your concerns with this information);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in 'Our promotional updates and communications' section); and
- to request that your provided personal data be moved to a third party.
- Your right to withdraw consent:
- If we are processing your personal data because you have given us permission, you have the right to withdraw that consent without detriment at any time by contacting us at https://www.wineinvestment.com/contact. You can also change your marketing preferences at any time as described in 'Our promotional updates and communications' section;
- You can ask us to do any of the aforementioned things at any time by contacting us at [email protected].
- If your request or concern is not satisfactorily resolved by us, you can speak to your local data protection authority see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html. The Information Commissioner is in charge of personal data protection in the UK and can give you more information about your rights and what you can expect from us: https://ico.org.uk/global/contact-us/.
8. Where we store your information
- The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA") that may not be subject to equivalent Data Protection Law.
- Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this Policy.
- Payment details you provide will be kept securely. We use a third party to process your payments and information which you supply to Stripe is not within our control and subject to Stripe's privacy policy here: https://stripe.com/privacy
- If we make any changes to this Policy, a new version will be posted on this page and you will be notified via email of the substantive changes. This policy was last updated on 10th August 2021.
- We welcome your feedback and questions. If you would like to contact us, please contact us:
- By email at [email protected]
- By phone on +44(0)207 1000 950 between the hours of 9am to 5pm from Monday to Friday
- Our Data Protection Officer is:
Gemma Castle
Clockwork Building
45 Beavor Lane
London
W6 9AR
England, United Kingdom
Phone: +44 (0)207 1000 958
Email: [email protected]
Purpose and lawful basis for processing of personal data
This table sets out:- What personal data we process
- What we use that data for
- The lawful basis for the processing
It forms part of our Terms of Use Policy which you should also read.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
(a) Identity (b) Contact |
Performance of a contract with you |
| To process your order including: (a) Manage payments, fees and charges (b) Collect and recover money owed to us (c) Arrange for your order to be delivered and stored |
(a) Identity (b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) (c) Performance of a contract with you |
| To manage our relationship with you which will include: (a) Notifying you about changes to our 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 our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to 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 our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | (a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences | (a) Identity (b) Contact |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you (including, in some circumstances, using automated decision making using artificial intelligence) | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
Consent provided by you |
| To set preferences and make decisions about your Account in order to present goods or services that may be of interest to you when you visit the Site or use our Services (including, in some circumstances, using automated decision making using artificial intelligence) | (a) Identity (b) Contact (c) Technical (d) Usage (e) Profile |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to develop our products/services and grow our business) |