We are Cult Wines (SG) Pte. Ltd., a company registered in Singapore and with its registered office at 16 Raffles
Quay, #33-03 Hong Leong Building, Singapore 048581 (we might refer to ourselves as "Cult
Wines", "we", "our" or "us"). This is the
Privacy Policy ("Policy") for our wine portfolio management services and the website hosted at
www.wineinvestment.com/sg/ ("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
- 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 and consent to us collecting, using and disclosing your personal data in
accordance with this Policy.
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.
- We will also collect usage and technical information related to your use of our Site and Services, including your device ID, mobile carrier, time zone setting, operating system and platform, IP address and other unique identifiers.
- 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.
Information from third parties
- We may from time to time receive your Account Opening Request information (set out above) from third party introducers, where you have agreed for them to share your information with us. We use this information to onboard you and set up your Account (at your request).
2. How will we use this information?
- 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. See 'Our promotional updates and communications'.
- Ensure 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, to help us:- to personalise our Site and our Services for you;
- to ensure content from our Site is presented in the most effective manner for you and your device;
- 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.
Our promotional updates and communications- 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 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 Pixel, Analytics | https://www.facebook.com/about/privacy/ |
4. 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 seven 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.
5. 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;
- You have the right to withdraw your consent to us collecting, using or disclosing personal data in accordance with this Policy by contacting us at https://www.wineinvestment.com/sg/contact/. In some cases, your withdrawal of consent may mean that we are no longer able to provide our Services to you. We will inform you of this prior to processing your consent withdrawal where this is the case. You can change your marketing preferences at any time as described in ‘Our promotion updates and communications’ section.
- You can ask us to do any of the aforementioned things at any time by contacting us at [email protected].
7. Where we store your information
- The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. Where your information is transferred outside Singapore, we will take all steps reasonably necessary to ensure that your data is protected to at least the same standard as that which is required in Singapore. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.
- 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
9 Battery Road
#09-01 MYP Centre
Singapore 049910
Website: www.wineinvestment.com/sg/