Last Updated: May 23, 2018
WHO WE ARE
This website (“Site” or “Service”) is operated by Gandhi Wine Suppliers Limited trading as Imbibe Melrose, a company registered in England and Wales under registration number 1850698 (“Gandhi Wine Suppliers”, “Imbibe Melrose”, “GWS”, “we”, “us” or “our”).
The data controller responsible for your personal data is the Gandhi Wine Suppliers company with whom you contract as a customer (“you” or “your”).
By using our website and giving your information to us, you indicate your consent to us and our commercial partners collecting and using your personal information in accordance with the terms of this policy, so please read it carefully.
HOW WE COLLECT YOUR DATA
To provide you with the services you require, we will collect personal information about you via various channels including our website, telephone conversations, emails and written and verbal communications. These will include, for example, your name, email, address, telephone numbers and other details that are relevant to the service(s) in which you are interested. We may supplement the information that you provide with other information that we obtain from our dealings with you or which we receive from other organisations.
When you visit our website or use our services, we collect personal data. The way we collect broadly falls into the following categories:
2.1 Information you provide us directly
Certain parts of our Website may ask you to provide personal information voluntarily: for example, we may ask you to provide your contact details in order to register an account with us, to complete an online order with us, to participate in customer engagement programs, to submit a review or other content for potential posting on the Website, to participate in a competitions and promotion, to subscribe to marketing communications from us, and/or to submit enquiries to us. The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information. For example, we may ask you for your date of birth for age verification purposes. Any personal information you choose to upload to ‘Your Account’ will be used to fulfil your order and maintain your account.
- Information we collect automatically
When you visit our Website, we may collect certain information automatically from your device. In some countries, including countries in the European Economic Area, this information may be considered the personal information under applicable data protection laws. Specifically, the information we collect automatically may include information like your IP address, device type, traffic data, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical and communication information. Location information will only be collected where you have specifically permitted your device to share such information. Should you not wish us to automatically collect your location data you should turn off the location sharing feature on your device. We may also collect information about how your device has interacted with our Website, including the pages accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our Website, where they come from, and what content on our Website is of interest to them. We use this information for our internal analytics purposes and to improve the quality and relevance of our Website to our visitors. Some of this information may be collected using cookies and similar tracking technology, as explained further under the heading “Cookies” below.
- Information we get from third parties
The majority of information we collect, we collect directly from you. Sometimes we might collect personal data about you from other sources, such as publicly available materials or trusted third parties like marketing research partners. We use this information to supplement the personal data we already hold about you, in order to better inform, personalise and improve our services, and to validate the personal data you provide.
Currently, we do not feature an online store. However, we will shortly. Any credit/debit card payments you make through our Site will be processed by our third-party payment providers and the payment data you submit will be securely stored and encrypted by our payment service providers using up to date industry standards. Please note that we will not ourselves directly process or store the debit/credit card data that you submit.
We will store and use this card or payment information for the purpose of processing any future payments for additional goods and services. We will store this data in accordance with our legal obligations under applicable law and only for so long as legally permitted.
You will be able to choose to opt out of us holding your card or payment data although this means that you will need to re-supply us with card/payment details for the purpose of making any future purchases.
INFORMATION ABOUT OTHER PEOPLE
If you provide information to us about any person other than yourself, you must ensure that they understand their information will be used and that you are authorised to disclose it to us, and to consent to its use on their behalf, before doing so.
HOW WE CAN USE YOUR INFORMATION
- To provide the services you request from us and manage our relationship with you
- To communicate with you. This may include; providing the information you have requested from us; operational communications like changes to our website and services; marketing communications in accordance with your marketing preferences;
- To carry out market research by asking you for feedback or taking part in research we are conducting so that we can improve the services we offer
- To track and analyse activity on our website so that we can keep improving and optimise your user experience
- To create an individual profile for you so that we can enhance your user experience, understand and respect your preferences and provide you with relevant offers and opportunities where you have agreed to receive them
HOW WE CAN SHARE YOUR INFORMATION
Additionally, they may be disclosed to:
- Any competent law enforcement body, regulatory, government agency, court or other third party where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
- Any other person where we have your consent to the disclosure.
If we believe you are in breach of our terms and conditions, we may refer details to our advisers. If we have cause to believe you are acting unlawfully, we may provide details (which may include personal information) to the police and/or regulators.
INTERNATIONAL DATA TRANSFERS
Your personal data may be transferred to and stored in countries other than the country in which the information was originally collected, including the United States and other destinations outside the EEA, to our service providers and affiliated businesses for the purposes described above. These countries may have data protection laws that are different to the laws of your country and therefore offer various levels of protection.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION (EEA VISITORS ONLY)
If you are a visitor from the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information).
Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Our cookies are used to enable us to develop our website to reflect our customers’ interests and by noting who has seen which pages, properties, how frequently particular pages are visited and determining the most popular areas of our website.
Most browsers automatically accept cookies, but you can usually change your browser to prevent cookies being stored. Please note, if you do turn cookies off this will limit the service that we are able to provide to you and may affect your experience.
We use appropriate technical and organisational measure to protect the personal information that we collect and process about you. This includes our paper and computer systems and databases. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Risks include unauthorised use, loss and damage.
To determine the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the personal data, the purposes for which we process your personal data, applicable legal requirements or operational retention needs, and whether we can achieve those purposes through other means.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
YOUR DATA PROTECTION RIGHTS
You have the right to receive a copy of your personal information that we hold about you as well as the following data protection rights:
- Right of Access, Rectification and Erasure: If you wish to access, correct, update or request deletion of your personal information, you can do so at any time.
- Right to Restrict Processing and Data Portability: If you are a resident of the European Union, you can object to the processing of your personal information, ask us to restrict processing of your personal information in certain circumstances, such as where you contest the accuracy of the personal data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data, so you can contact them directly
- Right to Data Portability: You have the right to obtain your personal data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you. We will provide you with your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.
- Right to Object: You may ask us at any time to stop processing your personal data, and we will do:
- If we are relying on a legitimate interest to process your personal data — unless we demonstrate compelling legitimate grounds for the processing
- If we are processing your personal data for direct marketing.
- Right to Opt-Out of Marketing Communications: You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you o at any time. To opt-out of other communication forms, please contact us.
- Right to Withdraw Consent: If we have collected and processed your information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- Right to Complain to a Data Protection Authority: You have the right to lodge a complaint about our collection and use of your personal information or our privacy practices to the UK data protection authority or any other data protection authority of an EU member state. For more information, please contact your local data protection authority.
We respond to all requests exercising their data protection rights in accordance with applicable data protection laws. Please see our contact details provided under the “Contact Us” heading below. We may charge a small fee towards the cost of administering any request you make. The current fee is £15.00.
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