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JASCOTS WINE MERCHANTS

PRIVACY POLICY

Introduction

Jascots Wine Merchants Limited and WineEd Limited takes your privacy very seriously. This Privacy Policy is intended to set out your rights and answer any queries you may have about your personal data. If you need more information, please contact:  enquiries@jascots.co.uk

Our personal information handling policy and procedures have been developed in line with the requirements of the 1995 European Union Data Protection Directive (Directive 95/46/EC) and the General Data Protection Regulation (in force from 25 May 2018) and applicable national law.

1. What information do we collect?

We collect and process personal data about you when you interact with us and our products, and when you purchase goods and services from us. The personal data we process can include:

  • Your name
  • Your username and password where you may have requested one;
  • Your work address, email address and/or phone number;
  • Card payment details;
  • Your job title;
  • Your payment and delivery details, including billing and delivery addresses; and/or
  • Any other information you provide.
     

2. How do we use this information and what is the legal basis for this use?

We process the personal data listed above in paragraph 1 for the following purposes:

  • To establish and fulfil a contract with you.  For example, if you make a purchase from us or enter into an agreement to provide or receive services. This may include verifying your identity, taking payments, communicating with you, providing customer services and arranging the delivery or other provision of products or services. We require this information in order to enter into a contract with you and are unable to do so without it;
  • To comply with applicable law and regulation;
  • In accordance with our legitimate interests in protecting Jascots Wine Merchants’ legitimate business interests and legal rights, including but not limited to, use in connection with legal claims, compliance, regulatory and investigative purposes (including disclosure of such information in connection with legal process or litigation);
  • With your express consent to respond to any comments or complaints we may receive from you, and/or in accordance with our legitimate interests including to investigate any complaints received from you or from others, about our products or services;
  • We may use information you provide to personalise: 
    • Our communications to you; and 
    • Products or services for you, in accordance with our legitimate interests;
  • To monitor use of our websites and online services. We may use your information to help us check, improve and protect our products, content, services and websites, both online and offline, in accordance with our legitimate interests;
  • If you provide a credit or debit card, we may also use third parties (such as POS payment providers) to check the validity of the sort code, account number and card number you submit in order to prevent fraud, in accordance with our legitimate interests and those of third parties;
  • We may monitor any customer or supplier account to prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law and our legitimate interests;
  • In circumstances where you contact us by telephone, calls may be recorded for quality, training and security purposes, in accordance with our legitimate interests; and
  • We may use your information to invite you to take part in market research or surveys. 
  • Seek, hold and process any information obtained about you from you or third parties for the purpose of and as a result of any applications or agreements you have with the Company. This will include a search with a licensed credit reference agency which will keep a record of that search;
  • Use his information for credit assessment purposes including assessing your credit limit and to administer and operate the credit account to you and analyse the conduct of that credit account. This may include further searches with licensed credit reference agencies;


We may also send you direct marketing in relation to relevant products and services. Electronic direct marketing will only be sent where you have given your consent to receive it or we believe there is a legitimate interest in the information it contains, or (where this is allowed) you have been given an opportunity to opt-out. You will continue to be able to opt-out of electronic direct marketing at any time by following the instructions in the relevant communication.

3. With whom and where will we share your personal data?

We may share your personal data with our group companies to process it for the purposes of inter-group administration and to deliver products or services where elements of these are provided by group companies other than those with which you have directly contacted.

We may also share your personal data with the below third parties:

  • Our professional advisors such as our auditors and external legal and financial advisors;
  • Marketing and communications agencies where they have agreed to process your personal data in line with this Privacy Notice;
  • Business partners and sub-contractors.

Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if needed for the legal protection of our legitimate interests in compliance with applicable laws. Personal data may also be shared with third party service providers who will process it on behalf of Jascots Wine Merchants Ltd for the purposes above. Such third parties include, but are not limited to, providers of website hosting, maintenance, ERM provider and identity checking.

Disclose any information the Company holds about you to licensed credit reference agencies, other suppliers and creditors to help the Company and others make credit decisions; to help prevent or direct fraud or other crimes; to trace debtors; to provide trade references on a confidential basis to the Company’s agents and subcontractors; to insurance companies for purposes connected with insurance products that relate or might relate to your credit account; to any person to whom the Company proposes to transfer its rights and/or responsibilities under these Conditions and to the extent the Company is required and permitted to do so by law.

In the event that our business or any part of it is sold or integrated with another business, your details will be disclosed to our advisers and those of any prospective purchaser and will be passed to the new owners of the business.

4. How long will we keep your personal data?

We will not keep your personal information for any purpose for longer than is necessary and will only retain the personal information that is necessary in relation to the purpose. We are also required to retain certain information as required by law or for as long as is reasonably necessary to meet regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our terms and conditions.

Where you are a customer, we will keep your information for the length of any contractual relationship you have with us. At the point where your contract comes to an end your information will be changed to that of a prospective customer.

Where you are a prospective customer we will only retain your data until you unsubscribe from our communications.

In the case of any contact you may have with our team, your information will be retained as per our data retention policy [hold and use this information during and for up to 6 years after the trading relationship; and if you are a body corporate or incorporate, the Company may access information relating to your directors, shareholders or members, including searches with licensed credit reference agencies].

We will retain your data for a short time beyond the specified retention period, to allow for information to be reviewed and any deletion to take place. In some instances, laws may require Jascots Wine Merchants Ltd to hold certain information for specific periods other than those listed above.

5. Where is your data stored?

The personal data that we hold will be collected and stored within the UK.

6. What are your rights in relation to your personal data?

You have the right to ask us not to process your personal data for marketing purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, clicking the unsubscribe button on any communication we have sent to you or by contacting us.

Where you have consented to us using your personal data, you can withdraw that consent at any time.

If the information we hold about you is inaccurate or incomplete, you can notify us and ask us to correct or supplement it.

You also have the right, with some exceptions and qualifications, to ask us to provide a copy of any personal data we hold about you.

Where you have provided your data to us and it is processed by automated means, you may be able to request that we provide it to you in a structured, machine readable format.

If you have a complaint about how we have handled your personal data, you may be able to ask us to restrict how we use your personal data while your complaint is resolved. In some circumstances you can ask us to erase your personal data. 

  • By withdrawing your consent for us to use it; 
  • If it is no longer necessary for us to use your personal data; 
  • If you object to the use of your personal data and we don't have a good reason to continue to use it; or 
  • If we haven't handled your personal data in accordance with our obligations.


7. Where can you find more information about Jascots’ handling of your data?

Should you have any queries regarding this Privacy Policy, about Jascots’ processing of your personal data, want to make a complaint or wish to exercise your rights you can contact Jascots’ Data Protection Officer.   The DPO within Jascots Wine Merchants Ltd and WineEd Ltd is:

Director P3
Jascots Wine Merchants Ltd,
The Observatory,
Pinnacle House,
260 Old Oak Common Lane,
London,
NW10 6DX

If an individual is unhappy with the outcome of the IR they have the right to appeal to the Information Commissioner’s Office (ICO) for assessment, the ICO is contactable at;

Wycliffe House,
Water Lane,
Wilmslow,
Cheshire,
SK9 5AF.

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