Reviewed 17 April 2020
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.
Information we get from your use of our website.
We collect information about the pages of this website you use and how you use them, like the journey through multiple pages of our website, or how long you spend on a specific page. This information includes:
We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with the forms you submit.
When you use our website, we automatically collect and store certain information in server logs. This includes:
- details of how you used our website, such as your search queries.
- telephony log information, such as your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.
- Internet protocol address.
- device event information, such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- cookies that may uniquely identify your browser or you if you have previously submitted a form via our website.
When you use our website, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS and other sensors that may, for example, provide us with information on nearby devices, Wi-Fi access points and mobile towers.
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Cookies and similar technologies.
We use various technologies to collect and store information when you visit our website, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with us, such as advertising services or features that may appear on other sites. Our analytical products help us analyse the traffic to our websites and apps.
You are not obliged to accept cookies and may modify your browser so that it will not accept cookies. The browser you use not only allows you to see the cookies that you have got but also allows you to control their use. You can control them by allowing them, deleting them individually or deleting all of them. You can also set your browser to not accept cookies altogether. If this option is selected, you should be aware that many websites will not function properly or at all. It may be possible to set your browser to not accept cookies and ask for your consent before each cookie is set on your device. This gives you control over what is set on your device, however, has the drawback of slowing down your browsing experience.
There are different levels of control too. You are able to prevent just third party cookies being deployed, and some even allow you to block specific companies you do not wish to deploy a cookie, instead of selecting all companies. In order to manage your cookies, please refer to your browser’s help guides and follow their instructions.
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 use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our website. One of the products we use to do this is Google Analytics.
We process personal information on either our servers in the UK and the USA so we may process your personal information on a server located outside the country where you live.
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, ERP 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. Data protection and information security
We comply with the Data Protection laws in the United Kingdom. We take all reasonable care to prevent any unauthorised access to and use of your personal data.
Our staff and those working for our agents and contractors maintain a responsibility to keep your personal information confidential and will only use it to offer relevant products and services related to your enquiry, interaction or order.
Whilst any personal information that we use to provide or promote our services to you will not be passed to any third party organisation for marketing purposes, on occasion your details may be shared by our approved contractors or agents, in order to inform you and/or produce relevant services.
If you do not wish to receive this information from us or our associates or wish to delete Personal Information you have submitted through the website please send an email to the email address email@example.com.
Information security. We work hard to protect our company and our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold. In particular:
- We encrypt our website interactions using SSL.
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorised access to systems.
- We restrict access to personal information to employees, contractors and agents who need to know that information in order to process it for us and who are subject to strict contractual confidentiality obligations. They may be disciplined or their contract terminated if they fail to meet these obligations.
- We will provide the same protections in respect of any electronic communications received from you as those employed in respect of information received by post and telephone.
- The personal data that we hold will be collected and stored within the UK and USA.
We make no representations as to the accuracy or any other aspect of information contained in other websites.
7. What are your rights in relation to your personal data?
Right to restrict processing.
In certain circumstances you have a right to require us to stop processing your personal data in a particular way.
Right to erasure.
ou have the right to request that your personal data is erased from our database in certain circumstances.
Right of access.
You have a right to ask for a copy of the personal data we hold about you. If you want to access your personal data, please send a description of the personal data you want to see and proof of your identity to firstname.lastname@example.org this is free of charge.
Right to rectification.
We also want to make sure that your personal data is accurate and up to date. Please let us know if your details change. You may also ask us to correct or remove personal data which is inaccurate.
Right to object.
You can also opt-out of receiving all marketing communications by clicking the unsubscribe link on any email marketing communication you receive from us, or request that we stop processing personal data about you for certain purposes at any time by contacting us using the details below.
Right to data portability.
In certain circumstances you have a right to data portability which means we will provide you (or a third party you nominate) with your personal data in a structured, commonly used and machine-readable format. Please note that you may only use/ benefit from some of these rights in limited circumstances. For more information, we suggest that you consult guidance from the Information Commissioner’s Office (ICO) or please contact us using the details below.
We keep personal data for as long as there is a need to keep it in connection with the purposes for which it was collected and in accordance with our Data Retention Policy. In the event that you ask us to stop sending you marketing communications, we will retain certain details, such as your name, to help us ensure that you are not contacted again.
Changes to your Details.
We aim to keep our information about you as accurate as possible. If you would like to review or change the details you have supplied us with, please contact us as set out below.
7. Where can you find more information about Jascots’ handling of your data?
The data controller responsible for your personal information for the purposes of the European Union data protection law is: If you have any questions about this privacy notice or our data collection practices, please contact our Data Protection Officer by writing to the Data Protection Officer at the address, telephone number or email listed below. Alternatively you may complete the web form on this page.
Jascots Wine Merchants
Call: + 020 8965 2000
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;