At Hanwell Wine Estate we take your privacy very seriously. Maintaining the security of your data is a priority and we are committed to respecting your privacy rights. We pledge to handle your data fairly and legally at all times. Hanwell Wine Estate is also dedicated to being transparent about what data we collect about you and how we use it.
This policy, which applies when you visit our website at http://www.hanwellwine.co.uk/privacy-policy provides you with information about:
- how we use your data;
- what personal data we collect;
- how we ensure your privacy is maintained; and
- your legal rights relating to your personal data.
When we use your personal data we are regulated under the General Data Protection Regulation (GDPR) which applies across the European Union (including in the United Kingdom) and we are responsible as ‘controller’ of that personal data for the purposes of the GDPR. Our use of your personal data is subject to your instructions, the GDPR, other relevant UK and EU legislation and our professional duty of confidentiality.
- Key terms
- Personal data we collect about you
- How your personal data is collected
- How and why we use your personal data
- Promotional communications
- Who we share your personal data with
- Where your personal data is held
- How long your personal data will be kept
- Transferring your personal data out of the EEA
- Your rights
- Keeping your personal data secure
- How to complain
- How to contact us
|We, us, our||Hanwell Wine Estate|
|Our data protection officer||Helenka Brown|
|Personal data||Any information relating to an identified or identifiable individual|
Personal data we collect about you
The table below sets out the personal data we will or may collect in the course of running our business.
|Personal data we will collect:-|
|Your name, address and telephone number
Electronic contact details, eg your email address and mobile phone number
Information to enable us to undertake a credit or other financial checks on you if we are extending credit to you.
Details of your professional online presence, eg LinkedIn profile, Facebook page if we are working with your business
Information about your use of our IT, communication and other systems, and other monitoring information, eg if using our secure online customer website.
This personal data is required to enable us to provide our service to you. If you do not provide personal data we ask for, it may delay or prevent us from providing services to you.
How your personal data is collected
We collect most of this information directly from you, via web orders, email and online forms. However, we may also collect information:
- other professionals
- via our information technology (IT) systems, eg: reception logs; automated monitoring of our websites and other technical systems, such as our computer networks and connections, CCTV and access control systems, communications systems, email and instant messaging systems;
How and why we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason for doing so, eg:
- to comply with our legal and regulatory obligations means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to;
- for the performance of our contract with you or to take steps at your request before entering into a contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract;
- for our legitimate interests or those of a third party; or
- where you have given consent.
A legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
The table below explains what we use (process) your personal data for and our reasons for doing so:
|What we use your personal data for||Our reasons|
|To provide services to you||For the performance of our contract with you or to take steps at your request before entering into a contract|
|Ensuring business policies are adhered to, eg policies covering security and internet use||For our legitimate interests or those of a third party, ie to make sure we are following our own internal procedures so we can deliver the best service to you|
|Operational reasons, such as improving efficiency, training and quality control||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Ensuring the confidentiality of commercially sensitive information||For our legitimate interests or those of a third party, ie to protect our intellectual property and other commercially valuable information
To comply with our legal and regulatory obligations
|Statistical analysis to help us manage our business, eg. efficiency measures.||For our legitimate interests or those of a third party, ie to be as efficient as we can so we can deliver the best service for you at the best price|
|Preventing unauthorised access and modifications to systems||For our legitimate interests or those of a third party, ie to prevent and detect criminal activity that could be damaging for us and for you
To comply with our legal and regulatory obligations
|Statutory returns||To comply with our legal and regulatory obligations|
|Ensuring safe working practices, staff administration and assessments||To comply with our legal and regulatory obligations
For our legitimate interests or those of a third party, eg to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
|Marketing our services to you:
|For our legitimate interests to promote our business to our clients|
We may use your personal data to send you updates by email that might be of interest to you and/or information about our products and services.
We have a legitimate interest in processing your personal data for promotional purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal data with the utmost respect and never sell OR share it with other organisations outside of Hanwell Wine Estate for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:
- contacting us on email@example.com
- using the ‘unsubscribe’ link in emails
We may ask you to confirm or update your marketing preferences in the future.
Who we share your personal data with
|External Third Parties||Reason for sharing personal data|
|External service suppliers, representatives and agents that we use to make our business more efficient, eg admin services, marketing agencies, accountants, auditors, suppliers.||We only allow our service providers to handle your personal data if we are satisfied they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers relating to ensure they can only use your personal data to provide services to us and to you. We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal data with other parties, in these cases the recipient of the information will be bound by confidentiality obligations.
Where your personal data is held
Information may be held at our premises and those of our third party agencies, service providers, representatives and agents as described above (see ‘Who we share your personal data with’).
Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal data when this occurs, see below: ‘Transferring your personal data out of the EEA’.
How long your personal data will be kept
We will keep your personal data after we have finished advising or acting for you. We will do so for one of these reasons:
- to respond to any questions, complaints or claims made by you or on your behalf;
- to show that we treated you fairly;
- to keep records required by law.
We will not retain your data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of data
When it is no longer necessary to retain your personal data, we will delete or anonymise it.
Transferring your personal data out of the EEA
To deliver services to you, it is sometimes necessary for us to share your personal data outside the European Economic Area (EEA), eg:
- with our service providers located outside the EEA;
- if you are based outside the EEA;
These transfers are subject to special rules under European and UK data protection law.
Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal data will be secure. Our standard practice is to use standard data protection contract clauses which have been approved by the European Commission.
If you would like further information please contact, our Data Protection Officer (see ‘How to contact us’ below).
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
You have the following rights, which you can exercise free of charge:
|Access||The right to be provided with a copy of your personal data|
|Rectification||The right to require us to correct any mistakes in your personal data|
|To be forgotten||The right to require us to delete your personal data—in certain situations|
|Restriction of processing||The right to require us to restrict processing of your personal data—in certain circumstances, eg if you contest the accuracy of the data|
|Data portability||The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations|
|To object||The right to object:
—at any time to your personal data being processed for direct marketing (including profiling);
—in certain other situations to our continued processing of your personal data, eg processing carried out for the purpose of our legitimate interests.
|Not to be subject to automated individual decision-making||The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you|
For further information on each of those rights, including the circumstances in which they apply, please contact us or see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.
If you would like to exercise any of those rights, please:
- email, call or write to us see below: ‘How to contact us’; and
- let us have enough information to identify you (eg your full name, address, email address and order or contract reference).
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill); and
- let us know what right you want to exercise and the information to which your request relates.
Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
How to complain
We hope that we can resolve any query or concern you may raise about our use of your information.
The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live or where any alleged infringement of data protection laws occurred. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns or telephone: [0303 123 1113].
How to contact us
Our contact details are shown below:
Hanwell Wine Estate, Melton Road, Hickling Pastures, Melton Mowbray LE14 3QG
Our Data Protection Officer’s contact details:
Helenka Brown, Hanwell Wine Estate, Melton Road, Hickling Pastures, Melton Mowbray LE14 3QG
Tel: 01949 81393