Privacy Policy

 

Welcome to the Ratcliffe and Brown Wines privacy policy.

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Ratcliffe and Brown Wines respects your privacy and is committed to protecting your personal data.

The information set out in this privacy policy aims to inform you as to how we collect and look after your personal data when you visit our website, when you purchase wines, spirits or other products and services from us (through our website) when you open a customer account and/or register with us, when you otherwise contact us and when we deliver you the products and services you have ordered from us. It will also tell you about your privacy rights and how the law protects you.

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IMPORTANT INFORMATION

It is important that you read this privacy policy together with our Terms and Conditions. Please note that Ratcliffe and Brown Wines may update and amend this privacy policy from time to time and any changes will be posted on our website. This version was last updated in February 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. 

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

By accessing and continuing to use the Ratcliffe and Brown Wines website, you accept the terms of this privacy policy.

 

WHO WE ARE

Ratcliffe and Brown Wines is a trading name of Ratcliffe & Brown Wines and Spirits Ltd., a company incorporated in England and Wales with company number 3898602. Our registered office is Agusta House, Edenbridge TN8 6ED and is referred to as "Ratcliffe and Brown Wines”, “we”, “us” or “our” in this privacy policy.

Ratcliffe and Brown Wines is a wholesaler of wines and spirits. We operate this ecommerce website to provide our customers with the ability to purchase from a selection of distinctive wines & spirits which we source from producers around the world. 

Ratcliffe and Brown Wines is a controller and we are responsible for your personal data. We are bound by applicable data protection laws in respect of the handling and collection of your personal data and are in the process of becoming registered as a data controller in England and Wales, with the Information Commissioner's Office (ICO).

If you have any questions about this privacy policy, including any requests to exercise your legal rights as set out in the 'LEGAL RIGHTS' section, please contact us using the contact details in the 'CONTACT' section.

 

THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data) or data relating to a corporate entity.

If you visit our website, or contact us about employment opportunities or to enquire about our products and services or are a customer making contact with us via our website or by telephone or email, we may collect, use, store and transfer different kinds of personal data about you, which we have grouped together as follows:

•    Identity Data includes first name, last name, title and date of birth.

•    Contact Data includes home or business address, billing and delivery address(es), place of work, email address(es) and telephone number(s).

•    Financial Data includes our customers' card holder details, bank account details (bank name, account name, number, address and sort code).

•    Transaction Data includes details about order history, payment instructions, payment patterns (including details related to certain subscription payments) made by you.

•    Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, use of cookies or other devices to store and sometimes track information about you (more details on our use of cookies is set out in the 'Cookies' section) and other technology on the devices you use to access this website or our software.

•    Profile Data includes your username and password, purchases and orders made by you, any membership or event history, account preferences, feedback and survey responses.

•    Usage Data includes information about how you use our website and/or software.

•    Marketing and Communications Data includes your preferences in receiving marketing from us, or from our clients or other third parties and your communication preferences.

Special Categories of Personal Data. We do not actively collect any special categories of personal data about you. Children. Our website is not intended for children and in this respect we do not knowingly collect data relating to children.

We do not actively collect any information about criminal convictions and offences.

 

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our products or services or open up a customer account). In this case, we may have to suspend or cancel a product or service you have with us but we will notify you if this is the case at the time.

 

HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

•    Direct interactions. You may give us your Identity, Contact, Profile, Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email, social media or otherwise. This includes personal data you provide when you:

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o    purchase any of our products or services from our website, in our shop or at our events;

o    purchase any of our products or services by making contact with us via email or by telephone;

o    set up a customer account with us (as an individual, as a sole trader or on behalf of a corporate entity);

o    meet with one of our members of staff to discuss our products and services or otherwise contact us;

o    make contact with our sales and support teams via email or telephone;

o    request marketing and publications to be sent to you;

o    subscribe to our newsletter;

o    enter a competition, promotion or survey;

o    email us about your interest in a job with us; or

o    give us some feedback.

•    Automated technologies or interactions. As you interact with our website or software we may automatically collect Technical or Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see the 'Cookies' section.

•    Third parties or publicly available sources. We may receive personal data about you from various other third parties and public sources as set out below:

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o    Identity and Contact Data from individuals recommending, in a business-to-business context, that we make contact with you to introduce our products and services to you;

o    Identity, Contact (and possibly Special Categories of Personal) Data from recruitment professionals who send us your CV; and

o    Technical and Usage Data from analytics providers, such as Google, based outside the EU.

 

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

•    Performance of Contract means processing your personal 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.

•    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best product/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 contact us for further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities (please see the 'CONTACT' section).

•    Consent means where we have obtained your agreement to process your personal data. Consent must be freely given, specific, informed and be an unambiguous indication of your wishes for us to process your personal data (this may be collected by you ticking a box). Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending our newsletters and/or marketing material to you via email, post, phone, text message and social media. You have the right to withdraw consent to newsletters and/or marketing at any time by contacting us (please see the 'Opting Out / Unsubscribing', the 'Withdraw consent at any time' and the 'CONTACT' sections).

•    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

•    Prospecting. In a business-to-business context we may make contact with you to provide or seek information in connection with our products and/or services. The legal basis we rely on for making contact with you and processing your personal data is our shared legitimate interests in doing business together. When we make contact with you, you can exercise your right to object to such contact from us (please see the 'Object to processing' section).

•    Marketing. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

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o    Unsubscribe link displayed on every email newsletter and marketing communication.

o    Account settings within our website to enable individuals who work for and on behalf of our clients, or our clients' customers, with an account, to change their preferences.

Marketing from Us

If you provide your express, opt-in consent, we may use your Identity, Contact, Technical, Usage and/or Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You may receive marketing communications from us after you have requested information from us or opened a customer account and, in each case, you have opted-in to receiving that marketing.

You can withdraw your consent at any time.

In some limited circumstances, we may contact you about similar products and/or services where you have purchased products or services from us and you have not opted-out of receiving this information. The legal basis on which we process personal data for these purposes is our legitimate interest to develop our products and services and grow our business.

You can ask us to stop sending you marketing communications at any time (please see the 'Opting Out / Unsubscribing' section).

Third-Party Marketing

We will get your express opt-in consent before we share your personal data with any company outside Ratcliffe and Brown Wines for marketing purposes. We have made it clear to our clients that they must do the same. If you think any of our clients are not operating in accordance with this policy, please let us know.

Opting Out / Unsubscribing

You can ask us or our clients to stop sending you marketing messages at any time by logging into your account (if you are a customer account user using our software on our clients’ websites) and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out / unsubscribe links on any marketing message sent to you or by contacting us at any time.

Where you opt out of receiving these marketing messages, you may still receive messages for other purposes (such as providing the services to you).

•    Cookies. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our website. By continuing to browse the website, users are agreeing to our use of cookies.

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you disable or refuse cookies when browsing our website, please note that some parts of our website may become inaccessible or not function properly.

•    Change of Purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, you can contact us (please see the 'CONTACT' section).

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

 

DATA SECURITY

We have put in place appropriate security measures (including SSL technology) to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

 

DATA RETENTION

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

We will generally retain our clients' data for a period of five years after a contract has ended, to ensure that we are able to assist you should you have any questions or feedback in relation to our products or services or to protect, or defend our legal rights, or for tax purposes.

We have processed your personal data to provide you with marketing communications with consent, we may contact you at least every 12 months to ensure you are happy to continue receiving such communications. If you tell us that you no longer wish to receive such communications, your personal data will be removed from our marketing lists (but will be added to a "do not contact" list).

 

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are detailed below:

•    Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

•    Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

•    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

•    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

•    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

•    Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

•    Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

•    If you wish to exercise any of the rights set out above, please contact us directly (please see the 'CONTACT' section).

•    No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

•    What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

•    Time limit to respond. 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.

©2020 by Ratcliffe & Brown Wines.

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