This privacy policy applies between you, the user of this website and Winoship Ltd (Winoship Wines), the owner and provider of this website. Winoship Wines takes the privacy of your information very seriously. This privacy policy applies to our use of any data collected by us or provided by you in relation to your use of the website. Please read this privacy policy carefully.

Definitions and interpretation

1. In this privacy policy, the following definitions are used:

Data – Collectively all information that you submit to Winoship Wines via the website. This definition incorporates, where applicable, the definitions provided in the Data Protection Act 1998;

Cookies – A small text file placed on your computer by this website when you visit certain parts of the website and/or when you use certain features of the website. Details of the cookies used by this website are set out in the clause below (cookies);

Winoship Wines Ltd, or us Winoship Wines, a company incorporated in England and Wales with registered number 11884735 whose registered office is at 13 Hambledon Place, London, SE21 7EY,

UK and EU Cookie Law – The Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011,

User or you – Any third party that accesses the website and is not either (i) employed by Winoship Wines and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to Winoship Wines and accessing the website in connection with the provision of such services; and

Website – The website that you are currently using, www.winoship.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions.

2. In this privacy policy, unless the context requires a different interpretation:
3. the singular includes the plural and vice versa;
4. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy,
5. a reference to a person includes firms, companies, government entities, trusts and partnerships,
6. “including” is understood to mean “including without limitation”,
7. reference to any statutory provision includes any modification or amendment of it,
8. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Winoship Wines and Users with respect to this website. It does not extend to any websites that can be accessed from this website including, but not limited to, any links we may provide to social media websites.

Data collected

4. We may collect the following data, which includes personal data, from you:
5. Name
6. Contact information such as email addresses and telephone numbers,
7. IP address (automatically collected),
8. Web browser type and version (automatically collected),
9. Operating system (automatically collected),
10. in each case, in accordance with this privacy policy.

Our use of Data

5. For purposes of the Data Protection Act 1998, Winoship Wines is the “data controller”.
6. We will retain any data you submit for 12 months.
7. Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this policy, your data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.
8. All personal data is stored securely in accordance with the principles of the Data Protection Act 1998. For more details on security see the clause below (security).
9. Any or all of the above data may be required by us from time to time in order to provide you with the best possible service and experience when using our website. Specifically, data may be used by us for the following reasons:
10. internal record keeping;
11. improvement of our products / services;
12. transmission by email of promotional materials that may be of interest to you; in each case, in accordance with this privacy policy.

Third party websites and services

10. Winoship Wines may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the website. The providers of such services do not have access to certain personal data provided by Users of this website.

Links to other websites

11. This website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

12. Winoship Wines may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Winoship Wines. Data provided by users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the data for the purposes for which it was originally supplied to us.
13. We may also disclose data to a prospective purchaser of our business or any part of it.
14. In the above instances, we will take steps with the aim of ensuring your privacy is protected.

Controlling use of your Data

15. Wherever you are required to submit data, you will be given options to restrict our use of that data. This may include the following:
16. use of data for direct marketing purposes; and
17. sharing data with third parties.

Functionality of the Website

18. To use all features and functions available on the website, you may be required to submit certain data.
19. You may restrict your internet browser’s use of cookies. For more information see the clause below (cookies).

Accessing your own Data

20. You have the right to ask for a copy of any of your personal data held by Winoship Wines (where such Data is held) on payment of a small fee, which will not exceed £10.

Security

21. Data security is of great importance to Winoship Wines and to protect your data we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure data collected via this website.
22. If password access is required for certain parts of the website, you are responsible for keeping this password confidential.
23. We endeavour to do our best to protect your personal data. However, transmission of information over the internet is not entirely secure and is done at your own risk. We cannot ensure the security of your data transmitted to the website.

Cookies

24. This website may place and access certain cookies on your computer. Winoship Wines uses cookies to improve your experience of using the website and to improve our range of services. Winoship Wines has carefully chosen these cookies and has taken steps to ensure that your privacy is protected and respected at all times.
25. All cookies used by this website are used in accordance with current UK and EU Cookie Law.
26. Before the website places cookies on your computer, you will be presented with a pop-up requesting your consent to set those cookies. By giving your consent to the placing of cookies, you are enabling Winoship Wines to provide a better experience and service to you. You may, if you wish, deny consent to the placing of cookies; however certain features of the website may not function fully or as intended.
27. This website may place the following Cookies:

Strictly necessary cookies – These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies – These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

28. You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.
29. You can choose to delete cookies at any time; however you may lose any information that enables you to access the website more quickly and efficiently including, but not limited to, personalisation settings.
30. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

General

31. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
32. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
33. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
34. This agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.

Changes to this privacy policy

35. Winoship Wines reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. You may contact Winoship Wines by email at dataprotection@winoship.com Date Of This Privacy Policy – 29 October 2020

GDPR POLICY

Winoship Ltd operate a GDPR Compliance Policy for all data that we hold, process and retain.

GDPR Compliance Statement Commitment

Winoship LTD, Unit 16 Wilkinson Court, Clywedog Road South, Wrexham Industrial Estate, Wrexham, LL13 9AE, with the following responsibilities is committed to the principles inherent in the GDPR and particularly to the concepts of privacy by design, the right to be forgotten, consent and a risk-based approach.

In addition, we aim to ensure:

transparency with regards to the use of data

that any processing is lawful, fair, transparent, and necessary for a specific purpose

that data is accurate, kept up to date and removed when no longer necessary

that data is kept safely and securely.

Staffing

Our Data Protection Officer (DPO)/appointed data protection person is Dean Totham, Winoship LTD, 13 Hambledon Place, London, SE21 7EY. He works with a data protection team to promote awareness of the GDPR throughout the organisation and to oversee the organisation’s commitment to best practice. He or she will inform and advise the organisation and monitor its compliance.

Policy

Our data protection policy is available on our website and a copy has been made available to all employees and to contractors and suppliers associated with this organisation. It forms part of the induction training of all new staff and follow-up sessions will be put in place if the legislation changes or further guidance is available.

Right to be forgotten

Winoship Ltd recognises the right to erasure, also known as the right to be forgotten, laid down in the GDPR. Individuals should contact dataprotection@winoship.com with requests for the deletion or removal of personal data. These will be acted on provided there is no compelling reason for continued processing and that the exemptions set out in the GDPR do not apply. These exemptions include where the personal data is processed for the exercise or defence of legal claims and to comply with a legal obligation for the performance of a public interest task or exercise of official authority.

Subject access requests

Winoship Ltd recognises that individuals have the right to access their personal data and supplementary information and will comply with the one-month timeframe for responses set down in the GDPR. As a general rule, a copy of the requested information will be provided free of charge although Winoship Ltd reserves the right to charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive. If this proves necessary, the person concerned will be informed of their right to contest our decision with the supervisory authority (the Information Commissioner’s Office (ICO)). As set out in the GDPR, any fee will be notified in advance and will be based on the administrative cost of providing the information.

Privacy

Winoship Ltd will implement data protection “by design and by default”, as required by the GDPR. Safeguards will be built into products and services from the earliest stage of development and privacy-friendly default settings will be the norm. The privacy notice, which is on our website and which is provided to anyone from whom we collect data, explains our lawful basis for processing the data and gives the data retention periods. It makes clear that individuals have a right to complain to the ICO. Winoship Ltd has conducted a privacy impact assessment (PIA) to ensure that privacy risks have been carefully considered and addressed.

Data transfers outside the EU

Either

Winoship LTD does not transfer personal data outside the EU.

Or

Winoship LTD has put recognised procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of any personal data that is transferred to countries outside the EU. Diligence checks are carried out to ensure that such countries have the necessary safeguards in place, provide enforceable data subject rights and offer effective legal remedies for data subjects where applicable.

Children

The GDPR provides for special protection for children’s personal data and Winoship Ltd will comply with the requirement to obtain parental or guardian consent for any data processing activity involving anyone under the age of 16. Systems have been introduced to verify individuals’ ages.

Data loss

If a data breach occurs that is likely to result in a risk to the rights and freedoms of individuals, the people affected will be informed as soon as possible and the ICO will be notified within 72 hours.

GDPR contact

Any questions related to GDPR or to issues concerning data protection generally should initially be addressed to the Data Protection Team via dataprotection@winoship.com