XECO Wines Limited

Website Privacy Notice

Last updated: May 25, 2018

 

XECO Wines Limited respects your right to privacy. This Privacy Notice explains who we are,

how we collect, share and use personal information about you, and how you can

exercise your privacy rights. This Privacy Notice only applies to personal information that we

collect through our Website or have collected by reference in writing to this Privacy Notice.

If you have any questions or concerns about our use of your personal information, then please

contact us using the contact details provided at the bottom of this Privacy Notice.

 

What does XECO Wines Limited do?

XECO Wines Limited is a privately owned alcoholic beverage company, headquartered in London,

United Kingdom. Our products consist of a range of fortified wines and brand-related

offerings for consumers.

 

What personal information does XECO Wines Limited collect and why?

 

The personal information that we may collect about you broadly falls into categories:

1. Information that you provide voluntarily

Certain parts of our Website may ask you to provide personal information voluntarily:

for example, we may ask you to provide your contact details in order to register for the

provision of information. The personal information that you are asked to provide, and

the reasons why you are asked to provide it, will be made clear to you at the point we

ask you to provide your personal information. For example, we may ask you for your

date of birth for age verification purposes.

 2. Information that we collect automatically

When you visit our Website, we may collect certain information automatically from your

device. In some countries, including countries in the European Economic Area, this

information may be considered personal information under applicable data protection

laws.

Specifically, the information we collect automatically may include information like your

IP address, device type, unique device identification numbers, browser-type, broad

geographic location (e.g. country or city-level location) and other technical information.

Location information will only be collected where you have specifically permitted your

device to share such information. Should you not wish us to automatically collect

location data you should turn off the location sharing feature on your device. We may

also collect information about how your device has interacted with our Website,

including the pages accessed and links clicked.

Collecting this information enables us to better understand the visitors who come to our

Website, where they come from, and what content on our Website is of interest to

them. We use this information for our internal analytics purposes and to improve the

quality and relevance of our Website to our visitors.

Some of this information may be collected using cookies and similar tracking technology,

as explained further under the heading “Cookies and similar tracking technology” below.

3. Information that we obtain from third party sources

From time to time, we may receive personal information about you from third party

sources, but only where we have checked that these third parties either have your

consent or are otherwise legally permitted or required to disclose your personal

information to us.

The types of information we might collect from third parties include your name and

contact details and we may use the information we receive from these third parties to

maintain and improve the accuracy of the records we hold about you and the goods we

offer to you.

 

In general, we will use the personal information we collect from you only for the purposes

described in this Privacy Notice or for purposes that we explain to you at the time we collect

your personal information. However, we may also use your personal information for other

purposes that are not incompatible with the purposes we have disclosed to you (such as

archiving purposes in the public interest, scientific or historical research purposes, or statistical

purposes) if and where this is permitted by applicable data protection laws.

 

Who does XECO Wines Limited share my personal information with?

We may disclose your personal information to the following categories of recipients:

● to third party services providers and partners who provide data processing services to

us (for example, to process information, fulfil and deliver orders, process credit card

payments and provide support services on our behalf, or help to enhance the security of

our Website) , or who otherwise process personal information for purposes that are

described in this Privacy Notice or notified to you when we collect your personal

information;

● to any competent law enforcement body, regulatory, government agency, court or

other third party where we believe disclosure is necessary (i) as a matter of applicable

law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect

your vital interests or those of any other person;

● to a potential buyer (and its agents and advisers) in connection with any proposed

purchase, merger or acquisition of any part of our business, provided that we inform the

buyer it must use your personal information only for the purposes disclosed in this

Privacy Notice;

● to any other person with your consent to the disclosure.

 

Legal basis for processing personal information (EEA visitors only)

If you are a visitor from the European Economic Area, our legal basis for collecting and using the

personal information described above will depend on the personal information concerned and

the specific context in which we collect it.

 

However, we will normally collect personal information from you only where we have your

consent to do so, where we need the personal information to perform a contract with you, or

where the processing is in our legitimate interests and not overridden by your data protection

interests or fundamental rights and freedoms. In some cases, we may also have a legal

obligation to collect personal information from you or may otherwise need the personal

information to protect your vital interests or those of another person.

 

If we ask you to provide personal information to comply with a legal requirement or to perform

a contact with you, we will make this clear at the relevant time and advise you whether the

provision of your personal information is mandatory or not (as well as of the possible

consequences if you do not provide your personal information).

 

Similarly, if we collect and use your personal information in reliance on our legitimate interests

(or those of any third party), we will make clear to you at the relevant time what those

legitimate interests are.

 

If you have questions about or need further information concerning the legal basis on which we

collect and use your personal information, please contact us using the contact details provided

under the “How to contact us” heading below.

 

Cookies and similar tracking technology

We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use

personal information about you. For further information about the types of Cookies we use,

why, and how you can control Cookies, please see our Cookie Notice.

 

How does XECO Wines Limited keep my personal information secure?

We use appropriate technical and organisational measures to protect the personal information

that we collect and process about you. The measures we use are designed to provide a level of

security appropriate to the risk of processing your personal information.

 

International data transfers

Your personal information may be transferred to, and processed in, countries other than the

country in which you are resident. These countries may have data protection laws that are

different to the laws of your country (and, in some cases, may not be as protective) .

 

However, we have taken appropriate safeguards to require that your personal information will

remain protected in accordance with this Privacy Notice. These include implementing the

European Commission’s Standard Contractual Clauses for transfers of personal information

between our group companies, which require all group companies to protect personal

information they process from the EEA in accordance with European Union data protection

law.

 

Our Standard Contractual Clauses can be provided on request. We have implemented

appropriate safeguards with our third party service providers and partners and further

details can be provided upon request.

 

Data retention

We retain personal information we collect from you where we have an ongoing

legitimate business need to do so (for example, to provide you with a service you have

requested or to comply with applicable legal, tax or accounting requirements) .

 

When we have no ongoing legitimate business need to process your personal information,

we will either delete or anonymise it or, if this is not possible (for example, because your

personal information has been stored in backup archives) , then we will securely store

your personal information and isolate it from any further processing until deletion is possible.

 

Your data protection rights

You have the following data protection rights:

● If you wish to access, correct, update or request deletion of your personal information,

you can do so at any time by contacting us using the contact details provided under the

“How to contact us” heading below.

● In addition, if you are a resident of the European Union, you can object to processing of

your personal information, ask us to restrict processing of your personal information or

request portability of your personal information. Again, you can exercise these rights by

contacting us using the contact details provided under the “How to contact us” heading

below.

● You have the right to opt-out of marketing communications we send you at any time.

You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the

marketing e-mails we send you. To opt-out of other forms of marketing (such as postal

marketing or telemarketing), then please contact us using the contact details provided

under the “How to contact us” heading below.

● Similarly, if we have collected and process your personal information with your consent,

then you can withdraw your consent at any time. Withdrawing your consent will not

affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it

affect processing of your personal information conducted in reliance on lawful

processing grounds other than consent.

● You have the right to complain to a data protection authority about our collection and

use of your personal information. For more information, please contact your local data

protection authority.

 

We respond to all requests we receive from individuals wishing to exercise their data protection

rights in accordance with applicable data protection laws.

 

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or

business developments. When we update our Privacy Notice, we will take appropriate measures

to inform you, consistent with the significance of the changes we make. We will obtain your

consent to any material Privacy Notice changes if and where this is required by applicable data

protection laws.

 

You can see when this Privacy Notice was last updated by checking the “last updated” date

displayed at the top of this Privacy Notice.

 

How to contact us

If you have any questions or concerns about our use of your personal information,

please contact us at hello@xecowines.com

 

The data controller of your personal information is XECO Wines Limited.