Privacy

This policy pertains to personal information collected through our system on Celtic Wines Ltd’s behalf. This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

About this policy

This policy describes how we use your personal data when you buy our goods, or when we provide services to you.  We have provided this policy to ensure that you understand what personal data we may collect and hold about you, what we may use it for and how we keep it safe. You have legal rights to access the personal data that we hold about you and to control how we use it which are also explained.

Who we are and how you can contact us

We are Celtic Wines Ltd, a Wholesaler of wine, beer, spirits and other alcoholic beverages

[Company No. 04926317].  Our Main Office / Depot address is at: Unit 1a, Warrior Way, Pembroke Dock Pembrokeshire SA72 6UB.

You can contact us in writing at the address given above or by emailing info@celticwines.com. If you would like to speak to us please call us on 01646 681369, ask for Margaret Ambrose, Helen Couling, or Daniel Smith for any data queries.

Please refer to the sections on Your rights to know what personal data we hold and to control how we use it and How to make a complaint for further contact information.

What personal data we collect about you

We collect:

• personal data that you provide to us.  There are lots of ways in which you may share your personal data with us, for example, you may contact us in connection with goods or services that you would like to buy, or have already bought, from us. The personal data that you provide to us may include your name, address, e-mail address and phone number, financial and credit card information.

What we use your personal data for

We use your personal data in the following ways:

• personal data that you provide to us is used to:
• process and respond to any enquiry you make such as ordering
• provide you with the information, products and services that you request from us
• provide you with marketing information in accordance with your marketing preferences (see How we use your personal data for marketing)
• manage and administer our business
• review and improve our goods and service

When we need your consent to use your personal data

Whilst we always want you to be aware of how we are using your personal data, this does not necessarily mean that we are required to ask for your consent before we can use it.  In the day to day running of our business we may use your personal data without asking for your consent because:

• we are entering into and carrying out our obligations under a contract with you
• we need to use your personal data for our own legitimate purposes (such as the administration and management of our business and the improvement of our services) and our doing so will not interfere with your privacy rights
• we have a legal obligation to do so

In exceptional circumstances we may wish to use your personal data for a different purpose which does require your consent.  In these circumstances we will contact you to explain how we wish to use your data and to ask for your consent.  You are not required to give consent just because we ask for it.  If you do give consent you can change your mind and withdraw it at a later date.

Please refer to the section on How we use your personal data for marketing to read about marketing consents.

Personal data you are legally obliged to provide

You are not under a legal obligation to provide us with any of your personal data but please note that if you elect not to provide us with your personal data we may be unable to provide our goods or services to you.

Your rights to know what personal data we hold and to control how we use it

You have a legal right to know what personal data we hold about you – this is called the right of subject access.  You can exercise this right by sending us a written request at any time. Please mark your letter “Subject Access Request” and send it to us by post or email using the details in the Who we are and how you can contact us section.

You also have rights to:

• prevent your personal data being used for marketing purposes (see How we use your personal data for marketing for further details)
• have inaccurate personal data corrected, blocked or erased
• object to decisions being made about you by automated means [or to your personal data being used for profiling purposes
• object to our using your personal data in ways that are likely to cause you damage or distress
• restrict our use of your personal data
• require that we delete your personal data
• require that we provide you, or anyone that you nominate, with a copy of any personal data you have given us in a structured electronic form such as a CSV file

You can find full details of your personal data rights on the Information Commissioner’s Office website at ww.ico.org.uk.

Automated decision making and profiling

We do not make use of automated decision making or profiling.

When we will share your personal data with others

We share your data with the following people in the day to day running our business:

• any business partners, suppliers and sub-contractors we work with to provide you with goods or services that you have requested from us
• if you have made a cash purchase we may have to share your personal data with HMRC as part of our money laundering compliance obligations

We may also share your personal information with third parties on a one-off basis, for example, if:

• we sell or buy any business or assets (including our own), in which case we will disclose your personal data to the prospective seller or buyer of such business or assets
• we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our website terms of use [http://celticwines.com/legal/] or our terms and conditions of supply and other agreements; or to protect the rights, property, or safety of our customers, ourselves or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction

How we keep your personal data safe

We take every care to ensure that your personal data is kept secure.  The security measures we take include:

• only storing your personal data on our secure servers
• ensuring that our staff receive regular data security awareness training
• keeping paper records to a minimum and ensuring that those we do have are stored in locked filing cabinets on our office premises
• maintaining up to date firewalls and anti-virus software to minimise the risk of unauthorised access to our systems
• enforcing a strict policy on the use of mobile devices and out of office working

Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of personal data sent to our website; you send us personal data at your own risk. Once we have received your personal data, we will use strict procedures and security features (some of which are described above) to try to prevent unauthorised access.

How we use your personal data for marketing

We will add your details to our marketing database if:

• you make an enquiry about our goods or services
• you buy our goods or services
• you have told a third party that you would like them to pass us your contact details so that we can send you updates about our goods and services

You can ask us to only send you marketing communications by particular methods (for example, you may be happy to receive emails from us but not telephone calls), about specific subjects, or you may ask us not to send you any marketing communications at all.

You can check and update your current marketing preferences at any time by calling or emailing us using the details set out in the Who we are and how you can contact us section above.

We never share your personal data with third parties for marketing purposes

When we will send your personal data to other countries

Your personal data may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”) by us or by our sub-contractors.  Where we, or our sub-contractors, use IT systems or software that is provided by non-UK companies, your personal data may be stored on the servers of these non-UK companies outside the EEA.  We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

How long we keep your personal data

We only keep your personal data for as long as we actually need it.  In practice this means that we will keep:

• your name and contact details for 7 years
• a record of the goods and services (including a copy of your full customer file) we provide to you for 7 years
• if we have collected your details as part of our money laundering compliance obligations, we will retain that information for 3 years
• complaint records for 3 years
• any financial or card details dictated to us in order to make a payment will be destroyed immediately following the payment

Please note that we may anonymise your personal data or use it for statistical purposes.   We keep anonymised and statistical data indefinitely but we take care to ensure that such data can no longer identify or be connected to any individual.

How you can make a complaint

If you are unhappy with the way we have used your personal data please contact us to discuss this using the contact details set out in the Who we are and how you can contact us section above.

You are also entitled to make a complaint to the Information Commissioner’s Office which you can do by visiting www.ico.org.uk.  Whilst you are not required to do so, we encourage you to contact us directly to discuss any concerns that you may have and to allow us an opportunity to address these before you contact the Information Commissioner’s Office.

How we keep this policy up to date

We will review and update this policy from time to time. This may be to reflect a change in the goods or services we offer or to our internal procedures or it may be to reflect a change in the law.

The easiest way to check for updates is by looking for the latest version of this policy on our website [http://celticwines.com/] or you can contact us (see Who we are and how to contact us) to ask us to send you the latest version of our policy.

Each time we update our policy we will update the policy version number shown at the end of the policy and the date on which that version of the policy came into force.

We are committed to protecting your privacy. We will only use the information that we collect about you lawfully in accordance with the Data Protection Act 1998.

We collect information about you for 2 reasons: firstly, to process the order and secondly, to provide you with the best possible service.

We will not e-mail you in the future unless you have given us your consent.

We will give you the chance to refuse any marketing email from us or from another trader in the future.

The type of information we will collect about you includes:
– your name
– address
– phone number
– email address

We will never collect sensitive information about you without your explicit consent. The information we hold will be accurate and up to date. You can check the information that we hold about you by emailing us. If you find any inaccuracies we will delete or correct it promptly. The personal information which we hold will be held securely in accordance with our internal security policy and the law. If we intend to transfer your information outside the EEA European Economic Area we will always obtain your consent first. We may use technology to track the patterns of behaviour of visitors to our site. This can include using a “cookie” which would be stored on your browser. You can usually modify your browser to prevent this happening. The information collected in this way can be used to identify you unless you modify your browser settings. If you have any questions/comments about privacy, you should email us.

Disclaimer
To the fullest extent permitted at law, ………….. provides this web site and its contents on an “as is” basis and makes no and expressly disclaims all representations or warranties of any kind, express or implied, with respect to this web site or the information, content, materials or products included in this site including, without limitation, warranties of merchantability and fitness for a particular purpose.

In addition, Celtic Wines does not represent or warrant that the information accessible via this web site is accurate, complete or current.

Price and availability information is subject to change without notice except as specifically stated on this Web Site, to the fullest extent permitted at law, neither Celtic Wines nor any of its affiliates, directors, employees or other representatives will be liable for damages arising out of or in connection with the use of this Web Site or the information, content, materials or products included on this site. This is a comprehensive limitation of liability that applies to all damages of any kind, including without limitation compensatory, direct, indirect or consequential damages, loss of data, income or profit, loss of or damage to property and claims of third parties. For the avoidance of doubt, Celtic Wines does not limit its liability for death or personal injury to the extent only that it arises as a result of the negligence of Celtic Wines, its affiliates, directors, employees or other representatives.

This is policy version [1] which came into effect on [25/05/18].