Summary of how we use your information
‐ We will use your information in order to comply with your requests, correspond with you, administer our competitions and process any wine orders you make with us or with our related companies.
‐ This information will be shared with our related companies, who are often located outside the EEA.
‐ Where we rely on your consent (such as to send you marketing), you can withdraw this consent at any time. More details on how to withdraw consent are set out below.
Stewart Hill Walker UK Limited and your privacy
Information you give us
You provide us with information about yourself when corresponding with us, entering our competitions, buying our wines or when using or registering on our websites. This may include:
‐ when you transact with us online, over the phone or in person;
‐ when you enter a promotion or competition conducted by us (including via our websites or through social media sites);
‐ when you visit and/or register to use our websites or when you participate in any other social media functions pertaining to our website; or
‐ when you contact us to request information or support in relation to our company, products or services (including about our brands, product quality, visiting our sites or employment opportunities).
If you buy wine from us online for example, we will require you to provide us with your name, company name and address , as well as the company’s phone number to enable us to process your order and deliver your wine to your establishment. We will also require your date of birth to verify that you are of legal drinking age, and unless otherwise agreed, a company credit/debit card number, which is likely to contain an individual’s name, in order to process the sale.
‐ technical information such as your computer’s IP address, hardware type, browser type, device identifier and screen type/resolution;
‐ any search terms entered on our website;
‐ general location data based on your device or IP address;
‐ any technical errors or exceptions; and
‐ information about your visit such as the products you viewed or searched for, the length of your visit, page load speed, and the pages that you visited.
Cookies help us gather and store information about visitors to our websites. They help our websites remember what you chose on previous pages (to avoid having to re-enter information) and can help us to identify you as a unique visitor, tailor content based on past visitation and provide you with an optimised experience.
We use the following categories of tracking technologies on our websites:
- Strictly Necessary tracking technology – these technologies are essential in order to enable you to move around our website and use their features.
- Performance related tracking technology – these technologies collect anonymous information on how people use our website. For example, we may from time to use dedicated analytics to help us understand how users arrive at our website, browse or use our website and highlight areas where we can improve areas such as navigation, interface experience and marketing campaigns. The data stored by these technologies never show personal information from which any individual identity can be established.
- Functionality related tracking technology – these technologies remember choices you make such as the country from which you visit our website, your completion of the age verification check, language preferences and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these technologies collect may be anonymous and they cannot track your browsing activity on other sites.
- Targeting or advertising related tracking technology – these technologies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advert as well as help measure the effectiveness of an advertising campaign. These technologies are usually placed by third party advertising networks. They remember the sites you visit and that information is shared with other parties such as advertisers. For example, we use third party companies such as Twitter, Instagram, LinkedIn and will add other users in the future, to provide you with more personalised adverts when visiting other websites and social networks. A mix of first party and third party cookies are likely to be used.
- Social Media related tracking technologies – these technologies allow you to share content from our websites on social media such as Instagram and Twitter, or may use your login to these social networks to verify your age when visiting our website. These technologies are not within our control. Please refer to the respective privacy policies for how their technologies work.
- Commerce related technologies – these technologies are essential in order to enable a functional online shopping experience across our website and payment/checkout. They keep track of what products and quantities are in your shopping cart, your membership level, country / state (if applicable for tax or shipping compliance reasons) and any coupons or discounts you may utilise.
Our use of your information
We will not use your information to carry out electronic marketing unless we have your consent. For example, if you have entered a promotion in relation to our products, we may obtain your consent to send marketing materials about those products. If you receive electronic communications from us, we will always provide you with an opportunity to unsubscribe from receiving further information from us by clicking on the unsubscribe link provided in the communication.
We may use or disclose the personal information we collect for one or more of the following purposes in order to conduct our business and pursue our legitimate business interests (and where required, your consent):
‐ To fulfill or meet the reason you provided the information. For example, if you provide your personal information to purchase our products, we will use that information to process and manage your order. If you provide your details to apply for a job with TWE, we will use those details to process your application for employment.
‐ To provide, support, personalise, and develop our Website, products, and services and to help us gain a better understanding of your likes and dislikes in order to improve our websites and the services we offer.
‐ To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
‐ To personalise your Website experience and to deliver content and product and services relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (where we do not need your consent).
‐ To allow you to participate in interactive features of our website and administering our promotions and competitions.
‐ To verify that you are of legal drinking age in your jurisdiction (if applicable).
‐ To make suggestions and recommendations to you and other users of our websites about goods or services that may interest you or them.
‐ To fulfil a contract we may have with you, such as where you make a purchase from us.
‐ In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations).
‐ To produce consumer insights (e.g., general research on our consumers; conduct consumer testing, surveys, and panels; and data analytics when we sell to consumers).
‐ As described to you when collecting your personal information or as otherwise set forth in the CCPA.
‐ To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of TWE’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by TWE about our Website users is among the assets transferred.
In some instances, the provision of information to us is mandatory. If for example you want to buy wine from us and certain personal information is not provided (such as your age, your contact details and delivery address), then we will not be able to fulfil your order. We will always ensure that we minimise the amount of data we collect and will only ask for data that we need to process your request.
SWH will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your information for other purposes, such as those set out above. You have an absolute right to opt-out of direct marketing, and to object to profiling we carry out for direct marketing purposes, at any time. You can do this by following the instructions in the communication (where this is an electronic message) or by contacting us using the details set out below.
How long we keep your information
Where we process registration information, we retain this for as long as we consider that you are an active user of our sites and for 2 years after this.
Where we process personal information for marketing purposes or with your consent, we process the information until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your information indefinitely so that we can respect your request in future.
Where we process personal information in connection with performing a contract (such as when you purchase wine from us) or for a competition, we keep the information for 6 years from your last interaction with us.
Where we process personal information for site security and/or fraud management purposes, we retain it for 3 years.
Our disclosure of your information
We will not disclose your personal information to third parties except:
‐ with your consent;
‐ where we are required or authorised by law to do so, for example to law enforcement agencies;
‐ where third parties appointed by us require access to personal information held by us to perform services (in which case we require these third parties to keep that personal information confidential and not to use or disclose it for any purpose other than the purpose of performing those services). The types of third parties we may transfer information to include vendors, service providers, agencies and other partners who globally support our business and help us administer certain activities on our behalf, such as providing technical infrastructure services, marketing services, customer service, data hosting and management services, processing credit card payments services for us, and providing logistics and delivery services to help us deliver our products and services; or
‐ to our related companies in order to operate our global business and in accordance with the law.
We may also transfer personal information to a related company or a third party in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.
Our website may sometimes contain links to other websites. With the exception of our own website, we do not control the privacy practices of sites that may be contacted through links from our website. If you have any questions about the privacy practices of those websites then you should contact the relevant companies directly.
Your rights in relation to your information.
Under applicable law, you may be entitled to ask us for a copy of the personal information we hold about you, including to correct, delete or restrict processing of your personal information. In some jurisdictions, applicable law may also entitle you ask us to transmit your data to another controller where the processing is based on your consent carried out by automated means, or entitle you to object to the processing of your personal information in certain circumstances (in , where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing or profiling). However, these rights may be limited, for example if fulfilling your request would reveal personal information about another person, or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping.
To exercise any of these rights, you can get in touch with us using the details set out below.
We take appropriate measures to keep your personal information secure. We have implemented appropriate physical and electronic procedures to protect the personal information we collect. If you have an account with us, you are responsible for maintaining the confidentiality of your account details including your password, and are responsible for any activity under your account. We will not be responsible for any loss arising from your failure to comply with this obligation.
Due to its nature, transmission of information via the internet is not completely secure. Although we will protect your personal data in accordance with this policy, we cannot guarantee the security of any data transmitted to our websites and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security measures to try to prevent unauthorised access.
If you have any questions or concerns about our collection, use or disclosure of personal information, wish to exercise your rights in relation to data protection or you wish to make a complaint in relation to our privacy practices, please visit our privacy portal. If you have a complaint or concern about how we use your personal data, please contact us in the first instance and we will attempt to resolve the issue as soon as possible. You also have a right to lodge a complaint with your national data protection supervisory authority at any time.
For the purposes of the EU General Data Protection Regulation and the Data Protection Act in