We collect personal information about you (i.e. information which may identify you in some way, such as your name, address, delivery address (if different), confirmation you are over 18, cardholder and payment details, gender and other contact details such as telephone number, company, email address, etc. and passwords) through this Site only when you voluntarily submit it. For example, when you register on the Site, purchase our goods, subscribe to our services, request information, submit comments or participate in some competition, game, promotion, survey or other feature of the Site. We may also ask you for information when you report a problem with our Site. If you do not want your personal information collected, please do not submit it.
If you contact us we may keep a record of that correspondence.
You must not attempt to purchase and/or provide us with your personal information if you are not of legal age to purchase alcohol in your country of residence and, if different, the country from which you are accessing the Site. For UK residents the legal purchase age is 18 years or over. We do not intend to collect personal information from, or market to, anyone under the legal purchase age.
If we believe you are under the legal purchase age we will make every effort to remove your personal information from our records, other than where we are required to keep this information to show how we enforce our age policy.1.2 Use Of Your Personal Information
The purposes for which we use your information and the legal basis under data protection laws on which we rely to do this are explained below.Where you have provided CONSENT
We may use and process your personal information where you have consented for us to do so, including to contact you via email with marketing information about our goods and services if you (i) indicate that you would like to receive such marketing from us; (ii) sign up to our newsletter emails via our Site or other medium where available; or (iii) when you refresh your marketing preferences when responding to a request from us to do so.
You may withdraw your consent for us to use your information in any of these ways at any time. Please see “Withdrawing your consent” below for further details.
Where it is in your VITAL INTEREST
Where we have supplied you with any products, we may use your personal information to contact you if there are any urgent safety or product recall notices to communicate to you or where we otherwise reasonably believe that the processing of your personal information will prevent or reduce any potential harm to you. It is in your vital interests for us to use your personal information in this way.
Where there is a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business, or that of a third party, for the following purposes:
- for analysis to inform our marketing strategy, and to enhance and personalise your customer experience (including to improve the recommendations we make to you on our Site);
- to correspond or communicate with you;
- to verify the accuracy of data that we hold about you and create a better understanding of you as a customer;
- for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
- for prevention of fraud and other criminal activities;
- to assess and improve our service to customers through recordings of any calls with our contact centres;
- for the management of queries, complaints, or claims; and
- for the establishment and defence of our legal rights.
Where there is a LEGAL REQUIREMENT
We will use your personal information to comply with our legal obligations: (i) to assist a public authority or criminal investigation body; (ii) to identify you and your age when you contact us (for identification purposes and for age restricted sales); (iii) to verify the accuracy of data we hold about you; and/or (iv) to comply with a request from you in connection with the exercise of your rights (for example where you have asked us not to contact you for marketing purposes, we will keep a record of this on our suppression lists in order to be able to comply with your request).
Where it is required to complete a CONTRACT
We may use and process your personal information where it is required to complete a contract for the following purposes:
- to process your order data (which may include your name, billing address, delivery address, phone number and email address) for the purposes of fulfilling and delivering your orders to you;
- to process your transaction data (which may include information relating to your previous purchases of goods or services, your name, billing address, delivery address, telephone number, email address and purchase history) for the purpose of supplying the purchased goods or services, fast check-out and keeping records of transactions; and
- to process financial information (which may include your encrypted card details – where your primary account number (PAN) is replaced with a series of randomly-generated numbers, name and billing address) for the purposes of processing your payments, refunds and to prevent fraud.
Data Anonymisation and Use of Aggregated Information
Your information may be converted into statistical or aggregated data in such a way as to ensure that you are not identified or identifiable from it. Aggregated data cannot be linked back to you as a natural person. We may use this data for analytical and research purposes.
Our suppliers and service providers
We may disclose your information to our third party service providers, agents, subcontractors and other organisations for the purposes of providing services and goods to us or directly to you on our behalf such as Drinksupermarket.com. Such third parties may include logistics or delivery companies, cloud service providers (such as hosting and email management), advertising agencies and administrative services.
When you purchase any products or services online, your credit/debit card payment is processed by Shopify eCommerce solutions who specialises in the secure online capture and processing of credit/debit card transactions. Barclays Bank provides the pop-up with banking services. If you have any questions regarding secure transactions, please contact us using the details at the end of this policy.
When we use third party service providers, we only disclose to them any personal information that is necessary for them to provide their service and we have a contract in place that requires them to keep your information secure and not to use it other than in accordance with our specific instructions.
Other ways we may share your personal information
We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation. We may also transfer your personal information if we’re under a duty to disclose or share it in order to comply with any legal obligation, to detect or report a crime, to enforce or apply the terms of our contracts or to protect the rights, property or safety of our visitors and customers. We will always take steps with the aim of ensuring that your privacy rights continue to be protected.
We will not provide any of your personal information to any third parties, for marketing purposes, without your specific consent. At the point of collection of your information we will ask you if you would like to "opt-in" to marketing by us and/or our third party partners (which we will give you details of at the time we ask for your consent).
If you opt in to receive marketing from Freixenet and/or our third party partners by email, your personal information will be used by Freixenet and we will pass it to our third parties (if requested by you) for marketing purposes. This may include sending you newsletters, details about promotions or offers, or other information which may interest you. All email marketing communications will have instructions on how to unsubscribe from future email marketing communications.
We use link and image tracking within email newsletters to track which links are being opened and clicked on. This data is only used in aggregated form and cannot be used to identify individuals.
1.4 Storage Of Your Personal Data
All information you provide to us may be transferred to countries outside the European Economic Area (EEA). By way of example, this may happen where any of our group companies are incorporated in a country outside of the EEA or if any of our servers or those of our third party service providers are from time to time located in a country outside of the EEA. These countries may not have similar data protection laws to the UK.
If you use our services whilst you are outside the EEA, your information may be transferred outside the EEA in order to provide you with those services.
1.5 Your Rights
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to confirm your identity and, where applicable, to help us to search for your personal information. Except in cases where we are entitled to an extension, we will respond to you within one month from either (i) the date that we have confirmed your identity and/or the scope of your request or (ii) where we do not need to do this because we already have this information, from the date we received your request.
Accessing your personal information
You have the right to ask for a copy of the information that we hold about you by emailing or writing to us at the address at the end of this policy. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Correcting and updating your personal information
The accuracy of your information is important to us and we are working on ways to make it easier for you to review and correct the information that we hold about you.
Withdrawing your consent
Objecting to our use of your personal information and automated decisions made about you
You may object to us using your personal information for direct marketing purposes and we will automatically comply with your request. If you would like to do so, please use our unsubscribe tool.
Erasing your personal information or restricting its processing
You may also ask us to restrict processing your personal information where you believe it is unlawful for us to do so, you have objected to its use and our investigation is pending or you require us to keep it in connection with legal proceedings. In these situations we may only process your personal information whilst its processing is restricted if we have your consent or are legally permitted to do so, for example for storage purposes, to protect the rights of another individual or company or in connection with legal proceedings.
Transferring your personal information in a structured data file (“data portability”)
Where we rely on your consent as the legal basis for processing your personal information or need to process it in connection with your contract you may ask us to provide you with a copy of that information in a structured data file. We will provide this to you electronically in a structured, commonly used and machine readable form, such as a CSV file.
You can ask us to send your personal information directly to another service provider, and we will do so if this is technically possible. We may not provide you with a copy of your personal information if this concerns other individuals or we have another lawful reason to withhold that information.
Complaining to the UK data protection regulator
You have the right to complain to the Information Commissioner’s Office (ICO) if you are concerned about the way we have processed your personal information. Please visit the ICO’s website for further details (www.ico.org.uk).
1.6 Security Of Your Information
We use certain reasonable security measures to help protect information you send to this Site. However, we cannot guarantee the security of such information. To the fullest extent permitted by law, we disclaim all liability and responsibility for any damages you may suffer due to any loss, unauthorised access, misuse or alteration of any information you submit to this Site.
1.7 How Long We Keep Your Data
If we collect your personal information, the length of time we retain it is determined by a number of factors including the purpose for which we use that information and our obligations under other laws. We do not retain personal information in an identifiable format for longer than is necessary.
We may need your personal information to establish, bring or defend legal claims. For this purpose, we will always retain your personal information for 7 years after the date it is last used by us. The only exceptions to this are where:
- the law requires us to hold your personal information for a longer period, or delete it sooner;
- you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Erasing your personal information or restricting its processing below); or
- in limited cases, the law permits us to keep your personal information indefinitely provided we put certain protections in place.
1.8 Links To Other Websites
Our Site may from time to time, contain links to and from other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
1.10 Contact Us
You may contact us at any time if you have any queries about our use of your personal information or if you would like to exercise any of your rights listed above You can write to: The Data Protection Compliance Manager, Freixenet UK Ltd, 23 Wellington Business Park, Dukes Ride, Crowthorne, Berkshire RG45 6LS, UK or send an e-mail to: firstname.lastname@example.org.