Who we are
Laithwaite's Wine is operated by Direct Wines Limited ("Direct Wines"), a private company registered in England and Wales with company number 01095091. Our registered office is:
One Waterside Drive
Arlington Business Park
If you have any questions about how we look after your personal data, you can contact us:
- In writing, at the address above. Please mark your letter for the attention of the Data Protection Officer
- By email to this address: firstname.lastname@example.org
- By telephone on 03330 148 168
You can manage your marketing preferences (whether we can mail you catalogues, call you on the phone, email you or share your personal data with third parties) by contacting us as above or through the preference centre in your online account - available here. We will update your preferences as soon as we can but please note that as catalogues are printed in advance, it may take up to 8 weeks for the process to be completed and for emails it may take up to 2 weeks.
How do we collect your personal data?
We collect your personal data in two main ways:
- When you give it to us directly
When you create a customer account, visit our website, communicate with us or purchase our products or services, you may choose to give us certain information. For example, when you give us your name and address, tell us about your wine preferences or when clicking on active buttons such our 'Place Order & Pay'.
- When our systems collect information or personal data as you use our website or app, or websites or apps that are connected to our website
Whenever you use a website, app or other internet service, information gets recorded automatically by the IT systems used to operate that website, app or service. The most common type of information collected is in the form of cookies (small text files sent by your computer each time you visit our website) but can also include personal data transferred by the electronic device you use to access our website and its settings. The manufacturer of your device, or the provider of the operating system, will have details about what information your device shares with us.
What categories of personal data do we collect?
We may collect the following information about you:
- Your name, date of birth and contact details
This can include your postal, billing and delivery addresses (which would include the addresses of any family or friends you choose to send wine to); your telephone number(s), including, if you provide it, your mobile number; and your email address
- Purchases and orders made by you
- Your payment card details (which we encrypt) when you purchase our products or services
- When you set up an account with us, your password (which we encrypt) and your marketing preferences
- Your wine preferences, favourites, ratings and reviews
- Your on-line browsing history on our website
- Your correspondence with us
Personal data we will process to fulfil your orders and to comply with the law
We will need to process some of your personal data to fulfil any orders you place and to comply with the law. For example:
- We will share your (or your recipient's) name, address and, where applicable, telephone number with our carriers.
- We will share your payment details with our bank or clearing house so that we can process payment for your order
- We will share your name, address and telephone numbers with an external provider to verify your age when you first purchase from us. This is because we are required by law to ensure that we sell products containing alcohol only to people aged 18 or over
- Occasionally with the police, or our trade body, for the purposes of preventing and investigating fraud
Legal basis for collecting and processing your data
The law on data protection sets out a number of lawful bases for which a company may collect and process your personal data. Only 4 of these are relevant to us.
- Personal data is processed on the basis of our legitimate interests
- Personal data is processed on the basis of a contractual obligation
- Personal data is processed on the basis of legal compliance
- Personal data is processed on the basis of a person's consent
"Legitimate Interests" means the interests of our company in conducting and managing our business to enable us to give you the best products and services, and the best and most secure experience.
For example, we have an interest in marketing our products and services to you, and making sure our marketing is relevant for you. Therefore, we may process your information to send you marketing that is tailored to your interests.
It can also apply to processing that is in your interests as well. For example, we may process your information to protect you against fraud when transacting on our website, and to ensure our websites and systems are secure.
When we process your personal information for our legitimate interests, we make sure to consider and balance any potential impact on you (both positive and negative), and your rights under data protection laws. Our legitimate business interests do not automatically override your interests - we will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
Where we rely on our legitimate interests to send you marketing communications, we shall tell you when you become a customer how we would like to market our products and services to you, and offer you a means of opting out of those communications. You can opt out of our marketing communications at any time through the preference centre in your online account – available here – or by contacting us on 03330 148 168 or email@example.com.
In addition to sending you marketing communications, we rely on our legitimate interests to process your personal data so that we can:
- Improve our existing wine range, associated products and services, and develop new ones
- Provide you with a quality customer service experience
- Protect you, our employees and our business
- Understand your likes and dislikes, what wines you want to hear about and how best to contact you to inform you about them
- Manage insurance claims made by our customers
- Carry out market research. We use a specialist third party market research company to assist with this research
- Taking legal action against any party in breach of its obligations to Direct Wines, and handling any legal claims or regulatory enforcement actions taken against Direct Wines
- Handling customer contacts, queries, complaints and disputes
- Fulfilling our duties to our customers, colleagues, shareholders and other stakeholders
In specific situations, we collect and process your data to comply with our contractual obligations. For example, if you order an item from us we collect your address details, phone number and email and pass these to our couriers to deliver your purchase.
If the law requires us to we may need to collect and process your data. For example, we pass on your details to verify your age to ensure that we only sell products containing alcohol to those aged 18 or over. We may disclose the personal information that you provide to a credit reference or fraud prevention agency which may keep a record of that information. This is done only to confirm your identity. A credit card check is not performed, and your credit rating will be unaffected.
We can collect and process your data with your consent. For example, when you tick a box to confirm that you are happy for us to share your data with third parties for marketing purposes.
How and why do we use your personal data and on what lawful basis?
We use your personal data:
- On the basis of our contractual obligation to send you the wines and other products and services you have purchased; to manage any accounts you have registered with us so that (i) we can provide you with products and services; (ii) you can place orders; and (iii) we can fulfil those orders and communicate with you about them.
- On the basis of our legitimate interests to improve the range of wines, offers and associated products we offer you and to help identify new products and services in the future to present you with personalised offers on our website, through social media channels such as Facebook and Instagram and by placing banner advertisements on third party websites; to personalise the offers you receive from us – the wines you love, unique events, and special offers and promotions; to allow you to post links to our products on social media; to carry out research to better understand your views on our products and services and to allow you to continue enjoying our award winning customer service.
- On the basis of our legal compliance to comply with the law (for example, to ensure that we only sell products containing alcohol to those aged 18 or over); to detect and prevent fraud and other illegal activities (and to assist regulators, trade bodies and law enforcement agencies in relation to the same) to verify your identity and your age;
When do we share your personal data?
So that we can provide you with our products and services, we have to share some of your personal data with certain third parties.
When we share your personal data, we make sure that it remains secure:
- We conduct a data security review of third parties we share your personal data with to ensure that they will keep your personal data secure and confidential to the standards you and we would expect
- Every external company we work with is required to have a contract with us which clearly describes our expectations about the way in which they keep your personal data secure, the purposes for which they can use your personal data and which holds them fully responsible for meeting those expectations
- We will only send to third parties the personal data that is necessary for the purposes it is required for.
We share your data as follows:
With core service providers to enable our business to function
We rely on a set of external companies to provide us with services that enable our business to run properly. Our core service providers include the courier companies we use to deliver our products to you; banks and clearing houses to process your payments; companies we use to carry out fraud protection and age verification checks; IT services providers; companies to help us with our marketing; and partners through which we provide our concession shops.
With other partners when we have your consent to do so
We work with a number of other third party companies to provide value to our business and to you. These companies include our marketing partners and social media partners (for instance you can publish a link on Facebook or Twitter to any wines of ours that you have enjoyed).
We will only partner with a company that meets our own high standards and that we think is a good fit for our business and our customers. Each of these third parties is required by the terms of the contract we have agreed with them to use your personal data only as we instruct it and to ensure that your personal data is secure.
We may also on occasions share your data with trusted retail partners either directly or through alliances operated by third parties. The companies we share your data with directly and the retailers participating in these alliances are active in the clothing, collectables, food & wine, gardening, gadgets & entertainment, health & beauty, household goods, and home interiors categories.
These alliances work by each trusted retailer sharing information on what their customers buy. This information is analysed to help the retailers understand consumers' wider buying patterns. As a result, the retailers can tailor their communications, sending suitable offers that should be of interest, based on what they like to buy.
If you would rather not receive marketing offers from third party companies you can withdraw your permission whenever you want through the preference centre in your online account – available here or by contacting us on 03330 148 168 or firstname.lastname@example.org.
With regulators and law enforcement agencies when required to do so by law
We are required to co-operate with regulators (like the Information Commissioner's Office or HMRC) and law enforcement agencies (like the police or the Serious Fraud Office) in every country we operate in. Although it does not happen often, regulators and law enforcement agencies can require us to share information with them as part of an investigation; this may include your personal data. We would have to disclose your personal data where we believe that disclosure is reasonably necessary to comply with the regulator or crime enforcement agency's demand.
When we think it is reasonably necessary to protect you or us
Occasionally businesses are subject to attempted criminal activities; this can affect both us and you. We will take all reasonable steps to protect you and our business but sometimes we may need to share your personal data where we think it is reasonably necessary to:
- Detect, monitor, investigate or prevent any suspected illegal activities, fraud or security issues
- Enforce our terms and conditions and to protect your and our rights and property
- Investigate and defend any third party claims or allegations
As part of a business sale or purchase, merger or reorganisation
From time to time we may look to purchase another business or sell or re-organise parts of our business to ensure that we remain in strong shape. Sometimes these types of corporate transactions involve the transfer of your personal data solely for the purposes of assessing the transaction. In the event that we sell or buy any business or assets, personal data which we hold about you may be one of the transferred assets.
In aggregated format
Strictly speaking this is not personal data, but on occasions we will use data from which you cannot be personally identified but which does include information that relates to you (such as your purchase history). This data is combined with data from other customers to provide general trends on customers preferences, ratings and reviews and general buying habits.
When do we send your personal data outside the European Economic Area and why does it matter?
From time to time we may use service providers outside the European Economic Area ("EEA"), in particular for the provision of IT services and as a result we may transfer your data to suppliers in countries such as Australia, the US and India.
If we do share your personal data with service providers outside the EEA we will ensure reasonable safeguards are put in place to protect your personal data. Our standard practice is to use ‘standard data protection clauses’ which have been provided by the European Commission for such transfers. Those clauses can be accessed here.
How long do we hold your personal data for?
We will not keep your personal data for longer than is necessary for the purposes described in this policy.
As a guide:
- we will keep personal data while your account is active
- Currently we retain data for 6 years from date of last purchase with us, but we may keep certain categories of personal data after your account is closed in order to meet any legal or regulatory requirements, or to resolve a legal dispute.
- and, because of this, we may keep different types of personal data for different lengths of time (for instance, we may need to keep certain personal data relating to your purchases in order to comply with HMRC's VAT reporting requirements)
You have a number of rights under data protection laws; these are summarised below.
You can access the personal data we hold on you by contacting us 03330 148 168 or email@example.com. To process your request, we will ask you to send us two forms of proof of identity so that we can be sure we are releasing your personal data to the right person.
We will process your request within one month or, if the request is particularly complex, two months. We can provide you with a copy of your personal data in electronic format or hard copy.
If we consider the frequency of your requests is unreasonable, we may refuse to comply with your request. In those circumstances, we would notify you of your right to complain to the Information Commissioner's Office.
- the right to rectification
We welcome feedback from you to ensure our records are as accurate and up-to-date as possible. If you think that the information we hold about you is inaccurate or incomplete please ask us to correct it by contacting us on 03330 148 168 or firstname.lastname@example.org or by updating your details at any time through the My Details section in your online account. We will process your request as soon as we receive it or within one month of receipt at the latest.
You can ask us to delete your personal data; however, this is not an absolute right. We can refuse to erase personal data which we need to keep (i) to comply with a legal obligation (for instance, we are required by HMRC to keep certain personal data for up to 6 years for VAT reporting purposes); and (ii) in relation to the exercise or defence of any legal claims.
When you ask us to delete your personal data, we assume that you do not want to hear from us again. To ensure that we do not send you any special offers in the future (for example, if we purchased your details from a third party list), we will retain just enough of your personal data solely for suppression purposes.
Other than as described above, we will always comply with your request and do so promptly. We would also notify any third parties with whom we have shared your personal data (for instance, our carriers for the purposes of delivering wine to you) about your request so that they could also comply.
Some customers would still like to order our products but do not want to receive any marketing communications from us. This is not a problem as you can simply update your marketing preferences by contacting us on 03330 148 168 or email@example.com or through the preference centre in your online account – available here.
- the right to transfer your personal data (known as data portability)
You have the right to move, copy or transfer your personal data from one organisation to another. We hold little information that would be much use to another wine merchant but if you do wish to transfer your personal data we would be happy to help.
If you ask for a data transfer, we will give you a copy of your personal data in a structured, commonly used and machine-readable form (for instance, in a CSV file format). We can provide the personal data to you directly or, if you request, to another organisation.
Please note that we are not required to adopt processing systems that are compatible with another organisation, so it may be that the recipient organisation cannot automatically use the personal data we provide.
When making a transfer request, it would be helpful if you can identify exactly what personal data you wish us to transfer.
We will comply with your request within one month or, if the request is complex or there are a number of requests from you, within two months.
If you would like us to stop processing your personal data for marketing purposes simply let us know by contacting us on 03330 148 168 or firstname.lastname@example.org or through the preference centre in your online account – available here.
We put a lot of effort into personalising your experience with us to ensure that the offers we send you are interesting, relevant and timely. To do this we look at your previous purchases plus any wine preferences, ratings, reviews and favourites you may have indicated to build a profile of what you are most likely to want to buy. This is known as 'profiling'.
If you don't want us to carry out any profiling using your personal data please let us know by contacting us on 03330 148 168 or email@example.com. However, please be aware that if you ask us to stop profiling your personal data you will stop receiving personalised offers on the wines you enjoy the most.
Data Protection Officer
We have appointed a Data Protection Officer. If you have any questions about how we use your personal data that are not answered here, or if you want to exercise any of your rights described above please contact our data protection team by contacting us on 03330 148 168 or firstname.lastname@example.org or write to Data Protection Officer, Laithwaites Wines, One Waterside Drive, Arlington Business Park, Theale, Reading, RG7 4SW.
Contacting the Regulator
If you feel that your data has not been handled correctly, or you are unhappy with our response you have the right to lodge a complaint with the Information Commissioner's Office.
We may update this policy from time to time to take account of any new business activity or to reflect any changes in law or best practice in relation to data protection. We will notify you if we do so.
This policy was last updated on 23 May 2018.