Swirl Wine Group Ltd understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.swirlwinegroup.com, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
- Information About us
Our Site is operated by Swirl Wine Group Ltd, a Limited Company registered in England under company number 10483126.
1st Floor, Charles House , 148-149 Gt Charles Street, Birmingham, B3 3HT, United Kingdom
VAT number: 2384 81978.
Data Protection Officer: Sarah Abbott.
Email address: Sarah@swirlwinegroup.com
Telephone number: (0)20 3858 0837
- What Does This Policy Cover?
- What is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
- What Are My Rights?
Under the GDPR, you have the following rights, which we will always work to uphold:
b- The right to access the personal data we hold about you. Part 11 will tell you how to do this.
c- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 12 to find out more.
d- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we have. Please contact us using the details in Part 12 to find out more.
f- The right to restrict (i.e. prevent) the processing of your personal data.
g- The right to object to us using your personal data for a particular purpose or purposes.
h- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
i- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
j- For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 12.
k- Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
l- If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office.
- What Data Do You Collect?
Depending upon your use of our Site, we may collect some or all of the following personal and non-personal data:
- [Email address;]
- [Telephone number;]
- [Business name;]
- [Job title;]
- [Payment information;]
- [Information about your preferences and interests;]
- [Age – you must be over 18 to attend our events]
- [IP address];
- [Web browser type and version;]
- [Operating system;]
- [A list of URLs starting with a referring site, your activity on our Site, and the site you exit to;]
- How Do You Use My Personal Data?
Under the GDPR, we must always have a lawful basis for using personal data. This may be because the data is necessary for our performance of a contract with you, because you have consented to our use of your personal data, or because it is in our legitimate business interests to use it. Your personal data may be used for the following purposes:
- Supplying our services to you. Your personal details are required in order for us to enter into a contract with you.]
- Communicating with you. This may include responding to emails or calls from you.
- Supplying you with information by email or post that you have opted-in to (you may unsubscribe or opt-out at any time by emailing firstname.lastname@example.org)
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message or post, with information, news, and offers on our services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We do not use any automated systems for profiling.
- How Long Will You Keep My Personal Data?
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
- How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data in the EEA. This means that it will be fully protected under the GDPR.
- Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to one important exception.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may sometimes contract with the following third parties to supply certain products or services. These may include payment processing, delivery, and marketing. In some cases, those third parties may require access to some or all of your personal data that we hold.
If any of your personal data is required by a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.
- Can I Withhold Information?
You may access all areas of our Site without providing any personal data at all.
- How Can I Access My Personal Data?
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 12.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month. Normally, we aim to provide a complete response, including a copy of your personal data within that time.
- How Do I Contact You?
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Sarah Abbott)]:
Email address: email@example.com.
Telephone number: (0)20 3858 0837
Postal Address: 1st Floor, Charles House , 148-149 Gt Charles Street, Birmingham, B3 3HT, United Kingdom
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.