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Privacy

This notice explains what personal data (information) we hold about you, how we collect it, and how we use and may share information about you during the time we provide our products and services to you and after we cease to provide such products and services. We are required to notify you of this information under data protection legislation. Please ensure that you read this notice (sometimes referred to as a ‘privacy notice’) and any other similar notice we may provide to you from time to time when we collect or process personal information about you.

WHO COLLECTS THE INFORMATION?

Richard Dawes Fine Wine Ltd trading under the name of ‘MARLO’ is the controller and responsible for your personal data (collectively referred to as the Company, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us in writing, by email or telephone using the details shown in paragraph 10 below.

We will comply with the data protection principles when gathering and using personal information.

ABOUT THE INFORMATION WE COLLECT AND HOLD

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together in the table set out in the Schedule.

We seek to ensure that our information collection and processing is always proportionate. We will notify you of any changes to information we collect or to the purposes for which we collect and process it.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

DISCLOSURES OF YOUR PERSONAL DATA

As outlined in the table in theSchedule, we may need to share your personal data with third parties, examples of which are listed below:

  • Internal third parties, being other group companies acting as joint controllers or processors.
  • External third parties as follows:
    • Service providers who provide IT and system administration services.
    • Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
    • HM Revenue & Customs, regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

INTERNATIONAL TRANSFERS OF INFORMATION

We do not ordinarily transfer your personal data outside the European Economic Area (EEA).

However, if we do need to transfer your personal data out of the EEA, we will ensure that any such transfer is made securely and that there is adequate protection in place in order to protect your personal data, as required by the Data Protection Act 2018 and the provisions of Regulation (EU) 2016/679, including requiring the transferee to enter into model contractual clauses or (if US based) being a member of the Privacy Shield.

If we ever transfer your personal data outside the EEA you can ask us for a copy of relevant safeguards.

WHERE INFORMATION MAY BE HELD

Information may be held at our offices and [those of [our group companies, and] third party agencies, service providers, representatives and agents as described above.Information may be transferred internationally to other countries around the world, including countries that do not have data protection laws equivalent to those in the UK, for the reasons described above.

We have appropriate security measures in place to prevent personal information from being accidentally lost, or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

HOW LONG WE KEEP YOUR INFORMATION

We keep your information during and after your custom with us for no longer than is necessary for the purposes for which the personal information is processed, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.Further details on this are available in our Data Retention Policy which you can request from us by emailing hello@marlo.wine.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

YOUR RIGHTS TO CORRECT AND ACCESS YOUR INFORMATION AND TO ASK FOR IT TO BE ERASED
  • Your rights in connection with personal information
    • Under certain circumstances, by law you have the right to:
      • Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
      • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
      • Request erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
      • Object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal information for direct marketing purposes.
      • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
      • Request the transfer of your personal information to another party.
      • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact in writing, by email or telephone using the details shown in paragraph 10 below.
    • No fee usually required
      • You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
    • What we may need from you
      • We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure we take to ensure that personal information is not disclosed to any person who has no right to receive it.
CHANGES TO THE PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on 1st February 2020

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

CONTACTS &COMPLAINTS

If you have any questions about how we treat and protect your personal data and your privacy, if you have any comments, wish to seek to exercise any of your rights as outlined above or to complain, please contact Richard Dawes Fine Wine Ltd t/a ‘MARLO’, No.15 Calico Row, Plantation Wharf, London, SW11 3YHor by email to hello@marlo.winefor the attention of the Data Protection Officer.

We hope that we can resolve any query or concern you raise about our use of your information. If not, you may contact the Information Commissioner at ico.org.uk/concerns/ or telephone: 0303 123 1113 for further information about your rights and how to make a formal complaint.

Schedule

About the information we collect and hold

The information we collect How we collect the information Why we collect the information How we use and may share the information
Identity data including first name, maiden name, last name or similar identifier, marital status, title, date of birth, employment information and gender. From you

To enter into/perform our contract with you


Legitimate interest: to ensure that you are properly identified as a customer and that we are able to perform our obligations under our contract with you on an on-going basis

Where we need to comply with a legal or regulatory obligation

To enter into/perform our contract with you
Contact data, including addresses, email addresses and telephone numbers.

From you


From selected third parties such as data brokers or aggregators


From publicly available sources such as Companies House and the Electoral Register

To enter into/perform our contract with you

Legitimate interest: to ensure that you are properly identified as a customer and that we are able to perform our obligations under our contract with you on an on-going basis

To enter into/perform our contract with you
Financial data including bank account details, billing information, payment card details and credit history, information to enable us to undertake credit or other financial checks on you

From you

From selected third parties including credit reference agen

 

To enter into/perform our contract with you

Legitimate interest: to establish your ability to make payments to us under our contract with you, and to obtain such payments

To enter into/perform our contract with you

To establish your ability to make payments to us and to obtain such payments

Contract and transaction data including details about payments to and from you and other details of products and services you have purchased from us, contact history, purchase history, saved items

From you

Automatically from our information technology systems and our customer relationship management software

From providers of technical payment and delivery services

To enter into/perform our contract with you

Legitimate interest: to keep our records up to date

Legitimate interest: to monitor how customers use our products and services for the purposes of business management and planning and to identify whether any other products or services may be of interest to you To enter into/perform our contract with you

To keep our records up to date

For business management and planning

To identify future customer demand

Your family, friends and other contacts’ identity data including first name, maiden name, last name or similar identifier, marital status, title, date of birth and gender, and contact data, including addresses, email addresses From you

To enter into/perform our contract with you

Legitimate interest: To ensure we are able to comply with our obligations under our contract with you if we are unable to communicate with you directly provided that this does not affect your/theirinterests, rights and freedom

To enter into/perform our contract with you
Information involving feedback, questions and complaints received by us from you in relation to our products and services and your responses to surveys, competitions and promotions From you

To enter into/perform our contract with you

Legitimate interest: to maintain accurate records and to comply with legal, regulatory and corporate governance obligations and good practice


To perform our contract with you

To maintain accurate records and to comply with legal, regulatory and corporate governance obligations and good practice

Marketing and communications data, including your preferences in receiving marketing from us and our third parties and your communication preferences From you Legitimate interest: to keep our records up to date and to understand how you wish for us to communicate with you

To enter into/perform our contract with you

To keep our records up to date and to understand how you wish for us to communicate with you