Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
Information About Us
We are the data controller for the purposes of the Data Protection Act 2018 (the Act), the EU General Data Protection Regulation (GDPR) and any other data protection legislation applicable in the UK from time to time.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details below:
Address: Rathfinny Wine Estate of Alfriston, East Sussex. BN26 5TU.
VAT number: 104756426.
Data Protection Officer: Jamie Everett
Email address: firstname.lastname@example.org
Telephone number: 01323 870022
This version was last updated on 12th August 2020. We reserve the right to amend this Policy from time to time and in the event that we buy or sell all or part of our business or assets, to disclose personal data held by us to the prospective seller or buyer of such business or assets.
What Does This Policy Cover?
This Policy applies to anybody who browses our webpages or who provides personal data via our shop portal https://shop.rathfinnyestate.com and website www.rathfinnyestate.com. It also applies to those who request communication via our website, orders products via our website, those who post material on our website, and to personal data processed in pursuit of our own marketing and business development efforts. We may also ask you for personal data when you report a problem on our Website.
This policy does not apply to the personal data of our Job Applicants, Employees, Agents and Contractors. The fair, lawful and secure processing of these types of data is governed by other company policies outside the scope of this Policy.
This website is not intended for children and we do not knowingly collect data relating to children.
Information We May Collect From You
We may collect and process the following data about you:
- Information you give us voluntarily. You may give us information about you by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. This includes information you provide when you register to use our website, search for a product, place an order on our website, enter a competition, promotion or survey and when you report a problem with our website. The information you give us may include your name, address, date of birth, e-mail address and phone number, financial and credit card information and other personal information.
- Information we collect about you. With regard to each of your visits to our website we may automatically collect the following information:
- technical information, including your IP address, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time);
- products you viewed or searched for; and
- page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
- Information we receive from other sources. We may receive information about you if you use any other websites we operate or any other services we provide. We may also work with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.
What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) 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 Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you as detailed below.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
- 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 hold.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- 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.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details above.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
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. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details above.
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. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):
Name, email address and post code: We will keep this data until we stop producing and sending newsletters or until you opt out.
Mailing lists: After registering subscribers will receive emails about the topics they expressed interest in or relevant related items. Any emails will include details on how to unsubscribe or edit their personal details. Users can choose to unsubscribe from Rathfinny emails at any time. They may do this immediately by clicking the ‘unsubscribe’ button at the bottom of emails or by contacting us with details. If users contact us then their removal from mailing lists may not be immediate.
We do our best to keep your data accurate and up to date, to the extent that you provide us with the information we need to do so. If your data changes (for example, if you have a new email address), then you are responsible for notifying us of those changes. Upon request, we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. We will retain your information for as long as your account is active or as long as needed to supply our products or services. We may also retain and use your information in order to comply with our legal obligations, resolve disputes, prevent abuse, and enforce our Terms and Conditions.
How and Where Do You Store or Transfer My Personal Data?
We will only store or transfer your personal data within the UK and European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, GDPR, and/or to equivalent standards by law.
Do You Share My Personal Data?
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
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 and services.
How Can I Control My Personal Data?
In addition to your rights under the Data Protection Legislation, set out above, when you submit personal data via our website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
Can I Withhold Information?
You may access our website without providing any personal data at all. However, to use all features and functions available on our website you may be required to submit or allow for the collection of certain data.
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 above.
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 14 calendar days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using our website, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies are used on our website for tailored advertising, marketing or analytics services. For more details, please refer to the table below. These Cookies are not integral to the functioning of our website and your use and experience of our website will not be impaired by refusing consent to them.
All Cookies used by and on our website are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop up at the top of the homepage requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our website may not function fully or as intended.
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access our website more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
You decide which cookies we use – We understand that not everyone wants to see targeted adverts or contribute to statistics on website use, so you can configure cookie settings in your web browser. You can find out more about how to do this at the following links:
You block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
For more information about cookies generally, visit allaboutcookies.org.
For further detailed information on our Cookies policy please contact us.
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.
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 Jamie Everett):
Email address: email@example.com.
Telephone number: +44 1323 870022.
Postal Address: Cellar Door, Rathfinny Wine Estate, Alfriston. East Sussex. BN26 5TU.