Privacy notice

We are International Exhibition Co-operative Wine Society Limited ("The Wine Society"), a mutual society based at Gunnels Wood Road, Stevenage, Hertfordshire SG1 2BT (registered number IP01824R).

For the purposes of the Data Protection Act 2018, the UK General Data Protection Regulation (UK GDPR), and the EU General Data Protection Regulation [together Data Protection Legislation] we are the 'controller' of the personal data that we collect and hold about you, which means that we make decisions as to how and why we use your data within our society.

We are registered with the Information Commissioner’s Office registration number Z5381197

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

If you have any questions about your privacy, your rights or our use of your personal data, please contact us.

You are not required (by law or by any contract with us) to provide personal information to us via our website. We will only require you to provide personal information to us where it is necessary for us to provide you with a service at your request, such as when you join us as a member.

Membership of The Wine Society

In order to join us and become a member of The Wine Society, you will need to provide us with personal information, such as:

• Your identity and contact details, including your full name, date of birth, telephone number, email and postal address.
• Photo ID such as your passport, driving licence or residence card (where required) (we have a legal requirement to confirm that you are over 18).
• Payment information such as your credit/debit card details, bank or other payment account details and/or direct debit information.

If you receive a gift membership or gift wines from a friend, colleague or family member then we may obtain certain information about you (such as your name and contact details) from them, instead of directly from you. We will also record the details of the person giving the gift.

As a member you will have access to our great range of wines and events and promotions, as well as our other services such as wine storage in our Members' Reserves. Throughout your membership we will collect other personal information from you, such as:

• Details of your orders and purchases (including wines, event tickets and other services such as wine storage).
• Further payment information that you provide to us to take payments and fulfil your orders.
• Information about your shopping habits with us, your preferences and your attendance at any of our tastings and events.
• Your comments and thoughts on or review of our products.
• Any other information that you provide to us in order to help us enhance your experience as a member (for example, you may provide us with details of your property to help with deliveries).

Other information that we collect and hold about you (as set out in this notice) may be combined with the information above to help us gain a better overall understanding of how you interact with us throughout your membership.

Where we anonymise your personal information (so that it can no longer be associated with you) for analytical or statistical purposes, we may use this information indefinitely without further notice to you.

Our news, competitions and surveys

Members can sign-up to our email and/or print marketing programmes to receive Society news, content, promotions and wine releases from The Wine Society.  Members are also able to access information from our social channels and community.

Non-members can also sign up to be included in a selection of Society emails, to enjoy some of our content, hear more about our wines and the benefits of membership.  If, as a non-member, you subscribe to our non-member email list (whether through our website, social media adverts or otherwise), you will need to provide us with your name and contact details (specifically, your email address) as well as any preferences regarding the information we send you and how we contact you.

Competitions are only open to members. If you enter any of the competitions that we hold, including via our website, Community forum and our social media pages, you will need to provide us, should we not already hold it, with information about your identity (such as your full name and relevant online profiles like your Community forum username or social media accounts), your contact details (including your postal address for any deliveries) and the details of your entry.

If you choose to complete any of the surveys, including providing reviews of any of our products or services, or questionnaires that we run, we may record your name and contact details as well as the answers or feedback that you provide.

If you choose to leave a comment or review about our products in a public forum some personal information may be displayed.

In some cases we will anonymise this information so that we only keep aggregated data and statistics.

Data we collect through our website, social media and marketing

We may collect other personal information about you whenever you visit our website or interact with us on social media (inc. The Wine Society’s Community forum) or when we send you promotional emails. This information may include:

• Your personal details including information relating to your member account on our website (email address, share number and password) and your Community forum account (username and password). We store passwords in an encrypted format for your security.
• Any information you add to your profile on our website or Community forum, as well as any posts or contributions that you submit or other content that you may upload. We gather data when you participate in the forum by reading, writing, and evaluating the content shared.
• Information about the devices and software you use to access our online services, such as the make, model, operating system and any unique identifiers of your device, and the type and version of your browser, to ensure that your on-line experience with us is as good as we can provide.
• Your IP address (which may reveal your location) and other identifiers relating to your device or browsing session.
• Your browsing behaviour on our website, such as the content and pages you view, links and adverts that you click and the sites or pages that referred you to our site (including where you interact with our adverts on other sites).
• Information about you when you comment on or review our products [and customer services].
• Information about your interaction with us on social media, such as views and impressions of our social media accounts, pages and content and any posts or content that you tag us in or post on our pages, as well as where you engage with our adverts on social media (for example, to subscribe to our email newsletter).
• Information about your interaction with our promotional emails, such as the date and time that you open them, which links or content you click and any products that you view or purchase after following the links on our emails, which we collect using tracking pixels and unique URL links in these emails.

Where you are a member and you have logged in to your account on our website or your Community forum profile, we may combine this information with the other information that you provide to us in relation to your membership.

We verify and authenticate all registrations for The Society’s Community by requiring all registrations and log-in to take place through your existing credentials on thewinesociety.com.

Applying for a job with us

If you apply for a role at The Wine Society, we may collect information about your identity and your contact details, as well as your CV and information, your previous work experience and qualifications, from you or from third party recruitment agencies. We will keep our own interview records and we may also collect information about you from psychometric and other tests that we ask you to complete as part of the recruitment process.

Our suppliers and business contacts

We hold personal information about our suppliers and other business contacts, including names, contact details and payment details and information about your engagement with The Wine Society.

We may collect personal information about you from other sources, including from third party organisations and publicly available registers.

Member insights and purchased marketing lists

We may collect additional information about our members from third party organisations which include analytics providers, providers of consumer reports, advertising networks, search information providers, providers of technical, payment and delivery services, providers of social media platforms (such as Facebook, Twitter and Instagram) (for example where you share our content through social media, for example by liking us on Facebook, following or commenting about us on Twitter and Instagram, to help us better understand our members through profiling and to enable us to personalise our services, advertisements and promotional materials.

Where it is appropriate and only when in compliance with data protection legislation we may also purchase information about consumers (including non-members) from third party organisations who provide us with consumer reports to help us target relevant audiences with our advertisements and promotions.

This information may include names and contact details, demographic information (such as age group, location/region and social status), credit details, information about behaviours and preferences and, where appropriate, records of any consents obtained by third parties that we may seek to rely on.

Verifying your identity and age

We may collect additional information from third party sources such as GBG (ID3 Global), and from publicly available resources such as the electoral roll, in order to verify your identity and age (such as when you become a member or wish to purchase any alcoholic products, and so that we can ensure that you are old enough to be sent promotional materials relating to alcoholic products).

Our website is not intended for children and we do not knowingly collect data relating to children.

Information from other sources

We may also collect information about you from other sources. For example:

• Publicly available information from sources such as Companies House.
• Publicly available information from the electoral roll.
• Information you have shared publicly, including on social media.
• Information from other third-party databases, such as credit reference agencies.
• New members who you have referred who have entered your data when joining.

Applying for a job with us

If you apply for a role at The Wine Society, we may collect information about your identity and your contact details, as well as your CV and information, your previous work experience and qualifications, from you or from third party recruitment agencies. We use a third party recruitment platform provided by Iris Software, full details regarding how they manage and process data on our behalf can be found by following the ‘Register’ link at the top of our Vacancy page (here).

We will keep our own interview records and we may also collect information about you from psychometric and other tests that we ask you to complete as part of the recruitment process.

We use personal information about you for a number of different purposes, which are explained in more detail below. In most cases, we will need to use your information for these purposes in order to fulfil our obligations under a contract with you, to comply with our legal obligations, or in pursuit of our (or third parties') legitimate interests where these are not overridden by your rights and interests.

Member Services

We need to use your personal information in order to manage and administer your membership generally. We use your information in this context to:

• Administer your membership, including verifying your age and identity, issuing your share and maintaining your details on our record of members.
• Answer your queries and correspond with you about matters relating to your membership.
• Take and fulfil your orders, including processing payments and refunds and arranging deliveries.
• Allow you to transfer wines to and access your Members' Reserves
• Enable you to purchase tickets for, and take part in, our tastings and other events.
• Provide you with information about your membership and shareholding (such as notice of general meetings and other important events).
• Provide you with information and news about The Wine Society, our performance and our services and products.
• Improve and develop the products and services that we offer, and the ways in which we communicate with you, to provide the best member experience that we can.

It is necessary for us to use your information in these ways in order to perform our obligations under our contracts with you, to comply with our legal obligations (such as to verify your age and identity and to maintain a record of our members) and to pursue our legitimate interests in monitoring, developing and improving our business and the services and experience that we offer.

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

If you choose not to share your personal information with us, or refuse certain contact permissions, we might not be able to provide some services you’ve asked for.

Promotional messages and marketing

We strive to provide you with choices regarding certain personal information uses, particularly around marketing and advertising.

We may use your personal information to send you news and updates from The Wine Society and information about our products and services including offers, promotions and new products. Depending on how you interact with us, we may contact you by email, text message, telephone, post or other methods, including on social media.

We may use data obtained from third parties (such as providers of consumer profiling) for postal marketing, online marketing and advertising, and we use profiling to help us identify relevant audiences (see further below).

We may contact you in relation to any similar products or services we have previously supplied.  We have a legitimate interest in using direct marketing to reach out to existing and prospective members to help promote and grow our business and improve our members’ experiences, and we need to use your personal information to do this. In some cases, we may seek your consent to contact you for marketing purposes.

If we're contacting you by post or you are an existing member, we may not require your consent, but you can always tell us to stop using your information for marketing purposes if you wish.

If you are a member, you can change your contact and marketing preferences at any time by using the preference centre in your account on our website.

If you wish to stop receiving email marketing from us, you can also use the ‘unsubscribe’ links provided in the emails we send to you to. Otherwise, if you wish to withdraw your consent or change your contact or marketing preferences, please contact us.

We use information about your interactions with our promotional emails, such as when you open them, which links or content you click on, and any products that you view or purchase after following the links in our emails, to help us to monitor and improve the effectiveness of our marketing campaigns. We have a legitimate interest in doing this, as it enables us to enhance the service that we provide by better understanding the information you would like to receive from us.

Profiling

Profiling is the use of personal information to evaluate certain aspects relating to a person, such as their preferences, interests or behaviour.

We use the personal information that we hold to carry out profiling on our members and other individuals for our internal business purposes and marketing and advertising campaigns. The information that we use in this context may include:

• Membership, order and purchase records
• Feedback from surveys and questionnaires
• Your comments and reviews on our products
• Information about lifestyle, interests, preferences and behaviour
• Demographic information such as age, location and financial or social status
• Information about website usage and interaction with our advertising campaigns
• Information obtained from third parties.

By analysing this information, it can help us to develop and improve our internal processes so that we can provide the best experience for our members.

This also allows us to tailor the information that we send to you and personalise your experience with The Wine Society by identifying the news, products and services that we think may be of most interest to you and avoiding sending you unwanted communications.

We have a legitimate interest in carrying out profiling in this way so that we can better understand our existing and prospective members, aim to build and improve our relationships with them and improve our service.

Automated decision-making

Some decisions that we make based on your personal information, such as which communications we choose to send to you, are made by our own analysts here at The Wine Society.

We may engage third parties to carry out profiling and automated decision-making on our behalf, including by combining the information we hold with their own databases, and we may use automated decision-making to help tailor our online advertising services. However, we will not rely on automated decision-making for any decisions that may have a significant impact on you or your experience with us. You will be notified if we a solely automated decision which produces a legal effect or significantly affects you.

Online advertising

We use personal information in order to display relevant adverts to you online.

We use retargeting to personalise your experience with us on social media (including Facebook and Pinterest) by showing you relevant adverts. When you visit our website or social media pages, a small script tells the advertising service (such as our Facebook ads account) about the content that you've viewed or clicked, so that we can show you similar content whilst you're browsing on the same device.

We also use list-based retargeting services such as Facebook Audiences to find relevant audiences for our adverts, which means that we provide a list of our contacts to the provider (e.g. Facebook) so that they can display relevant adverts to their own users who are on the list. The lists that we use for these purposes may be generated through profiling, as explained above.

We have a legitimate interest in using these advertising services as it allows us to improve our members' experience with us online and to increase the effectiveness of our advertising campaigns. You may also disable the use of cookies for the purposes of online advertising, using the cookie consent tool on our website.

Cookies

A cookie is a piece of data stored locally on your computer containing information about your activities on the Internet.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

You may also disable the use of cookies for the purposes of online advertising at any time on our website, using the Cookies Settings

Improving our website and promotions

We use data that we collect via our website (such as usage and performance data, IP addresses, browsing behaviour and device and browser information) to monitor and improve the performance, accessibility and user experience of our website and to measure and improve the effectiveness of our online adverts.

We use third party analytics providers to help us collect and analyse information about use of our website, and we may combine this information with other personal information that we hold for these purposes.

How else do we use your personal information?

We may use your personal information in other contexts, for specific purposes. For example:

• We use information about our suppliers and other business contacts to fulfil our contracts and to maintain our professional relationships.
• If you apply for a job at The Wine Society, we will use the information that you provide during the recruitment process to review, assess and progress your application, but not for any other purpose.
• We will use your personal information to respond to any communications that you send us, and to inform you of any important updates (including updates to this notice).
• We may use your information where it is necessary for us to do so in order to meet our legal obligations or to detect and prevent fraud, money-laundering and other crimes.
• We may use your information where it is necessary to protect your interests, or the interests of others, in accordance with our legal obligations. This may include in the event of criminality such as identity theft, piracy or fraud.

We will only use your personal information for the purposes for which we collected it, as set out in this notice, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose for the collection of the data.

Sharing your information within our business

We will share the information that you provide to us with our staff so that we can operate our business and provide our products and services, but access to different types of information is limited to those staff who need to access that information for their roles.

Sharing your information with third parties

We sometimes share your personal data with trusted third parties. We share your personal information with selected third parties to help us provide you with our products and services, and to assist us in carrying out various functions of our business.

We only provide third parties with the information they need to know to perform their specific services. We work closely with all the third parties to ensure that your personal data is secure and protected at all times.

We have listed some of the reasons we share personal data with third parties below, but this list is not exhaustive and we may change our third party providers from time to time.

Member Services

• We share information with GBG Plc to verify your age and identity.
• We share information as necessary to perform our obligations under contracts with you, such as with carriers for deliveries, and with our bank and payment service providers to make and receive payments.
• We may share information with IT service providers and communications providers for phone, email and other services, and we store physical and cloud backups of our servers and databases with Iron Mountain and iLand.
• We share information with our email delivery service, to automate the deployment of important transactional emails (such as when we email you to confirm your order).

Website and Community

• We share information with our web hosts (Optimizely) to host the website and related applications and infrastructure.
• We may share information with Google, Alterian and similar service providers for analytics purposes.

Marketing and advertising

• Our marketing database is hosted on Alterian (customer experience software) and we may share information with marketing agencies to help us run our campaigns.
• We share information with third parties to assist with profiling and to help us find the right audience for our ads.
• We share information with Facebook, Pinterest and other advertising services to help display relevant adverts to you.

Other third parties

• We may share information with our auditors, insurers, brokers, legal advisers and banks, where it is necessary to do so to enforce our terms of use, terms and conditions of sale or other contractual rights.
• We would share information where required by the law, or in order to comply with judicial proceedings, court orders or legal or regulatory proceedings.
• We would share information where necessary to protect the safety of our employees, our property or the public, or where necessary for the prevention or detection of crime.
• We may share information where proportionate as part of, and in the event of, a merger, business or asset sale.

We may otherwise share your personal information to the extent that we reasonably need to for our legitimate interests or to provide our products and services. We always seek to ensure that your personal data is protected and we choose carefully who we share it with.

We will never disclose or sell your personal data to others for their marketing purposes.

Sharing your information outside the UK

Sometimes we will need to share your personal data with third parties and suppliers outside the UK such as Europe [or the USA]. Where personal data is shared outside the UK, it may not be afforded the same protection and you may not have available the same rights.

We will only share your data with parties outside the UK where there are appropriate safeguards in place to protect your data and ensure that you have the same rights as you would in the UK. This may be on the basis of an "adequacy decision" adopted by the UK Government, or through robust contractual obligations with the receiving party.

Any transfer of your personal data will follow applicable laws and we will follow the guiding principles of this Privacy Policy.

We will only keep personal information about you for as long as necessary for the purpose or purposes for which we collected it.

Where we are providing you with any service (including our online services), we will continue to hold your data for at least as long as we provide that service to you.

We have different retention periods for different types of data, and after these periods we will delete or destroy the information unless we have a good reason not to.

We keep information about members, including your identity and contact details, indefinitely as we are required to maintain a permanent record of all of our members (as shareholders).

If you apply for a job with us and you are unsuccessful, we will keep your information for up to 6 months unless you ask us to keep it for longer (up to 12 months) to be considered for future vacancies.

We take the security of your personal data seriously and put in place appropriate measures to ensure that it is protected from unauthorised access or disclosure.

We implement information security policies and carry out training with staff to reduce the risk of security breaches, and we operate on a 'principle of least privilege' basis so that staff only have access to the information they need. We impose contractual obligations on the selected third parties that we work with to ensure that your data is protected when it is shared.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, including our staff.

We try to ensure that all information you provide to us via the website is transferred securely. You should always check for the padlock symbol in your browser and "https" in the URL before submitting data through the website.

Most of the information you provide to us is stored on our own servers or with third party secure servers in the UK or EEA.

We have procedures in place to prevent or reduce the risk of, and respond to, data security breaches, and we will notify you and/or the relevant authority (such as the ICO) where appropriate if this happens.

You have a number of rights in respect of your personal data. If you would like any further information or to exercise any of your rights, please contact us. In most cases, we will not charge you any fee if you wish to exercise any of these rights.

The right to be informed

We have a legal obligation to provide you with concise, transparent, intelligible and easily accessible information about your personal information and our use of it. We have written this notice to comply with this right, but please contact us if you require further information.

The right to access your personal data

You have the right to ask us to confirm whether or not we hold any of your personal data. If we do, you have the right to access a copy of your data, as well as information about how, and why, we use it. In order to prevent your data being disclosed to someone who is not authorised to access it, we may have to verify your identity before we provide you with a copy of the data that we hold.

The right to correct any inaccurate or incomplete personal data

If the information that we hold about you is inaccurate or incomplete, you have the right to require us to correct that data (or complete it by supplementing it with other information).

The right to be forgotten

You have the right to require us to delete or destroy your personal data in the following circumstances:

• The information is no longer needed for the purposes we collected it for.
• Where we rely on your consent, and you withdraw that consent.
• You object to us using your information for marketing purposes, or for our legitimate interests, and we have no overriding reason to keep using it.
• We have used your information unlawfully.
• We are required by law to delete your information.

If these situations apply, you may contact us to request that we erase your data from our systems.

The right to have your data transferred to you or a third party in a common format

Where your personal data is processed by automated means, you may have the right to obtain a copy of your personal data in a structured, commonly used and machine-readable format, and to ask us to transfer this data to another organisation in a safe and secure way.

You have the right to object to direct marketing

You can ask us at any time to stop using your information for direct marketing purposes, even if we do not rely on your consent to do this. If you are a member, you may change your contact and marketing preferences using the preference centre in your account on our website. Otherwise, you may exercise this right by following the instructions in any of the emails that we send to you, or by contacting us.

The right to object to us using your information for our own legitimate interests

Sometimes, we use your personal information to achieve goals that will help our business – these are our legitimate interests, and they are explained in more detail in this notice.

We aim to always ensure that your rights and information are properly protected. If you believe that the way we are using your data is not justified due to its impact on you or your rights, you have the right to object to our use of your data in these ways. If you do object to this, unless we have a compelling reason to continue we will stop using your personal data for these purposes.

You have the right to restrict how we use your personal data

You have the right to ask us to stop using your personal data in any way other than simply keeping a copy of it. This right is available where:

• You have informed us that the information we hold about you is inaccurate, and we have not yet been able to verify or update this.
• You have objected to us using your information for our own legitimate interests and we are in the process of considering your objection.
• We have used your information unlawfully, but you do not want us to delete it.
• We no longer need to use the information, but you need it for a legal claim.

You have rights related to automated-decision making and profiling

You have the right not to be subject to decisions made based on automated decision-making, including profiling, which will have a legal effect upon you or otherwise significantly affect you. We do not currently use any automated decision-making or undertake any profiling of our customers or other individuals.

Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.

If you wish to make a complaint about our collection or use of your personal data, please contact us in the first instance so that we may seek to resolve your complaint.

You have the right to lodge a complaint with the Information Commissioner's Office (ICO), the statutory body which oversees data protection law in the UK. Please visit the ICO website if you wish to lodge a complaint with the ICO. If you are based in another European Union member state, you may instead lodge a complaint with the supervisory authority in your country.

If you wish to speak to us regarding your privacy, or our use of your personal data, please contact us using the following details:

Email: Legal@thewinesociety.com
 
Phone: 01438 741177
 
Post:
The Company Secretary
The Wine Society
Gunnels Wood Road
Stevenage
Hertfordshire
SG1 2BT

We have appointed EU Business Partners as our representatives in the EU for the purposes of Article 27 of the GDPR. If you are based in the EU, you may contact our EU representative, as well as us directly, with any query that you may have in relation to your personal data. The contact details of our EU representative are as follows:

Flor McCarthy
EU Business Partners
10 Ashe Street
Clonakilty
Co. Cork
P85 E403
Ireland
Email: info@eubusinesspartners.com