Please order as early as possible to guarantee Christmas delivery, and at the very latest before 14th December
Lay & Wheeler is committed to respecting and protecting our customers' privacy and treats it with the same respect as our wine selection. This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of such personal data. It captures personal data entered across all channels: through our website, or via our office.
We incorporate marketing preferences in your online account, which affect how we will process your personal data. By using the marketing preferences functionality, you can specify whether you would like to receive direct marketing communications and limit the use of your information. You can access your marketing preferences here.
Please read this policy carefully to understand our views and practices regarding your personal data and how we will treat it.
In this section we outline how we may process your personal data. All personal data we process falls into one or more of the following categories:
We may process your order data ("order data"). The order data may include your name, billing address, delivery address, phone number and email address. The order data will be processed for the purposes of storing your wine or delivering your wine orders to you. The legal basis for this processing is the performance of a contract between you and us.
We may process your date of birth (“date of birth data”). Your date of birth will be processed for the purposes of confirming you are 18 or over and therefore legally able to purchase alcohol. The legal basis for this processing is compliance with legal obligations, namely the Licensing Act 2003.
We may process your transaction data (“transaction data”). The transaction data may include information relating to your previous transactions, including purchases of goods or services and Cellar Circle, Fine Wine Discovery Club and cellarage payments. The transaction data may include your name, billing address, delivery address, telephone number, email address and purchase history. It may be processed for the purpose of supplying the purchased goods or services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us.
We may process financial information (“financial data”) you share with us. The financial data may include your encrypted card details, name and billing address. The financial data may be processed for the purposes of processing your Cellar Circle, Fine Wine Discovery Club or cellarage payments, speedy check-out, easy refunds and to prevent fraud. The legal basis for this processing is the performance of a contract between you and us.
We may process information that you post for publication on our website or app, such as wall posts or product ratings and reviews ("internal social data"). This internal social data is public, and may be processed for the purposes of enabling interaction on the website between customers, winemakers and staff, and providing feedback to our winemakers on their products. We may also use your posts or reviews in our marketing materials to help us tell other customers about our products and services. In instances where internal social data is stored in an unstructured format (such as free text reviews and wall posts) it is exempt from our data retention rules, however may be deleted upon request. The legal basis for processing internal social data is consent.
We may process data about your use of our website, and reaction to our emails and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The sources of the usage data are our analytics packages (including, but not limited to Google Analytics) and email services providers. This usage data may be processed for the purposes of analysing the use of the website, emails and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
We may process information that you provide to us for the purpose of subscribing to our direct marketing communications and/or newsletters ("communication data"). The communication data may include your name, email address, postal address, phone number or marketing preferences (update them here). This communication data may be processed for the purposes of contacting you with service notifications, such as that your order has been processed, or contacting you with relevant offers and messages. The legal basis for this processing is performance of a contract for service notifications and legitimate interests for direct marketing communications.
We may process information contained in any enquiry you submit to us regarding goods and/or services ("enquiry data"). This enquiry data may be processed for the purposes of providing clarification, resolving issues or marketing relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and to ensure we are responding to your enquiry.
We may process information that you provide to us for the purpose of improving our digital marketing ("digital marketing data"). We may use digital marketing data in a number of different ways: either to advertise our products and services to you on third party websites such as Facebook, or to advertise our products and services to similar customers (lookalikes) on third party websites such as Facebook. We may also use digital marketing data to exclude you from seeing advertisements from third party websites such as Facebook. The digital marketing data may include your name, email address, billing address, phone number, date of birth, gender, and the user ID of any social platforms you have connected with us on. The legal basis for this processing is our legitimate interests, namely providing better services and enhancing our customer base.
Please be aware that CCTV is in operation at our head office.
We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
Please do not supply any other person's personal data to us, unless we prompt you to do so. If you do share your friends’ details with us, please ensure you have their authorisation.
We do not, and will not, sell any of your personal data to any third party – including your name, address, email address or credit card information. We want to earn and maintain your trust, and we believe this is absolutely essential in order do that.
However, we may disclose your personal data with the following categories of companies as an essential part of being able to provide our services to you, as set out in this policy:
Financial transactions relating to our website, app and stores are handled by our card payment service providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
In addition to the specific disclosures of personal data set out in this Section 3, we may disclose your personal data with law enforcement and fraud prevention agencies, so we can help tackle fraud or where such disclosure is necessary for compliance with a legal obligation to which we are subject, in order to protect your vital interests or the vital interests of another natural person, or in connection with the establishment, exercise or defence of legal claims, whether in court or not.
Your data could be processed by our staff working outside the EEA, in particular the United States of America and Australia. We will take all reasonable steps to ensure your information is treated securely and in line with this policy. You acknowledge that personal data that you submit for publication through our website, for example wine reviews, may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.
Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
If you have registered on our website but not purchased from us, the length of time we will retain your data is dependent on whether you have opted into our marketing communications. If you have opted in, we will retain your data for 2 years from registration; if you have not opted in, we will retain your data for 30 days from registration.
Whilst you are an active customer (which, for the avoidance of doubt, means you have purchased from us) we will retain your data for as long as needed to give you the best possible customer service. We will anonymise your personal data 7 years after your last transaction (sale, refund or Cellar Circle, Fine Wine Discovery Club or cellarage payment) provided you have not interacted with us for 2 years. For the purposes of this policy, an interaction is defined as an identifiable website session, or contacting our contact centre. We will inform you before we anonymise your data and give you the option for us to retain your details in order to continue to serve you.
For any wine that you have requested us to keep in our bonded warehouse, whilst it remains under bond we, by law, need to retain the purchase history, including all personal details associated with that purchase in order to prove the bonded value to HMRC.
In all instances outlined above, the process of anonymising your data may take up to one calendar month.
In certain circumstances we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, to resolve disputes and enforce our agreements.
You have a number of rights in respect to your personal data. We have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights. You may exercise any of your rights in relation to your personal data by either (i) emailing us on [email protected], or (ii) calling our Customer Care Team on 01473 313 300.
For details of the way we process information relating to external candidates please refer to our recruitment data retention policy which can be found here.
We may update this policy from time to time by publishing a new version on our website. You should check this page occasionally to ensure you are happy with any changes to this policy.
As a company we do not have a data protection officer, but we do have a team trained to help with any data protection query. If you have any concerns or questions about how we protect your privacy, please contact the team either on [email protected].
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